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Dubai real estate laws 2026: the DLD and RERA rules every broker must know

16 October 2026 · 22 min read · Thalhath Shah, Real Estate CRM Consultant

Dubai real estate laws 2026 cover: a compliance checklist for brokers with the cold-calling ban, escrow, permits and AML rules

Quick answer: The Dubai real estate laws 2026 brokers must follow are RERA's broker rules (Regulation No. 85 of 2006 and its circulars), the escrow law for off-plan (Law No. 8 of 2007), the interim register law (Law No. 13 of 2008), and the federal AML law (Decree-Law No. 10 of 2025). The newest: a cold-calling ban (February 2026) and an off-plan marketing circular (January 2026).

Key takeaways

  • You need a RERA broker card, tied to your office's trade licence, before you deal with anyone. The card requires a Dubai Police good conduct certificate and a pass in the broker exam, unless you are exempt.
  • Every advert needs a permit with its QR code (fine AED 50,000), and a permit is linked to a signed Form A with the owner. Sold or let listings must come off the portals.
  • RERA Circular 02-2026 (26 February 2026) bans calling owners whose data you did not obtain lawfully. A complaint can mean an AED 50,000 fine or a three-month suspension, and repeat offences can end your registration.
  • RERA Circular 01-2026 (5 January 2026) bars brokers from marketing any off-plan project that is not registered with the DLD, has no approved escrow account, or has no RERA marketing permit.
  • Real estate agents are AML reporting entities: a cash payment of AED 55,000 or more, or any virtual-asset payment, on a sale must be reported to the FIU through goAML, and records kept for at least five years.

Last checked: 12 October 2026.

This guide collects the Dubai real estate laws 2026 brokers deal with every week, using only what the Dubai Land Department (DLD), its regulator RERA, the federal ministries and the published laws say. Each rule carries its date: several of the most quoted "new rules" are years old, and a few genuinely new ones have barely been covered.

Summary table of Dubai real estate laws for brokers in 2026: broker card, Form A and permits, cold-calling ban, off-plan escrow marketing, AML reporting, with their sources and penalties

What are the Dubai real estate laws 2026 brokers must follow?

RERA (the Real Estate Regulatory Agency, the DLD's regulatory arm) writes the day-to-day rules as circulars to brokerage offices, resting on Dubai laws, with federal law on top for money laundering and telemarketing. Here is the reference version:

RuleApplies toSourcePenalty stated in the source
Register and hold a broker card before practising; card valid only while the office licence isEvery brokerDLD practice card service; Regulation No. 85 of 2006Disciplinary penalties under Regulation 85 (notice, warning, suspension)
Brokerage contract in writing and registered (Form A seller, Form B buyer, Form F sale)Brokers and their clientsRegulation 85, Article 26; DLD standard contracts (2014)Commission claims can fail without proof of registration (Dubai Court of Appeal, December 2022, as reported by BSA)
Permit for every advert, linked to Form A since 1 August 2022Brokerages, developersRERA Circular 01-2022Permit refused without a valid Form A
QR code of the permit on every print and audio-visual adAll real estate companiesRERA Circular 02-2023 (from 15 April 2023)AED 50,000
Remove ads for property no longer availableBrokerages; portalsRERA circulars of 2 and 5 August 2022A fine (amount not stated); portals can be blocked
Up to three permits (three brokers) per property; sold listings come down at onceBrokeragesDLD, as reported by Gulf News/WAM (from 1 October 2022)Not stated in the report
Use only phone numbers registered in the brokers registryBrokersRERA Circular 01-2023 (11 April 2023)Violations "as prescribed"
No cold calls or unlawfully obtained owner dataBrokerage offices and brokersRERA Circular 02-2026 (26 February 2026)AED 50,000 or 3-month suspension; permanent removal for repeats
Market off-plan only if registered, with escrow and a RERA permitBrokersRERA Circular 01-2026 (5 January 2026); Law No. 8 of 2007Fines, suspension, removal from the brokers register
No payments outside the project escrow accountDevelopersLaw No. 8 of 2007; RERA Circular 02-2025Legal action (Circular 02-2025); misappropriating buyers' money carries jail and a fine of at least AED 100,000 (Article 16)
Off-plan sales entered in the Interim RegisterDevelopers, buyers, brokersLaw No. 13 of 2008, Article 3Unregistered disposition is void
CDD, goAML, REAR for cash of AED 55,000+ or virtual assets, five-year recordsReal estate agents and brokersMinistry of Economy (July 2022); Federal Decree-Law No. 10 of 2025Administrative fines under Cabinet Resolution No. 71 of 2024
Ordinary brokerage cannot market property abroadBrokerage officesRERA Circular 01-2021Legal action
Telemarketing rules (hours, registered numbers, Do Not Call Register)Every UAE business that markets by phoneCabinet Resolutions No. 56 and 57 of 2024Up to AED 150,000, suspension or licence cancellation
Permit needed to use a unit as shared housingOwners and licensed operatorsDubai Law No. 4 of 2026 (in force 26 August 2026)AED 500 to 500,000, doubled for repeats up to AED 1 million

What are the new RERA rules in 2025 and 2026?

These are the changes found in official documents or major press coverage of an official announcement, newest first:

  • 26 August 2026: shared housing law in force. Dubai Law No. 4 of 2026 took effect 180 days after it was published in the Official Gazette on 27 February (Gulf News, August 2026). Existing operators have one year to comply.
  • 26 February 2026: cold-calling ban. RERA Circular 02-2026, "Regulations Governing Communication with Property Owners and the Prohibition of Cold Callings", reference DLD/OUT/2026/0001641.
  • 5 January 2026: off-plan marketing by brokers. RERA Circular 01-2026 on compliance with Law No. 8 of 2007, addressed to brokerage offices.
  • 14 October 2025: new federal AML law. Federal Decree-Law No. 10 of 2025 replaced Decree-Law No. 20 of 2018 (Hadef Partners, October 2025). Its executive regulations are Cabinet Resolution No. 134 of 2025.
  • 19 March 2025: developers and escrow. RERA Circular 02-2025 told developers not to market before registration, escrow and a RERA permit, to put the permit's QR code on every ad, and not to collect money outside escrow.

Older rules you will still hear called "new": the registered phone numbers circular and the QR code circular (both April 2023), the Form A permit link (August 2022) and the three-permit limit (October 2022).

Who can work as a real estate broker in Dubai?

A broker card is the RERA-issued card that lets a named person practise brokerage for a licensed Dubai office. Nobody may practise until they hold it. The DLD lists these conditions as of October 2026:

  • a certificate of good conduct from Dubai Police;
  • a pass in the broker exam (fee AED 700 plus AED 20 in knowledge and innovation fees), unless exempt;
  • a card fee of AED 500;
  • validity tied to the office's trade licence, so the card lapses when the licence does.

The exam is waived for applicants over 55 and for brokers with five consecutive years in the same office. The full steps, the course and the first-year costs are in our guide to the RERA broker card. Law No. 8 of 2007 also makes dealing with an unregistered broker an offence for developers (Article 16, item 7), which is why developers check cards before paying commission.

Which contracts must a Dubai broker use: Form A, Form B and Form F?

The DLD introduced standard contracts for sales in 2014 (Al Tamimi, August 2014): Form A between seller and broker, Form B between buyer and broker, and Form F between seller and buyer, the sale agreement often called the MOU. Regulation No. 85 of 2006 requires the brokerage contract to be in writing, naming the parties and the property, and registered in the real estate register (Article 26).

Form A matters most day to day because it unlocks advertising. Since 1 August 2022, RERA's electronic Form A is linked to the permit system: the broker enters the Form A contract number instead of uploading a signed marketing agreement (RERA Circular 01-2022). No valid Form A, no permit, no listing.

Leasing has its own set: in August 2022 the DLD published unified owner and broker, broker and tenant, and property viewing agreements.

Watch out: a broker who cannot show a registered agreement may struggle to collect. BSA reported (August 2024) a Dubai Court of Appeal ruling from December 2022 rejecting a commission claim for lack of proof of DLD registration, although later rulings held that non-registration leads to administrative penalties rather than voiding the agreement. Register every agreement and keep the record.

When do you need an advertising permit in Dubai?

Always. A RERA advertising permit is the approval, issued through the DLD's Trakheesi system, that every property advert in Dubai must carry. The short version:

  • Every print and audio-visual ad must show the permit's QR code from 15 April 2023, and the fine for not doing so is AED 50,000 (RERA Circular 02-2023).
  • Portals may not publish an ad without a RERA permit, must verify it through their integration with RERA, and the ad must match the permit (RERA Circular 3-2022 to portals).
  • A project permit covers the project. In April 2024 RERA warned brokers that advertising individual off-plan units under a project-wide permit breaks the permit terms, with a fine of AED 50,000 and up to three months' suspension (Gulf News, April 2024).

Costs, the steps and which social media posts need a permit are covered in our Trakheesi permit guide.

How many brokers can list one property, and when must sold listings come down?

The three-broker limit comes from a DLD rule reported by Gulf News (with WAM) in September 2022: from 1 October 2022, only three permits are issued to promote or list each property, so up to three brokers can market it. The same report says all advertising for a property must be removed the moment it sells. We could not find the circular itself on the DLD's rules page, so treat the number as press-reported rather than published text.

The removal duty is in a published circular. On 5 August 2022 RERA told every brokerage office to contact the portals within 7 working days about ads, posted by the office or its brokers, for property no longer available for sale or rent, have them deleted, and copy RERA at Licensing@RERA.GOV.AE. It warned that a violation brings a fine. The terms RERA issued to portals the same week say an unavailable property must be delisted or clearly marked as sold.

What are the RERA rules for broker commission?

There is no fixed commission rate in Regulation No. 85 of 2006. The articles, as reproduced by Gulf News (October 2020), say:

ArticleWhat it says
27The fee is set by agreement; without one, by prevailing practice.
28No fee unless the brokerage resulted in a contract; the fee is due on signing the sale contract and registering it with the DLD, unless agreed otherwise.
29If the client revokes the brokerage contract, the broker can claim the agreed fee, unless the broker deceived them or made a grave mistake.
31Several brokers working together for one party share one fee.
32If a client hired several brokers separately, the one who closed takes the full fee.
33A broker is paid only by the party that authorised them; if both did, each owes their own share.

Market rates, who pays on rentals and how to split with a co-broker are in our guide to real estate commission in Dubai.

Off-plan rules for Dubai brokers: the three checks from RERA Circular 01-2026 and a worked example of what a developer may keep under Article 11 of Law No. 13 of 2008

What do Dubai's escrow rules mean for brokers selling off-plan?

An escrow account is the project bank account, opened with an approved escrow agent and registered with RERA, into which off-plan buyers' payments must go. Law No. 8 of 2007 sets it up for every developer selling off-plan in Dubai (Article 3, with deposits into escrow under Article 7). A developer needs written DLD authorisation before advertising in local or international media (Article 5), and the escrow agent holds back 5% of each escrow account after completion (Article 14).

Circular 01-2026 turned this into a direct duty for brokers. Before you promote any off-plan project, check three things:

  1. the project is legally registered with the DLD;
  2. it has an approved escrow account with RERA;
  3. a RERA marketing permit has been issued.

A broker who markets a project failing any of the three faces fines, suspension, removal from the brokers register or other legal measures. For developers, Article 16 of Law No. 8 of 2007 sets jail, a fine of at least AED 100,000, or both, for offences including unlicensed development, misappropriating buyers' money and dealing with an unregistered broker.

Rule of thumb: never take a cheque, transfer or "booking fee" for an off-plan unit into the brokerage's account. RERA's March 2025 circular prohibits collecting any payment for a project outside its escrow account.

What does Law No. 13 of 2008 (interim registration) mean for brokers?

The Interim Real Property Register is the DLD record of off-plan units before a title deed exists. Law No. 13 of 2008 is short but has four articles brokers meet constantly:

  • Article 3: any sale or other disposition of an off-plan unit is void unless entered in the Interim Register.
  • Article 4: a developer may not start a project or sell off-plan before taking possession of the land.
  • Article 9: a developer marketing through a broker must contract with a certified broker and register that contract with the DLD.
  • Article 10: neither a developer nor a broker may sign an off-plan sale for a project the authorities have not approved; such a contract is void.

Article 11, as amended by Law No. 19 of 2017, sets what happens when an off-plan buyer stops paying. The DLD first gives the buyer 30 days' written notice and certifies the developer's compliance and the completion percentage (Dubai Legal Portal explanatory note, 2018). Then:

Project completionWhat the developer may doRefund of any excess
Above 80%Keep the contract and claim the balance; ask the DLD to auction the unit; or terminate and keep up to 40% of the unit's valueWithin 1 year of termination or 60 days of resale, whichever is earlier
60% to 80%Terminate and keep up to 40% of the unit's valueSame
Below 60%, work startedTerminate and keep up to 25% of the unit's valueSame
Work not started, for reasons beyond the developer's controlTerminate and keep up to 30% of the amounts paidWithin 60 days of termination

Worked example: a buyer agrees to pay AED 1,500,000 for a 1BR in Business Bay, has paid AED 750,000, and stops paying when the tower is 70% complete. After the DLD notice runs out, the developer may terminate and keep up to 40% of the unit's value, AED 600,000. The buyer gets back at least AED 150,000, within a year or within 60 days of the unit being resold, whichever comes first. Explaining this before a client signs a payment plan is part of advising honestly; our off-plan guide goes through payment plans.

What are a real estate agent's AML obligations in the UAE?

Real estate agents and brokers are designated non-financial businesses and professions (DNFBPs), supervised for anti-money laundering by the Ministry of Economy under Federal Decree-Law No. 10 of 2025 (in force 14 October 2025), with fines set by Cabinet Resolution No. 71 of 2024. The Ministry's July 2022 notice sets out the core duties:

  • Know your customer. Record the Emirates ID or valid passport of individual buyers and sellers. For companies: the commercial licence, articles, register of beneficial owners, and IDs of all shareholders or partners.
  • File a REAR. A Real Estate Activity Report goes to the Financial Intelligence Unit through goAML when a sale involves cash of AED 55,000 or more (one payment or several), any payment in virtual assets, or virtual assets converted to cash to fund it.
  • Report suspicion. Suspicious transaction and activity reports (STRs and SARs) also go through goAML.
  • Keep records of transactions for at least five years.

Worked example: a buyer agrees AED 2,400,000 for a villa in Arabian Ranches. The 10% deposit is AED 240,000: AED 180,000 by bank transfer and AED 60,000 in cash. The cash part of the price is AED 55,000 or more, so the brokerage files a REAR on goAML and keeps the ID copies, receipts and agreement on file for five years. Two cash payments of AED 30,000 each would trigger it too, because the threshold covers single or multiple payments.

Can a Dubai broker market overseas properties?

Not as an ordinary brokerage. RERA Circular 01-2021 (23 June 2021) says a brokerage office's activity is limited to properties registered in Dubai and does not allow it to market properties outside the UAE. Marketing overseas property is reserved for offices with the "real estate representative office" activity that own the property they market, and only after a RERA permit. Even then they may not sign sale agreements or take any money: buyers must be told to inspect the property and complete the purchase under the law of the country concerned.

RERA's June 2018 conditions (Circular 2-2018) add a no-objection letter from the country concerned, at least 50% completion and an AED 10 million bank guarantee for unfinished projects, and the permit number on every ad (permit fee AED 1,020 at the time).

Is cold calling illegal in Dubai real estate?

Calling owners you have no relationship with is now banned outright by RERA. Circular 02-2026 says brokerage offices must not obtain owner or investor data from any source by unlawful means, and must not contact owners or investors directly by phone, text or any other channel to offer, market or buy property. The exception is clients with documented prior transactions with the office, provided the office keeps an approved record of that relationship and gives it to RERA on request.

If an owner complains, RERA can record a violation against both the office and the broker and impose a three-month suspension or an AED 50,000 fine. A repeat violation means permanent removal from the register. Add the 2023 rule that brokers may only use phone numbers registered in the brokers registry, and the federal telemarketing rules in force since 27 August 2024 (Cabinet Resolutions No. 56 and 57: calls only from 9am to 6pm, from numbers registered to the company, never to numbers on the Do Not Call Register, with fines up to AED 150,000 and possible licence cancellation), and the old "data list and dialler" model is finished. Our cold-calling rules guide covers the federal hours and the Do Not Call Register in detail.

The exception only protects you if you can prove the past transaction, so each client's history has to live somewhere RERA can be shown it, not in an agent's phone.

What does the shared housing law (Law No. 4 of 2026) mean for agents?

Shared housing is a residential unit occupied by several people who are not one family. Dubai Law No. 4 of 2026 now needs a permit before any unit is used that way. As reported by Gulf News in August 2026:

  • only owners and licensed establishments may rent out approved shared units, and occupants may not sublet;
  • fines run from AED 500 to AED 500,000 per violation, doubled for a repeat within a year up to AED 1 million, plus possible suspension for up to six months and permit revocation;
  • existing owners and operators have until August 2027 to comply.

The coverage does not mention brokers, but a leasing agent should not market a unit for sharing unless the owner or operator holds the permit, and should not help a tenant sublet.

How do you stay compliant with Dubai real estate laws in 2026?

Most RERA problems come from habits: a listing posted before the Form A is signed, an old ad left up, a new hire calling a bought list. A weekly routine catches most of it:

  1. Cards and licences: check every agent's card expiry against the office licence renewal date.
  2. Listings: no listing without a signed Form A and a permit number; QR code on every ad; delist within days of a sale or let.
  3. Off-plan: keep the DLD registration, escrow account and RERA permit on file for every project you market.
  4. Calls and messages: registered numbers only; no lists of owners' numbers; keep the record of every existing client relationship.
  5. AML: ID copies on every deal, REAR for cash of AED 55,000 or more, five years of records.
  6. Offboarding: remove the leaver's listings from the portals and hand their clients to someone else the same day.

Software helps with the parts that rely on memory. In Majlis CRM's listings, the DLD permit number is part of the listing and a listing cannot be published to Bayut or Dubizzle without one. Every lead keeps its calls, notes and WhatsApp history, an audit log records who changed what, and when an agent leaves, their leads and contacts move to the General Pool instead of leaving with them. None of that replaces RERA's own systems, but it gives you the proof the rules keep asking for. If you want to see it, book a demo.

Frequently asked questions

What is the new RERA rule on cold calling in 2026?

RERA Circular 02-2026, dated 26 February 2026, bars brokerage offices from obtaining owners' data unlawfully and from contacting owners or investors by phone, text or other channels to market or buy property. Clients with documented prior transactions with the office are exempt if the office keeps the record. Penalties are an AED 50,000 fine or a three-month suspension, and removal from the register for repeat violations.

Can more than three brokers advertise the same property in Dubai?

Not according to the DLD rule reported by Gulf News in September 2022, which limits each property to three advertising permits from 1 October 2022. Each permit needs its own Form A with the owner. We could not find the original circular online, so confirm with RERA if a dispute turns on it.

Is there a fixed commission rate in Dubai real estate law?

No. Regulation No. 85 of 2006 says the broker's fee is set by agreement, and by prevailing practice when there is none (Article 27). The fee is earned only when the brokerage results in a contract, and is due on signing and registering the sale with the DLD unless agreed otherwise (Article 28).

Do real estate agents in the UAE have to register on goAML?

Yes. Real estate agents and brokers are supervised by the Ministry of Economy for AML. They file Real Estate Activity Reports and suspicious transaction reports through the FIU's goAML platform. A REAR is required for cash of AED 55,000 or more on a sale, or any payment involving virtual assets.

Can a broker market an off-plan project before it has an escrow account?

No. RERA Circular 01-2026 requires the project to be registered with the DLD, to have an approved escrow account and to hold a RERA marketing permit before any broker promotes it. Breaches can lead to fines, suspension or removal from the brokers register.

Can I sell property in another country from my Dubai brokerage?

Not with an ordinary brokerage licence. RERA Circular 01-2021 limits brokerage offices to Dubai-registered property. Overseas property can only be marketed by an office holding the real estate representative office activity that owns the property, with a RERA permit, and it may not sign sale contracts or take money.

Which law makes an unregistered off-plan sale void?

Article 3 of Law No. 13 of 2008 says any sale or disposition of an off-plan unit is void unless entered in the Interim Real Property Register. Article 10 adds that an off-plan sale for a project the authorities have not approved is void, whether a developer or a broker signs it.

This is general information about Dubai and UAE rules as of October 2026, not legal advice. Check the current text with the DLD or RERA, or a UAE-qualified lawyer, before relying on it for a specific transaction.

Sources

  1. Circular 02-2026: Regulations Governing Communication with Property Owners and the Prohibition of Cold Callings, RERA / Dubai Land Department, 26 February 2026.
  2. Circular 01-2026: Compliance with the Provisions of Law No. (8) of 2007 Concerning Real Estate Development Escrow Accounts, RERA, 5 January 2026.
  3. Circular 02-2025: Compliance with Law No. 8 of 2007 regarding the marketing of real estate projects, RERA, 19 March 2025.
  4. Circular 01-2023: Mandatory use of registered phone numbers in the brokers registry, RERA, 11 April 2023.
  5. Circular 02-2023: Applying the QR code system for real estate ads, RERA, 11 April 2023.
  6. Circular 01-2022: Linking real estate permits with the e-marketing contract (Form A), RERA, 14 July 2022.
  7. Ads through online real estate portals, RERA, 5 August 2022.
  8. Circular 3-2022: Terms and conditions for real estate marketing on portals, RERA, 2 August 2022.
  9. Circular 01-2021: Marketing and promoting overseas properties, RERA, 23 June 2021.
  10. Circular 2-2018: Amending terms of the permit for marketing properties abroad, RERA, 20 June 2018.
  11. Rules and Regulations, Dubai Land Department, accessed October 2026.
  12. Issuance of a real estate professional practice card, Dubai Land Department, accessed October 2026.
  13. Law No. (8) of 2007 Concerning Escrow Accounts for Real Estate Development, Dubai Legal Portal.
  14. Law No. (13) of 2008 Regulating the Interim Real Property Register, Dubai Legal Portal.
  15. Explanatory Notes on Article (11) of Law No. (19) of 2017, Dubai Legal Portal, 2018.
  16. Ministry of Economy obligates real estate brokers and agents to maintain records for at least five years, UAE Ministry of Economy, 7 July 2022.
  17. A new era for AML/CTF/PF in the UAE: Federal Decree-Law No. 10 of 2025, Hadef and Partners, 14 October 2025.
  18. Dubai: Can real estate agents charge 10 per cent commission fee? (Regulation 85 of 2006, Articles 26 to 33), Gulf News, October 2020.
  19. Broker's commission and the registration of the agreement with Dubai Land Department, BSA Ahmad Bin Hezeem and Associates, 16 August 2024.
  20. Dubai Land Department introduces Mandatory Property Contracts, Al Tamimi and Company, August 2014.
  21. Dubai Land Dept further tightens marketing of properties: only up to 3 permits allowed per property, Gulf News (WAM), September 2022.
  22. Remove illegal ads or face fines up to Dh50,000, Dubai property brokers warned, Gulf News, April 2024.
  23. Dubai's shared housing law takes effect, fines of up to Dh1 million for repeat violations, Gulf News, 26 August 2026.
  24. New Telemarketing Rules and Regulations in the UAE, Legal 500 (Awatif Mohammad Shoqi Advocates), 17 September 2024.
  25. Cold call crackdown goes into effect as firms face AED 150k fines, Dubai Eye 103.8, 30 August 2024.

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