Real Estate Broker Compliance in Dubai

Real estate broker compliance in Dubai starts before a property listing goes live. Brokers need the right approvals, clear client agreements and accurate advertising. They also need procedures for commissions, payments, customer checks and transaction records.

This guide covers the main checks for property dealers who act as brokers and for businesses that arrange transactions for clients. Buying or selling your own investment is different from acting as an intermediary. Confirm which rules apply to your actual activities rather than relying on the label “property dealer”.

Identify Your Business Activity and Approvals

Dubai Land Department (DLD) and its Real Estate Regulatory Agency (RERA) oversee key aspects of Dubai’s property market and brokerage practice. The business licensing authority also has a role in approving commercial activities.

A brokerage needs the appropriate business licence, DLD registration and professional approvals for its brokers. DLD’s Real Estate Brokerage Practice Guide explains the broker-card process through Trakheesi.

Keep a record of licence and card expiry dates. Check that the approved activities cover the work your team performs. A brokerage approval should not be treated as permission for every property-related activity, such as managing property or undertaking development.

Understand Forms A B and F

DLD identifies Contracts A, B and F as its smart marketing and sale contracts. Each records a different relationship. Use the current official process and check every field before asking the parties to approve a contract.

Form A for the seller and brokerage

Form A records the seller’s appointment of the brokerage to market a property. Check the owner’s identity, any representative’s authority, property details, asking price, duration and commission terms.

Confirm the permitted marketing scope and any exclusivity arrangements. A signed appointment does not replace the advertising permit requirements.

Form B for the buyer and broker

Form B records the buyer’s relationship with the broker. DLD’s Contract B instructions include property requirements, contract duration, commission and buyer approval.

Make sure the buyer understands the agreed service and payment terms. Check that the contract matches the actual instruction before submitting it for approval.

Form F for the buyer and seller

Form F records the sale agreement between buyer and seller. Review the price, deposit arrangements, completion date, conditions and consequences of default. Check that any additional terms fit the transaction and do not conflict with the rest of the agreement.

Signing Form F does not itself complete the ownership transfer. The parties must also follow the applicable registration process. Our guide to resale deposits, Form F and transfer payments explains the payment issues in more detail.

Record Broker Cooperation and Commission Terms

When two brokerages work on a transaction, record their respective roles and commission-sharing terms. Market participants often refer to a broker-to-broker cooperation agreement as Form I. Check the document itself and the current requirements; its label alone does not establish that DLD issued or approved it.

Agree who represents each client, who will communicate instructions, how the commission split works and when payment becomes due. Also address what happens if the transaction does not complete.

Under Dubai’s brokerage rules, commission entitlement depends on the agreement and relevant legal conditions. Do not assume that an introduction or property viewing automatically creates a right to payment. Keep the signed appointment and evidence of the work completed.

Obtain Advertising Permits and Check Madmoun

Obtain the relevant real estate advertising permit through Trakheesi before publishing. For seller listings, check the link between the permit and the electronic marketing contract. DLD has issued a circular linking permits with Form A.

DLD’s Madmoun service provides a QR code for advertising permits. Follow the applicable requirements for displaying the permit number and QR code, including across the advertising channels you use.

Before an advert goes live, compare the property, price and availability with the authorised details. Test the QR code and check its destination. Update or remove a listing when its status changes. Do not reuse another property’s permit or assume an old permit covers a new campaign.

Check Off Plan Marketing and Payment Arrangements

Before marketing a developer’s off-plan project, confirm its registration, the brokerage’s marketing authority and the project’s escrow account. Direct buyers’ payments towards the developer’s off-plan sale into the designated project escrow account.

Do not substitute a broker’s personal or operating account for that account. Separately identify any legitimate brokerage fee and explain its basis and recipient. An off-plan resale may involve additional payment and transfer arrangements, so check the transaction structure rather than applying one payment instruction to every deal.

Our guide to escrow accounts in Dubai real estate explains the role and limits of project escrow protection.

Register Applicable Leases Through Ejari

Dubai’s tenancy legislation requires registration of leases that fall within its scope, including amendments. For an ordinary residential or commercial tenancy under that framework, arrange Ejari registration and keep the details current. Check separately where a property or arrangement follows a different legal regime.

If your business handles registration, confirm its authority to act and agree who will provide the documents and complete the process. Check the parties, property details, rent and term against the signed contract.

For commercial leases, also review permitted use, fit-out approvals, maintenance, reinstatement and early termination. Do not promise that a missing Ejari record automatically makes the lease void or removes all remedies. Resolve registration issues and check the applicable procedure. Our guide to filing a case at the Rental Dispute Center covers the dispute route.

Meet Anti Money Laundering Duties

Real estate brokers and agents fall within the UAE’s designated non-financial businesses and professions framework when handling client property purchases or sales. The current framework includes Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025.

Customer checks and internal controls

Apply risk-based customer due diligence, identify beneficial owners and check representatives’ authority. Maintain appropriate screening, transaction monitoring, records, staff training and compliance oversight. Register for the required reporting systems and follow the competent supervisor’s instructions.

Suspicious transactions and activity reports

Report suspicions through the required FIU process, including goAML. Do not alert a client to a suspicious-transaction report. A bank’s checks do not replace the brokerage’s own duties.

Separate Real Estate Activity Report requirements cover specified freehold sales and purchases. Ministry Circular 05/2022 includes physical cash payments totalling AED 55,000 or more, payments in virtual assets, and payments using funds converted from virtual assets.

These reporting triggers differ from suspicion reporting. A transaction below the cash threshold can still raise suspicion. Check current supervisory instructions and escalation procedures before proceeding.

Build Checks Into Each Transaction File

Use a consistent file structure so that another team member can understand the transaction without relying on verbal explanations. Include:

• Client identity and authority documents, with appropriate access controls.
• The signed brokerage appointment and any cooperation agreement.
• Property details, ownership or project checks and relevant approvals.
• Advertising permit details and copies of published listings.
• Sale or lease documents and written amendments.
• Deposit instructions, payment records and commission calculations.
• Client communications, approvals and completion evidence.

Keep restricted compliance material separately where appropriate. Set reminders for licence renewals, permit expiry and transaction deadlines. Assign someone to review exceptions before the team commits to a course of action.

If you use standard agreements, review them when your services or business arrangements change. Our contract drafting services can support the review of contractual responsibilities and payment terms.