In the Abu Dhabi Global Market, the settlor, trustee, beneficiaries, protector and enforcer of an entity are now expressly identified as beneficial owners, with strengthened disclosure obligations. In the Dubai International Financial Centre, the Family Arrangements Regulations replaced the former Single Family Office regime and raised the aggregate net asset threshold required of the family to USD 50 million, against USD 10 million previously.
What happened
In the Abu Dhabi Global Market (ADGM), the Abu Dhabi financial centre operating its own corporate law framework, the rules now expressly identify as UBO — ultimate beneficial owner, the natural person who ultimately controls or benefits from an entity — the settlor, the trustee, the beneficiaries, the protector and the enforcer of a fiduciary structure, with strengthened disclosure obligations attaching to each. In the Dubai International Financial Centre (DIFC), the Family Arrangements Regulations 2024 replaced the former Single Family Office regime and raise the aggregate net asset threshold required of the family to USD 50 million, against USD 10 million under the preceding regime. The DIFC register recorded 158 new foundations in the first quarter of 2026, more than double the same quarter of 2025.
What changes in practice
Anyone who established a UAE foundation or trust on the expectation of confidentiality needs to reassess what is now reportable: the population of persons to be declared as beneficial owners has widened and includes roles that do not appear anywhere on a shareholder register. A protector appointed for governance reasons, or a class of discretionary beneficiaries, may now sit within the disclosure perimeter. On the DIFC side, a threshold multiplied by five removes from the family office regime a band of wealth that could previously access it, which affects both new applications and structures built on the assumption that the old figure would hold.
Who it applies to
Principals holding shareholdings, real estate or financial assets through foundations, trusts or family vehicles established in the ADGM or the DIFC, and those currently evaluating these instruments for succession planning. It is also relevant to trustees, protectors and family office executives who may themselves now be disclosable persons, and to advisers who structured such vehicles under the previous rules and have not revisited them since.
The exposure
The exposure is maintaining a structure that continues to cost — trustee fees, corporate service provider charges, audit, annual filings — without still producing the effect for which it was created. This situation gives no warning signals: the structure remains formally in good standing, and the mismatch between cost and benefit only surfaces when someone measures it. A secondary exposure is a disclosure failure arising not from concealment but from an outdated understanding of who counts as a beneficial owner.
What to do now
Retrieve the constitutional documents of the structure and the list of every person appearing in it in any capacity, and test that list against the current definition of beneficial owner to establish who is reportable today but was not before. Where the vehicle was established under the DIFC Single Family Office regime, confirm which regime it now falls within and whether the family meets the revised threshold. Because this is a developing regulatory area, read the current texts on the official ADGM and DIFC portals, and take advice, before amending an existing structure — a restructuring undertaken on an outdated reading can be more costly than the position it was meant to fix.
Sources
Published 18 August 2026 on the basis of public sources and official United Arab Emirates instruments. This is not legal or tax advice. Verify your position with a qualified professional before acting.