Saudi Arabia: Ultimate Beneficial Ownership

Minister of Commerce of Saudi Arabia issued Decision no. 235, which sets out notification requirements in respect of Ultimate Beneficial Owners (UBOs) of companies.  This decision will become effective on 05/10/1446H (corresponding to 03/04/2025G) and will apply to all companies subject to the Saudi Companies Law, except for joint stock companies listed on Tadawul, the Saudi stock exchange.

Key changes and requirements

The stated objectives of the new UBO decision are to enhance corporate transparency in alignment with international requirements and to establish a database to register and maintain UBO data.

New companies are required to disclose information and supporting documentation regarding their UBOs when applying for incorporation. Existing companies, must make their UBO disclosures to the Ministry of Commerce (MoC) within one year from the date of the company's registration in the Commercial Register.

Companies are required to use reasonable measures to identify their UBOs and obtain the required information and supporting documents. They must prepare a special register in which such information and documents are recorded. Additionally, companies are required to submit a request to MoC to update their disclosures within 15 days from the date of any change or amendment. An annual confirmation of the continued accuracy of disclosures must also be submitted to the MoC.

How can we help?

Computershare Governance Services global team of professionals are available to guide you through the process of determining the beneficial owner and the ongoing advisory oversight to monitor a change in the organization structure that may result in a triggering event that will require an update to the Registrar for a change of the beneficial owner.  

Computershare’s leading entity management system GEMS can also help you to manage and store your beneficial ownership information, as well as the information about shareholdings, ownership, and directorships on a global basis.  

Contact:

Please contact your dedicated Computershare Relationship Manager or send an email to globalentityservices@computershare.com for more information about how Computershare may assist you in responding to these new requirements.

This notice is provided by Computershare for general informational purposes only and is not intended and should not be construed as legal, regulatory, financial or tax advice. Computershare is not licensed or authorized to practice law in any jurisdictions and hence does not provide any legal advice and it does not hold itself out as doing so. Neither Computershare nor any of its affiliates or contributors accept any responsibility or liability for the quality, accuracy or completeness of any information contained in this notice. It is important that you seek independent professional advice relating to the subject matter of this notice before relying on it.