Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2025

Saudi Arabia

Saudi Arabia joined the Global Forum in 2009. Saudi Arabia underwent its Second Round of EOIR Peer Review in 2019 (Saudi Arabia’s 2019 Report),1 which assessed its legal and regulatory framework in force as at 2 August 2019 and its practical implementation, including in respect of requests received and sent during the review period from 1 January 2015 to 31 December 2017. Saudi Arabia received an overall rating of Largely Compliant and the individual Elements were rated as follows:

 

	A.1	A.2	A.3	B.1	B.2	C.1	C.2	C.3	C.4	C.5	Overall
Determinations	i.p.b.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	n.a.	LC
Ratings	LC	LC	C	C	C	C	C	C	C	PC

Status of implementation of recommendations issued in the peer review report

Saudi Arabia received seven in-box recommendations in relation to Elements A.1, A.2 and C.5.

This monitoring report assesses the actions taken by Saudi Arabia to address the recommendations issued in its EOIR Peer Review Report and the peer input received for the monitoring period 2023-2024.

The report concludes that two recommendations are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”, and five recommendations are “in the process of being addressed”, and it advises on actions required.

Element A.1: Availability of ownership and identity information

1. Coverage of all entities for beneficial ownership information

 

Recommendation (A.1, framework)	Saudi Arabia should ensure that comprehensive beneficial ownership information in line with the standard is available in respect of all entities.
Underlying factor	While the vast majority of entities would have an account with a Saudi bank which is required to keep comprehensive beneficial ownership information on its clients, there may be entities which do not. Most entities (LLCs [Limited Liability Companies], non-listed JSCs [Joint Stock Companies] and limited partnerships) must also collect and report beneficial ownership information to the authorities, however the scope of information that must be collected and reported does not match the definition of beneficial owner as used in the Terms of Reference. (see paragraphs 62, 63 et seq., and 120 of Saudi Arabia’s 2019 Report for more information)
Summary of actions reported	The November 2017 Ministerial Resolution that required all companies and limited partnerships to maintain beneficial ownership information has been repealed and replaced by a new Ministerial Resolution which imposes similar obligations and contains new “Ultimate Beneficial Owner Rules” which have entered into effect from 3 April 2025. These new rules require legal entities to maintain an up-to-date register of ultimate beneficial owners, including direct and indirect ownership details and manager information. This register must be kept at the company’s headquarters and submitted to the Ministry of Commerce upon establishment or modification. The rules impose requirements for maintaining underlying documentation for such identification. The Ministerial Resolution envisages that the Ministry of Commerce establish a Beneficial Owner Register which will include all the beneficial owner data submitted by the companies. Additionally, companies would be required to update their beneficial ownership information annually. Further, a Guidance Manual has been issued in 2025 regarding procedures and measures that companies should follow to identify their beneficial owners, obtain their data and disclose it to the Ministry.
Conclusion	Saudi Arabia has made progress to address the recommendation through the introduction of the Ultimate Beneficial Owner Rules. Further details are required to ensure that beneficial owners of legal persons are identified in line with the standard and that penalties are available for reporting inaccurate information to the beneficial ownership register. Saudi Arabia should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment, Saudi Arabia should – Report on measures taken to ensure the accurate identification of beneficial owners of legal persons, including in cases of joint ownership and control, or when charities, cooperative societies, awqaf, non-profit entities, or special-purpose entities appear in the ownership chain of the legal persons. Report on penalties available for submitting incorrect or false information.

2. Beneficial ownership information of inactive entities

 

Recommendation (A.1, practice)	Saudi Arabia should review its system whereby a significant number of inactive companies remain with legal personality on the Commercial Register.
Underlying factor	The large number of inactive companies that maintain legal personality and do not comply with their filing obligations raises concerns that beneficial ownership information might not be available in all cases. (see paragraphs 70 et seq. of Saudi Arabia’s 2019 Report for more information)
Summary of actions reported	The requirement to keep up-to-date beneficial ownership information applies to all entities covered by the Company law, including inactive entities. Failure to comply with obligations related to beneficial ownership information may be subject to sanctions, including financial penalties. From April 2025, a new Law on Commercial Register has entered into effect, which includes a range of legal measures to ensure the timeliness of commercial information and grants the Ministry of Commerce significant powers to address the challenges of inactive commercial registrations.
Conclusion	Saudi Arabia has taken steps in the form of the new law to address the recommendation, but these legal changes are very recent. The effective implementation and enforcement of this new law is required to ensure that beneficial ownership information is available in line with the standard in all cases, including for inactive companies. Saudi Arabia should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment, Saudi Arabia should – Report on the supervisory measures taken in respect of companies that are suspended for non-compliance with beneficial ownership reporting obligations, along with the outcomes of the supervisory measures, and relevant statistics. Report on the supervisory measures taken in respect of already identified inactive entities (prior to the enactment of the 2025 Law on Commercial Register) and their outcomes, along with relevant statistics.

3. Supervisory mechanisms for compliance with beneficial ownership information requirements

 

Recommendation (A.1, practice)	Saudi Arabia should ensure that adequate supervisory mechanisms are in place to investigate, pursue and sanction cases of noncompliance with the new obligation for companies and partnerships to keep beneficial ownership information and provide it to the authorities.
Underlying factor	On 15 November 2017 an obligation was introduced pursuant to a Ministerial Resolution requiring companies to maintain information about beneficial ownership and reporting of that information to the Commercial Register. The Ministry of Commerce and Industry did not update its supervisory and enforcement mechanisms to ensure that the relevant information is collected and reported in all cases. (see paragraphs 63 et seq. and 85 of Saudi Arabia’s 2019 Report for more information)
Summary of actions reported	The Ministry of Commerce has been upgrading its supervisory and enforcement mechanisms to ensure that the relevant information is collected and reported in all cases. The Companies Law was amended to allow for the formation of a Companies Committee in June 2022, under a resolution of the Minister of Commerce, which has the power to impose fines. The control measures applied checked compliance with beneficial ownership and accounting record-keeping obligations. The Companies Committee identified a total of 1 236 violations for the years 2020-2022.
Conclusion	Saudi Arabia has made progress to address the recommendation but entities’ obligations to maintain and report beneficial ownership information have changed recently and require monitoring and supervision to ensure effective implementation for the availability of adequate, accurate and up-to-date beneficial ownership information of legal persons is available in practice. Saudi Arabia should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment, Saudi Arabia should – Report information on the implementation of the beneficial ownership requirements by entities registered with the Ministry of Commerce. Report on steps taken to ensure that adequate, accurate and up-to-date beneficial ownership information of entities is available in practice, including sufficient means to compel the cooperation of the beneficial owner and the interposed persons. Report information, including statistics, on supervision and enforcement of entities’ obligations to maintain and report beneficial ownership information.

Element A.2: Availability of accounting information

4. Retention of underlying accounting documentation

 

Recommendation (A.2, framework)	Saudi Arabia should ensure that all LLCs [Limited liability companies], ULCs [Unlimited liability companies] and LPs [Limited partnerships] are required to keep underlying documentation and to keep accounting records for a period of at least 5 years.
Underlying factor	LLCs [Limited liability companies], ULCs [Unlimited liability companies] and LPs [Limited partnerships] with a capital of SAR 100 000 (EUR 24 000) or less without foreign partners are not expressly required to keep underlying documentation or to keep documentation for at least 5 years. (see paragraphs 158 et seq. of Saudi Arabia’s 2019 Report for more information)
Summary of actions reported	The Law on Commercial Books, the income tax law, the zakat obligations and the Value Added Tax Implementing Regulations contain legal provisions for the retention of accounting records.
Conclusion	Saudi Arabia has made progress to address the recommendation, but the availability of underlying accounting documentation of all relevant legal entities and arrangements for a period of at least five years is yet to be assured. Saudi Arabia should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment, Saudi Arabia should – Report on measures taken to ensure that accounting records are available in all cases in line with the standard.

5. Accounting records on inactive entities

 

Recommendation (A.2, practice)	Saudi Arabia should review its system whereby a significant number of non-complying inactive companies remain with legal personality on the Commercial Registry.
Underlying factor	The large number of inactive companies that maintain legal personality and do not comply with their filing obligations raises concerns that accounting records information might not be available in all cases. (see paragraph 173 of Saudi Arabia’s 2019 Report for more information)
Summary of actions reported	Same as for Recommendation 2.
Conclusion	Saudi Arabia has taken steps in the form of the new law to address the recommendation, but these legal changes are very recent. The effective implementation and enforcement of this new law is required to ensure that accounting information is available in line with the standard in all cases, including for inactive companies. Saudi Arabia should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment, Saudi Arabia should – Report on the supervisory measures taken in respect of suspended companies, along with the outcomes of the supervisory measures, and relevant statistics. Report on the supervisory measures taken in respect of already identified inactive entities (prior to the enactment of the 2025 Law on Commercial Register) and their outcomes, along with relevant statistics.

Element C.5: Effective exchange of information

6. Communication and provision of status updates

 

Recommendation (C.5, practice)	Saudi Arabia should effectively communicate with its peers, both by ensuring that it can be easily contacted and by clearly communicating the status of requests received, including by providing status updates to its EOI partners within 90 days where relevant.
Underlying factor	Over the review period, Saudi Arabia did not effectively communicate a change in its Competent Authority contact details to all its EOI partners. Several requests were only received after follow-up, resulting in significant delays. Moreover, Saudi Arabia has not provided any status updates during the review period nor clearly communicated the status of the requests in terms of whether further information can be expected to follow and whether or not the requests are considered to be closed due to, for example, insufficient identifying information. (see paragraphs 285 et seq. of Saudi Arabia’s 2019 Report for more information)
Summary of actions reported	Competent Authority contact details have been updated on the Global Forum Competent Authority database. Since 2019 (after the 2019 Report), Saudi Arabia has enhanced its internal procedures to include weekly monitoring of incoming requests, internal key performance indicators to guide turnaround time on requests, dedicated points of contact for foreign partners, improved access to commercial register data and processes to ensure proper and timely actions are taken on received requests, including providing status updates to EOI partners in all cases where a final response could not be provided within 90 days. Encrypted emails are used for communication with partners to ensure timely processing of incoming EOI requests.
Conclusion	Saudi Arabia appears to have taken appropriate actions to address the recommendation, which reflect in the improved timeliness of exchanges and communication with partners in the form of status updates.
Status determined	Considered provisionally addressed in the context of the monitoring process, subject to detailed validation
Actions required	No immediate action required. Nevertheless, Saudi Arabia should provide updated timeliness statistics for the corresponding monitoring period, according to paragraph 29 of the Methodology for Enhanced Monitoring.

7. Organisational processes for timely exchange of information

 

Recommendation (C.5, practice)	Saudi Arabia should ensure that it has appropriate organisational processes in place to process and answer EOI requests in a timely manner.
Underlying factor	During the review period, several changes in the organisation of Saudi Arabia’s Competent Authority resulted in internal communication issues and EOI requests not being processed in a timely manner. (see paragraphs 292 et seq. of Saudi Arabia’s 2019 Report for more information)
Summary of actions reported	Appropriate organisational processes are in place to process and answer EOI requests in a timely manner (see Recommendation 6). In addition, supervisory and monitoring mechanisms are in place to ensure requests are properly and timely processed. These include a clear reporting structure and weekly performance tracking. Monitoring is supported by a centralized request log and regular reviews. Staff receive ongoing training, and standardized templates have been adopted to ensure consistency and efficiency.
Conclusion	Saudi Arabia appears to have taken appropriate actions to address the recommendation which reflect in the improved timeliness of exchanges.
Status determined	Considered provisionally addressed in the context of the monitoring process, subject to detailed validation
Actions required	No immediate action required. Nevertheless, Saudi Arabia should provide updated timeliness statistics for the corresponding monitoring period, according to paragraph 29 of the Methodology for Enhanced Monitoring.

EOIR experience

Over the monitoring period, Saudi Arabia received 31 requests and sent 1 request. Tunisia, the United Kingdom and Egypt were the top three partners for incoming requests. Saudi Arabia reported providing full and final responses in 97% of all the received requests. The remaining request (corresponding to 3%) was withdrawn by the requesting partner within 30 days of receipt.

Four members provided peer input on Saudi Arabia, only one had (minimal) EOI exchanges with Saudi Arabia. This peer has agreed on special operating procedures for communication with Saudi Arabia and was satisfied with the response provided.

New developments having a bearing on the EOIR standard

No recent developments that could have a bearing on the EOIR standard (other than those reported to address recommendations) have been reported by Saudi Arabia or have otherwise come to light.

Next steps

Saudi Arabia should continue taking actions towards implementing the standard effectively.

The following next steps are expected from Saudi Arabia:

• Submit its next self-assessment in 2028 under the second round of enhanced monitoring.

• See also Chapter 1 (Scope and methodology), section on “PRMG decisions – Statuses determined and actions required”,, which explains the next steps expected on recommendations that are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”.

Views/response of the monitored jurisdiction

Saudi Arabia acknowledges with appreciation the efforts of the Global Forum Secretariat and the Peer Review and Monitoring Group in preparing the review report. We view this as an opportunity to further enhance and improve transparency and quality of exchanges.

In alignment with the Kingdom’s Vision 2030 objectives and longstanding commitment to international compliance, Saudi Arabia has already initiated comprehensive steps to raise quality of the ongoing mechanisms of exchange of information on request, to prioritize actions that deliver measurable progress.

We express our appreciation to the review and monitoring teams for their diligence and reaffirm Saudi Arabia commitment to fostering transparency regarding exchange of information based on request.

Note

← 1.  OECD (2019), Global Forum on Transparency and Exchange of Information for Tax Purposes: Saudi Arabia 2019 (Second Round): Peer Review Report on the Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD Publishing, Paris, https://doi.org/10.1787/186f45ba-en.