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Recent communications from the UAE movable collateral registry system have reminded users of a mandatory obligation to review and update all "Prior Notices" registered in 2018 that have not been amended to date.
While the request may appear administrative in nature, it has material legal and priority implications for lenders, security agents and secured parties.
This note briefly explains what this requirement means and why action is necessary.
Why older filings matter
Under Federal Decree-Law No. 4 of 2020 on Securing Interests in Movable Property, priority among competing security interests is determined by the date and time of registration on the movable collateral register. Accordingly, the integrity and accuracy of registry records are critical, as they directly affect enforcement rights.
Many early filings were never subsequently updated. This creates several risks. For example, outdated notices may incorrectly suggest that a creditor holds a prior-ranking security interest when it no longer does. Similarly, stale registrations can prevent new lenders from obtaining clean priority. In general, maintaining incorrect public registry information may raise compliance concerns.
Recommended Action
We recommend that banks, security agents and secured parties run a registry extract of all historical filings, identify unamended Prior Notices from 2018, map each to the underlying facility, and promptly amend or cancel where necessary.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
