Lesson 3 — Creating and activating the register
The clock in Articles 8(1) and 11(1) starts at establishment, so the establishment date is the single most consequential field on the record. Get it from the trade licence, not from memory.
Go to UAE UBO Register › Registers and create one for the company. Set the established date. Then press Activate, which moves the register into service and takes the first snapshot at the same moment.
That combination is the mental model for the whole module: activation is an event, not a status flag. From the moment you press it there is a frozen copy of what the register said, and every later change is measured against it.
Every field on a Real Beneficiary record is one the Resolution names in Article 8(2). This is where the sensitive data lands — date and place of birth, home address, passport number — which is why the access rules in Lesson 1 are strict. Grant UBO: Manager to one or two people, UBO: Officer to whoever maintains the entries, and nobody else. An accounting manager, a payroll officer or a general administrator sees nothing: the app is invisible to them, not merely read-only.
Worked example. Al Mirfa Contracting LLC is created with an established date of 3 March 2026 and activated on 11 March 2026 with five of its seven real beneficiaries recorded — the sixth and seventh come from a shareholders' agreement the team is still reading. The first snapshot therefore records a register that was true on 11 March and incomplete by 20 March. That is not a problem; it is the audit trail doing its job. What would be a problem is quietly editing history so it never looked incomplete.
Activate when the register is true, not when it is finished. Waiting for perfection before activating produces no snapshot at all, which means no evidence that you were working on it inside the 60 days. A dated, honest, partial record beats an undated complete one.
The failure mode. "I created the register but nothing happened." Creating a record is not activating it. Until you press Activate there is no first snapshot, and the change log in Lesson 6 has no baseline to compare against.