Ultimate Beneficial Ownership in Saudi Arabia: A Practical Compliance Guide for 2026

Saudi Arabia has strengthened its corporate transparency framework through Ministerial Decision No. 235, introducing mandatory Ultimate Beneficial Ownership (UBO) reporting for most companies operating in the Kingdom. Effective 3 April 2025, companies must identify their actual beneficial owners, maintain accurate internal records, and file verified UBO information through the Saudi Business Center (SBC) platform under the Ministry of Commerce.

UBO compliance is now directly linked to Commercial Registration (CR) issuance and renewal, banking procedures, and overall business continuity. Every company operating in Saudi Arabia in 2026 must treat UBO disclosure as a fundamental compliance obligation.

This guide explains what UBO means, who must comply, and the key actions businesses need to take to remain compliant.

What Is an Ultimate Beneficial Owner (UBO)?

An Ultimate Beneficial Owner (UBO) is the natural person who ultimately owns or controls a company, even when ownership is held through multiple entities or foreign structures.

A person qualifies as a UBO if they:

• Own 25% or more of shares or voting rights (directly or indirectly), or
• Have authority to appoint or remove the manager or majority of board members, or
• Exercise significant influence over decisions or operations

If no individual meets these criteria, the company’s manager, chairman, or another person with effective control may be designated as the UBO.

Who Must Comply?

UBO rules apply to nearly all companies registered under the Saudi Companies Law, including:

• LLCs
• Non-listed joint stock companies
• Foreign-owned branches and subsidiaries
• Professional firms
• Holding companies

Exempt entities include:

• Tadawul-listed companies
• Companies fully owned by the Saudi government
• Companies under liquidation under the Bankruptcy Law (with proof)

All non-exempt companies must identify, document, and submit UBO information.

What Businesses Must Do in 2026

The following steps outline the core actions companies must take to comply with Saudi Arabia’s UBO requirements.

1. Map Your Ownership Structure

Companies must clearly identify the individuals who ultimately own or control the business by:

• Listing all direct and indirect shareholders
• Tracing ownership through holding companies or offshore entities
• Identifying persons meeting the 25% ownership or control threshold
• Recognising individuals with meaningful influence even below 25%

2. Update Your Articles of Association (AoA) and Corporate Records

UBO filings must match your current legal structure.

Review and update:

• Articles of Association (AoA)
• Shareholder register
• Share certificates
• Capital change or transfer documents

Outdated documentation can lead to incorrect filings and compliance delays.

3. Maintain an Internal UBO Register in Saudi Arabia

Companies must maintain a dedicated UBO register stored inside the Kingdom, containing:

• Full name of each UBO
• National ID / Iqama / passport information
• Residential address
• Basis for UBO status (ownership %, control rights, influence)
• Dates of becoming or ceasing to be a UBO

The register must be accurate, complete, and available upon request.

4. Submit UBO Information Through the SBC Portal

All UBO submissions must be made digitally through the Saudi Business Center (SBC).

Companies must file UBO information:

• During incorporation
• Before CR issuance or renewal
• During annual confirmation (for multi-year CRs)

Missing or incomplete UBO filings can delay or block CR renewal, affecting the company’s ability to conduct banking, issue invoices, or access government platforms.

5. Report Any Changes Within 15 Days

Companies must update UBO information within 15 days of any event that affects ownership or control, including:

• Share transfers or capital changes
• Addition of new holding entities
• Changes to voting or appointment rights
• Appointment of a new manager or chairman (if designated UBO)

Timely updates help prevent discrepancies and compliance risks.

6. Keep Supporting Documents Ready

Companies should maintain up-to-date, organised documentation, including:

• Commercial Registration (CR)
• AoA and amendments
• Shareholder register
• Share transfer documents
• Identification copies for each UBO

These records support smooth audits, due diligence, and regulatory verification.

Enforcement and Penalties

Non-compliance with UBO obligations may result in:

• Fines up to SAR 500,000
• Delays in CR renewal
• Banking and financial restrictions
• Increased regulatory scrutiny

Accurate UBO reporting is now essential for maintaining uninterrupted business operations in Saudi Arabia.

Partner with TASC for End-to-End UBO Compliance

With over 18 years of GCC experience and a dedicated on-ground Saudi GRO/PRO team, TASC Corporate Services brings unmatched precision and local expertise to UBO compliance. We handle the entire process from ownership mapping and UBO register creation to AoA alignment, documentation review, and SBC filings, ensuring your disclosures are accurate, complete, and fully compliant.

Partner with TASC to stay fully UBO compliant in 2026 and beyond. Contact us today.

Frequently Asked Questions

1. Why is UBO compliance required?
To ensure transparency and identify the individuals who ultimately control the business.

2. Where is UBO information submitted?
Through the Saudi Business Center (SBC) digital portal.

3. What if no one owns 25% or more?
The manager, chairman, or another person with effective control may be designated as the UBO.

4. Who must comply?
All companies under the Companies Law except listed, government-owned, and liquidated entities.

5. Can TASC assist with UBO compliance?
Yes. TASC provides full support from documentation review and register creation to SBC filings and ongoing compliance management.