Lesson 1 — What Cabinet Resolution 109 of 2023 requires
Before any software, the obligation.
Cabinet Resolution No. 109 of 2023 on the Regulation of Real Beneficiary Procedures was issued on 6 November 2023. Article 22 cancels Cabinet Resolution No. 58 of 2020, which is the instrument most circulating checklists still cite. If your file refers to 58 of 2020, it is out of date, and so is anything built on it. Source: Cabinet Resolution 109/2023, Art. 22.
A licensed or registered legal person in the UAE keeps three things:
- The Real Beneficiary Register — the natural persons who ultimately own or control the company, with the data the Resolution itself names. Article 8.
- The Partners or Shareholders Register — who holds what on paper, which is a different question and often a different answer. Article 10.
- Board nominee member disclosures — a board member acting on another person's instructions declares it, and the declaration is recorded inside the Partners or Shareholders Register. Articles 9 and 10(2).
The idea to carry forward: these are registers you keep, not returns you file. Nobody stamps them, nobody approves them, and nothing tells you they are wrong until an authority asks. That is exactly why the record has to be defensible on its own — it is the only evidence that exists.
A scope question you must answer yourself. Article 3(2)(b) excludes "Financial Free Zones" from the Resolution, but it never names them. The module therefore ships no list of excluded zones, and this course will not invent one. Confirm your own position with your registrar or your advisor before you assume you are outside the regime — assuming you are inside it and keeping a good register costs you very little.
Odoone's implementation is a single module. Install Odoone UBO Register from Apps. It depends on Odoone Base, which supplies the Settings › Odoone section, and its own menus live in their own top-level app called UAE UBO Register.
Nobody sees that app until you put them in a group. Grant UBO: Officer to the people who maintain the register and UBO: Manager to whoever configures the regime and handles authority requests, both under Settings › Users. Access is never inherited from an accounting or compliance role: an accounting manager cannot see this data unless you add them by hand. That is a deliberate design decision, not an oversight, and Lesson 3 explains why it is the right one.
The failure mode. "I cannot see the UAE UBO Register app at all." You are not in a UBO group. That is the default state for every user in the database, including administrators of everything else, and it is working exactly as intended.