Direct answer: The UBO is the natural person who ultimately owns or controls the company, directly or through entities or arrangements. Naming an intermediate company is not enough.

Practical steps

• Map ownership to natural persons
• Collect registers and voting agreements
• Assess indirect control and appointment rights
• Record the data and retain evidence
• Update after ownership or control changes

Documents and decisions

• Current ownership chart
• Intermediate-company records
• Identity evidence
• Voting and control agreements
• Change resolutions

Common mistakes

• Confusing manager and owner
• Stopping at a holding company
• Ignoring contractual control
• Keeping stale data

Frequently asked question

Is the UBO always the largest shareholder?

No. Contractual or managerial control can point to another natural person.

Next step

Review the activity, ownership, funding and licensing path before commitments. See Legal Protector in English and related articles, then request a project-specific legal assessment.

Source and legal review

Primary official source: Financial Regulatory Authority guidance. Legal reviewer: Tarek Ibrahim. Reviewed on 4 October 2026. Requirements must be rechecked at filing.