Who decides whether a company gets a bank account?

The bank does. UAE anti-money laundering rules require banks to verify the customer and its beneficial owners before or while opening an account, and prohibit them from opening or continuing a relationship where they cannot complete those checks. [3][4] The Central Bank's guidance says banks should not keep customers who are unable or unwilling to provide the information they ask for, at opening or at any later review. [2]

Within those rules, each bank applies its own risk appetite. The Central Bank requires banks to consider an SME's application fairly, whatever its size, years in business or the nationality of its owners, in line with the bank's own appetite for financial crime risk. [1]

This guide covers company accounts. A separate guide, Opening a bank account in Dubai, covers personal accounts.

What documents are required to open a corporate bank account in the UAE?

UAE rules require the bank to verify the company's name, legal form, memorandum and articles, registered office and senior managers and, for a company subject to corporate tax, its tax registration number. [3] The Central Bank's guidance sets out what banks collect from company customers: [2]

What the bank asks for Why
Certificate of incorporation, trade licence or official registry extract To confirm the company exists [2][6]
Memorandum and articles of association To confirm its legal form and who controls it [2][3]
Shareholder register and an ownership chart up to each individual To identify every beneficial owner [2][3]
Passport or national ID (such as the Emirates ID) for each owner, senior manager and signatory To verify each person to the same standard [2]
Board resolution or power of attorney for each signatory To show who may give instructions on the account [2]
Proof of the registered office or place of business To confirm where the company operates; a bank may visit [2]
A description of the business, its main countries of operation and its counterparties To understand the purpose and nature of the account [2][3]
Expected payments: types, volumes and countries To judge later whether activity matches the profile [2]
Source of funds and source of wealth, with evidence if the bank asks To show where the money comes from [2]

If the bank does not recognise a foreign document, it can ask for a notarised, apostilled or embassy-certified copy. For a non-resident company with layers of ownership, the guidance says the first layer's ownership documents should be notarised, and each further layer should come with full incorporation documents and details of its beneficial owners. [2]

Who counts as a beneficial owner?

Under Cabinet Decision No. 109 of 2023, a beneficial owner is any individual who owns or controls 25% or more of the shares or votes, directly or through a chain of companies, or who controls the company by other means, such as the right to appoint or remove most of its directors. If no one meets the ownership test, the person who controls the company in another way is treated as its beneficial owner, and failing that, a senior manager. [5] Banks apply the same 25% test. [3]

The decision applies to companies on the mainland and in the commercial free zones; the financial free zones and wholly government-owned companies are exempt. Each company must keep a register of its beneficial owners and give the registrar the name of an individual living in the UAE who is authorised to supply that information. [5] Under the anti-money laundering regulations in force since 14 December 2025, a company must update its beneficial owner information within 15 working days of a change. [3]

Banks verify ownership themselves, from documents, and in higher-risk cases may ask owners to show share certificates or contracts. Where a trust, foundation or nominee sits in the chain, expect the bank to ask who stands behind it. [3][6] Where the bank's findings differ from what the company has told it, and the gap cannot be resolved, the guidance says the account should be rejected, or restricted and closed. [2]

Source of funds and source of wealth: what is the difference?

The Central Bank defines the two separately: [2]

  • Source of funds is the direct source of the money used to fund the account at the start, and of the money that passes through it afterwards, such as the proceeds of a property sale.
  • Source of wealth is what generated the owner's total net worth, such as an inheritance.

Banks record both for every customer at opening. The evidence they ask for rises with the risk: a statement may be enough for a lower-risk customer, while a higher-risk one may be asked for bank statements, property deeds or court rulings. A bank's own policy can require evidence at any level. [2] The guidance lists warning signs, including: [2]

  • a one-word explanation ("inheritance", "investment") with no documents
  • a newly formed company with little history funding the account with large sums
  • money arriving from a third party with no clear link to the company
  • funds coming from high-risk or sanctioned countries

If the money comes from an Indian resident, Indian rules on sending money abroad and investing overseas apply. See our guide to FEMA and the LRS.

Why are UAE corporate bank account applications refused or delayed?

UAE regulations define high-risk customers to include those from high-risk countries, non-residents without an Emirates ID, companies with complex ownership, and customers making large cash transactions, transactions with unknown third parties, or transactions with no clear economic or legal purpose. Banks must apply enhanced checks where they identify higher risk. [3] The Central Bank's guidance for company accounts adds: [6]

  • Country links: enhanced checks are mandatory when the company or its owners are based in a high-risk jurisdiction.
  • Activity: cash-heavy sectors, money services and payments, dual-use goods, and charitable work tied to high-risk countries.
  • Unclear business model: the guidance calls revenue with no apparent business activity "perhaps the highest risk".
  • No visible operations: no physical presence and few or no employees are listed as signs of a shell company, while accepting that such companies can have legitimate purposes.

The Central Bank names convenience stores, retail, restaurants, wholesale and general trading, travel agencies and car dealers as examples of cash-intensive businesses. It says most are legitimate, and asks banks to assess whether each one needs enhanced checks. [7]

If a bank rejects an SME's application, it must give the reason in writing, except where the reason relates to financial crime risk or the law prevents disclosure. [1]

How long does it take to open a business bank account in the UAE?

The Central Bank's SME Customer Protection Regulation (C 2/2026) took effect on 13 September 2026. It covers small, micro and medium businesses within the official limits on staff and turnover, including sole proprietors, banking with Central Bank-licensed banks and finance companies. [1]

  • 3 business days: banks must have systems to open an account within 3 business days for an applicant they assess as low risk, counted from the day all documents and information have been provided. [1]
  • The exception: the deadline is waived where the bank is applying the UAE's financial crime requirements, and the bank must record why. [1]
  • Other delays: where an application is accepted but delayed for other valid reasons, the bank must explain why. A low-risk applicant may get the account with limits on transactions in the meantime, and the delay must not exceed 2 weeks. [1]
  • Deposits: money paid in before checks are complete is blocked until they are finished, and the bank must tell you so in writing. [1]

The regulation sets no deadline for other applicants. [1] Plan payroll, supplier payments and customer collections on the basis that the account may take longer than the company licence.

Can a non-resident open a company bank account in the UAE?

The rules we reviewed don't bar it. They require the bank to identify and verify every owner and signatory, and they treat non-residents without an Emirates ID as higher-risk customers, which means enhanced checks. [2][3] The Central Bank's guidance also treats opening an account remotely, without the customer or its representative present, as a higher-risk situation where banks should consider extra means of verification. [2]

In practice each bank sets its own policy on non-resident owners and signatories. Ask before you apply, and expect to provide certified documents from your home country. [2] Separately, a mainland or commercial free zone company must give its registrar the name of an individual living in the UAE, as set out under beneficial owners above. [5]

Free zone, mainland and offshore companies: does the bank treat them differently?

The same checks apply to every company, wherever it is licensed. The evidence each type can offer differs: [2][3][6]

  • Mainland and free zone companies trading from the UAE usually have a lease, and often staff and invoices, to show. Banks may ask for invoices and payroll records, or visit the office, to confirm the activity. [2][6]
  • Offshore companies, such as a RAK ICC company holding property, often have no UAE office or staff. RAK ICC lists the ability to open a local or international bank account, for example to receive rent, among the advantages of its property holding companies. [8] The bank still decides. Expect it to ask what the company holds, who owns it and why the account is needed, because no physical presence and no employees are among the shell company indicators banks are told to check. [6]

Is there a minimum balance for a UAE corporate account?

Banks set their own minimum balances and fees. We found no official minimum that applies across the market. The Central Bank's SME rules require that: [1]

  • fees are fair and proportionate to the bank's costs and the customer's size
  • the bank gives a written schedule of fees
  • no fee is charged for updating identity documents that the law requires
  • no closing fee applies once the account has been open 6 months or more

Ask each bank for its fee schedule and minimum balance in writing before you apply.

Keeping the account open: reviews, dormancy and closure

Checks continue for as long as the account is open. [2]

  • Periodic reviews. Banks review customers on a cycle set by risk. The Central Bank's example is every year for high-risk customers, every 2 years for medium risk and every 3 years for low risk, plus reviews after events such as a change of ownership. [2]
  • What a review covers. Updated identity documents for the company, its owners and signatories, a check that real activity matches the expected activity, and fresh sanctions screening. [2]
  • When the company changes. The company must update its beneficial owner information within 15 working days of a change. [3] Tell the bank at the same time.
  • Closure by the bank. A bank that cannot complete its checks must not continue the relationship. [3]
  • Dormancy. A company current or savings account becomes dormant after 3 years with no transactions, service requests or contact, where the company has no other active account with that bank and the bank has no current address for it. The bank must first try to contact the company. Once 5 years have passed since the last transaction, the balance moves to the Central Bank and the account is closed; the money can still be claimed back through the bank. [9]
  • Complaints. A bank must give an SME customer a final written answer to a complaint within 30 business days. Unresolved complaints can go to Sanadak, the UAE's Ombudsman Unit for financial complaints. [1]

Corporate tax, VAT and your company bank account

  • Your tax number is part of the file. The bank must obtain it (see documents above). [3] Registration deadlines are in UAE corporate tax explained.
  • Refunds. A registered business claims VAT, excise and corporate tax refunds through EmaraTax. For a refund of an overpayment, the Federal Tax Authority asks for a bank IBAN letter. It estimates 25 business days for a completed request, or 55 working days if it needs an audit review. [10]
  • Payroll. Every employer registered with the Ministry of Human Resources and Emiratisation must pay wages through the Wage Protection System, by transfer through a bank, exchange house or other institution authorised by the Central Bank. [11]

Before you apply: questions a bank will ask

  • Can you explain in one page what the company sells, to whom, and where?
  • Can you show every owner and controller, up to each individual, including any trust, foundation or holding company?
  • Can you trace the first deposit, and the owners' wealth, with documents?
  • Do the expected payments and countries match the business?
  • Do the names, dates and amounts agree across every document?
  • If the account takes longer than planned, how will you pay staff and suppliers?

How Marlborough Gulf helps

What we do:

  • We set up the company in DMCC, RAK ICC and the other zones that license through corporate service providers, and keep its registers and records up to date.
  • We prepare the file the bank will review: the ownership chart, the business profile, the expected activity and a reconciled source-of-funds and source-of-wealth file.
  • We coordinate the application with the bank you choose and track its questions, and we keep the file current for later reviews.

What others do: The bank decides whether to open the account and on what terms. Lawyers advise on foreign documents and structures, and tax advisers in each country advise on their own rules.

Company formation in the UAE → Accounting and bookkeeping →

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Common questions

Can I open a company bank account in the UAE without a trade licence?

No. The bank must verify the company's name, legal form and founding documents, so the company has to exist and be registered first. [3]

What documents are required to open a corporate bank account in the UAE?

The licence or certificate of incorporation, memorandum and articles, shareholder register and ownership chart, IDs of owners, managers and signatories, a board resolution, proof of address, a business profile and source-of-funds information. [2][3]

Can a non-resident open a business bank account in Dubai?

UAE rules don't bar it, but non-residents without an Emirates ID are treated as higher risk, so expect enhanced checks. Each bank sets its own policy on non-resident owners and signatories. [2][3]

Can an offshore company open a bank account in the UAE?

The rules don't bar it, and RAK ICC lists a local or international bank account among the advantages of its property holding companies. Expect detailed questions about what the company holds and why it needs the account. [6][8]

Which bank opens a business account the fastest?

We don't name or rank banks. For SMEs the bank assesses as low risk, Central Bank rules require systems to open the account within 3 business days of a complete application. [1]

Will the bank tell me why my application was rejected?

For an SME, yes, in writing, unless the reason relates to financial crime risk or the law prevents it. [1]

This guide is general information, not legal, tax or financial advice for your circumstances. Banks set their own requirements, and the bank decides every application.

Marlborough Gulf does not give investment, pension or insurance advice. Regulated services are provided by licensed firms, who contract with you directly.

Sources

  1. Central Bank of the UAE, Small to Medium Sized Enterprises (SME): Customer Protection Regulation (C 2/2026), effective 13 Sep 2026, Articles 1.13, 1.33, 3.12, 4.31, 4.39 to 4.52, 6.9, 6.16 and 13.1, CBUAE Rulebook, read 29 Oct 2026. https://rulebook.centralbank.ae/en/rulebook/small-medium-sized-enterprises-sme-customer-protection-regulation
  2. Central Bank of the UAE, Guidance for Licensed Financial Institutions on Customer Due Diligence/Know Your Customer and Record-Keeping, effective 7 Nov 2025, sections 3.1 to 3.4, CBUAE Rulebook, read 29 Oct 2026. https://rulebook.centralbank.ae/en/rulebook/guidance-licensed-financial-institutions-customer-due-diligenceknow-your-customer-and
  3. Cabinet Resolution No. 134 of 2025 on the Executive Regulations of Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, effective 14 Dec 2025, Articles 1 ("High-Risk Customers"), 5, 6, 9, 10, 14, 23 and 38, CBUAE Rulebook, read 29 Oct 2026. https://rulebook.centralbank.ae/en/rulebook/cabinet-resolution-no-134-2025-regarding-executive-regulations-federal-decree-law-no-10
  4. Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing, effective 14 Oct 2025, Articles 1 ("Customer Due Diligence") and 19, CBUAE Rulebook, read 29 Oct 2026. https://rulebook.centralbank.ae/en/rulebook/federal-decree-law-no-10-2025-regarding-anti-money-laundering-and-combating-financing
  5. Cabinet Decision No. 109 of 2023 Regulating the Beneficial Owner Procedures, English version, Ministry of Economy and Tourism, Articles 3, 5, 8 and 11 (in force; listed on the CBUAE Rulebook, effective 16 Nov 2023), read 29 Oct 2026. https://www.moet.gov.ae/documents/20121/0/Cabinet+Decision+109-2023+English+Version+06062024.pdf/f7138fc2-fe12-cef3-077b-b4c49c12eabd?t=1718181974877
  6. Central Bank of the UAE, Guidance for Licensed Financial Institutions Providing Services to Legal Persons and Arrangements, effective 7 Jun 2021, CBUAE Rulebook, read 29 Oct 2026. https://rulebook.centralbank.ae/en/rulebook/guidance-licensed-financial-institutions-providing-services-legal-persons-and-arrangements
  7. Central Bank of the UAE, Guidance for Licensed Financial Institutions Providing Services to Cash-intensive Businesses, effective 27 Sep 2021, CBUAE Rulebook, read 29 Oct 2026. https://rulebook.centralbank.ae/en/rulebook/guidance-licensed-financial-institutions-providing-services-cash-intensive-businesses
  8. RAK ICC, Holding Company (Holdco), read 29 Oct 2026. https://www.rakicc.com/services/holding-company/
  9. Central Bank of the UAE, Dormant Accounts and Unclaimed Funds Regulation (C 9/2025), issued 31 Dec 2025, Articles 2.1, 2.2, 3.1, 4.1 and 8.1 to 8.3, CBUAE Rulebook, read 29 Oct 2026. https://rulebook.centralbank.ae/en/rulebook/dormant-accounts-and-unclaimed-funds-regulation
  10. Federal Tax Authority, Tax Refund to Registered Tax Payers, page updated 19 Aug 2026. https://tax.gov.ae/en/services/refund.of.extra.payments.paid.to.the.fta.aspx
  11. u.ae, Payment of wages (Ministerial Resolution No. 340 of 2026 on the Wage Protection System), updated 14 Oct 2026. https://u.ae/en/information-and-services/jobs/Sector-of-employment/employment-in-the-private-sector/payment-of-wages