On 30 July 2026, Kuwait’s Ministry of Commerce and Industry (“MOCI”) issued Ministerial Decision No. 156 of 2026, amending Ministerial Decision No. 4 of 2023 on procedures for identifying the Ultimate Beneficial Owner (“UBO”). The amendment follows an earlier set of changes introduced by MOCI Resolution No. 16 of 2025 and is the latest in a series of amendments to Kuwait’s UBO framework. While the 2025 amendment expanded the scope of application, tightened the penalty regime, and refined registration data requirements, Decision No. 156 of 2026 is narrower in scope but has immediate operational consequences: it significantly shortens the compliance deadlines within which legal persons must establish, update, and file beneficial ownership information. This update explains what changed, why it matters, and what companies should do now.

What Changed

Decision No. 156 of 2026 amends three provisions of Ministerial Decision No. 4 of 2023—specifically Item (1) of Articles 8, 9, and 11—by reducing the prescribed compliance timelines from their previous lengths to a uniform 15 days:

Beneficial Owner Register (Article 8(1)): A legal person must now establish and populate its UBO register within 15 days of the decision’s implementation date or the date the entity came into existence. Under the prior framework, this deadline was 60 days. The pre-existing obligation to record any change to the register within 15 days of awareness (or presumed awareness) remains unchanged.

Nominee Board Member Notification (Article 9(1)): A director or board member acting in a nominee capacity must notify the legal person of that status within 15 days of acquiring the capacity, a deadline that was already in place under the original framework. Existing nominee board members (those holding the capacity prior to publication of the decision) must likewise notify within 15 days of publication. The prior notification window for existing nominees was 30 days — this is the only change made by Decision 156/2026 to Article 9(1).

Filing with the Registrar (Article 11(1)): A legal person must submit its UBO register data and register of partners or shareholders to the registrar within 15 days of the decision’s implementation date or from the date of licensing and registration. The previous deadline was 60 days. Entities must also take reasonable measures to safeguard their records from damage, loss, or destruction.

Why the Change Matters

The tightening of deadlines should be read in the context of Kuwait’s broader transparency and AML/CFT agenda. The original 2023 UBO framework was introduced to meet international standards—particularly Financial Action Task Force (FATF) recommendations—requiring jurisdictions to ensure that competent authorities have timely access to adequate and accurate beneficial ownership information. The 2025 amendment escalated enforcement, introducing administrative fines of KD 1,000 to KD 10,000 per violation, registration suspension for up to three months, and the possibility of court-ordered deletion from the Commercial Register for sustained non-compliance. It also conditioned license grant or renewal on UBO compliance.

Decision No. 156 of 2026 completes this trajectory by compressing the time within which ownership and control information must reach the public register. A 60-day window allowed entities significant latitude to delay—or structure around—filing obligations. Reducing this to 15 days aligns Kuwait’s framework more closely with international best practice, where real-time or near-real-time beneficial ownership disclosure is increasingly the expectation.

Practical Impact

Newly formed entities: any company registered or licensed after the decision’s effective date must submit complete UBO data to the registrar within 15 days of formation. This effectively makes UBO filing a near-immediate post-incorporation step, comparable in urgency to commercial register entry itself.

Ongoing change management: the 15-day rolling update obligation means that any share transfer, change of control, restructuring, death of an owner, or new nominee arrangement must be reflected in the UBO register and filed with the registrar within 15 days. Companies must build internal processes to capture these events promptly.

Nominee directors: the compressed notification window puts immediate pressure on nominee board members to formalize their status. In practice, this also means that legal persons must have a mechanism to receive, acknowledge, and file nominee notifications rapidly.

M&A and investment transactions: acquirers, investors, and lenders should factor UBO filing timelines into transaction planning. A completion or closing that changes beneficial ownership triggers a 15-day clock—due diligence checklists and condition-precedent schedules should account for this.

Penalty exposure: the shorter deadline increases the risk of inadvertent non-compliance. With administrative fines of up to KD 10,000 per violation, registration suspension, and the potential for license non-renewal already in place (per the 2025 amendment), the cost of missing the new 15-day window is material.

Recommended Next Steps

We recommend that companies, investors, and advisors take the following actions:

1. Audit current UBO registers: confirm that all beneficial ownership data is complete, accurate, and filed with the registrar. Treat the decision as a reset point.
2. Establish internal notification protocols: ensure that share transfers, board changes, nominee appointments, and control shifts are flagged to compliance officers within days—not weeks—of occurrence.
3. Update transaction playbooks: for M&A, joint ventures, and financing transactions, build the 15-day UBO filing into post-closing action lists and designate responsibility for timely submission.
4. Brief boards and managers: directors and senior managers are the natural compliance owners. They should understand the compressed timelines and their personal exposure under the framework.
5. Monitor further MOCI guidance: the decision took effect immediately upon issuance. Further implementing instructions or clarifications from MOCI may follow and should be tracked.

Conclusion

Ministerial Decision No. 156 of 2026 is procedural in form but operational in effect. It does not change who qualifies as a UBO, what information must be disclosed, or what penalties apply—but it materially changes how quickly that information must reach the register. For companies with clean records, the impact is manageable. For those with outdated filings, undisclosed nominee arrangements, or pending ownership changes, the 15-day window leaves little room for delay. We encourage market participants to treat this amendment as a compliance trigger and to act promptly.

For assistance with UBO compliance, corporate restructuring, or transaction planning in light of Decision No. 156 of 2026, please contact our Kuwait office.

Authors: Alex Saleh, Managing Partner and Fahad Alzouman, Trainee Lawyer