The moment you realise the permit matters to your cheque
Picture this: you have spent three weeks working a buyer. You find the unit, you negotiate, everyone agrees on AED 2.8 million, and the seller’s agent sends you a Form F to sign. The commission is on the document — four percent split two ways. Your name is in the right field. The deal goes to the trustee office. And then you wait. The other side stalls on the split payment. They say you were not the “official” agent on the listing. They suggest you were just “helping”. The conversation gets uncomfortable, and you realise you never signed anything up front to nail the numbers. You are now chasing a fee that should have been settled the moment the client signed.
That scenario plays out in Dubai more than it should. And in almost every version of it, the breakdown traces back to something that happened — or did not happen — at the listing stage. Specifically, it traces back to the Trakheesi permit, to what it records, what it authorises, and what it leaves unsaid when two agencies are in the deal.
This article explains the full chain: what the Trakheesi permit actually controls, how it connects to your commission entitlement, where the co-broke split fits into that chain, and what you need to have in writing before anyone hands over a cheque.
What Trakheesi actually is — and what it is not
Trakheesi is the Dubai Land Department’s system for issuing real estate advertising permits. Before a brokerage can publish a Dubai listing, it applies for a permit through the Trakheesi system on the Dubai Land Department’s website, and DLD issues a permit number tied to that specific property and advert.
The system works by linking each advertisement to a verified property, a licensed agent or authorised owner, and a valid brokerage. This creates a chain of accountability: if a listing turns out to be fraudulent or misleading, DLD can trace it back to the person who obtained the permit.
Notice what Trakheesi does and does not do. It verifies that a real, authorised property is being advertised by a real, licensed brokerage. It does not, on its own, record how the commission will be split if a second brokerage brings the buyer. That is a separate agreement. Agents who treat the Trakheesi permit as the whole story of their listing, and skip documenting the split, are leaving the fee arrangement exposed at the exact moment they should be locking it in.
Advertising without a valid permit, or with incorrect permit details, is a RERA violation. That is not news to most agents. What is underappreciated is that having a valid permit is the floor, not the ceiling. The permit proves you are allowed to market the property. It does not prove how much you are owed when a co-broking agency closes it.
The permit is tied to the brokerage, not the individual agent
This matters for how you think about compliance. The Dubai Land Department records the eligibility for the real estate advertisement permit as “Company”. The permit is therefore issued at company level, not to an individual, and an agent advertising a Dubai property is doing so under a licensed brokerage or is not doing so compliantly at all.
The practical effect: if you leave your brokerage or work under a new firm, all prior permits belong to the entity that issued them. Your personal track record as a producer does not transfer those permits. The listing rights sit with the company that holds them.
To lawfully earn commission on a Dubai transaction, an agent must hold an active RERA broker card and work under a brokerage that holds a valid Dubai trade licence. An unlicensed individual cannot legally broker a deal or collect a fee, and the listing itself must carry a valid Trakheesi permit number to be advertised at all.
Form A is the upstream document
If the Trakheesi permit is the output, Form A is the input. You cannot have one without the other.
Brokers applying for any category of Trakheesi permit must hold a valid Form A signed by the property owner. Form A is the DLD’s standardised Real Estate Marketing Agreement, introduced to regulate the relationship between property owners and real estate brokerage offices. Under Form A, the property owner authorises one or more brokers to market a specific property at an agreed price through specified advertising channels. The agreement defines the marketing period, the permitted advertising formats, and the rights and obligations of both parties.
It covers the property details, the agent’s commission, the listing duration, and — if applicable — the property’s mortgage status.
This is where the listing’s fee structure starts to exist in writing. The commission rate the owner agrees to pay the listing side is recorded in Form A. If a second agency brings the buyer, the total pool of commission available on the listing side is already defined. What is not defined — and what Form A was never designed to settle — is how that listing-side fee gets divided if another brokerage co-brokers in.
What happens when the owner signs non-exclusively
In Dubai it depends on the appointment: a seller can appoint a brokerage exclusively or more than one on a non-exclusive basis, subject to RERA rules.
Property owners may grant exclusive marketing rights to a single broker or authorise multiple brokers to market the property simultaneously. When they do the latter, each authorised brokerage pulls its own permit. In both cases, each agent must obtain their own Trakheesi permit for the same property.
Non-exclusive listings are the Dubai market’s default reality. Walk any major residential community and you will find the same unit listed at different prices across different portals by different agencies, sometimes with minor price variations that damage the seller’s negotiating position. Owners who sign Form A casually — or who allow agents to “test the market” without formal documentation — typically end up with the same property listed at different prices across multiple portals, sometimes by agents the owner has never spoken to. This damages the property’s perceived market position and creates commission disputes when offers eventually arrive.
For the agent on the listing side, non-exclusive exposure increases the chance that someone else’s buyer closes the deal — and that the commission conversation becomes complicated. The permit does not settle who gets paid in that scenario. Only a documented inter-agency agreement does.
The off-plan permit: a different document chain
Off-plan transactions follow a different path through Trakheesi, and the implications for commission are meaningfully different.
The supporting document depends on the property type: Resale (secondary market): typically a signed marketing agreement between the seller and the brokerage (commonly called Form A / Contract A). Off-plan: generally a no-objection certificate (NOC) from the developer.
A primary off-plan permit requires a developer NOC and one fee can cover multiple units in the same project, while a secondary resale permit requires Form A signed by the owner.
The consequence of that distinction: on a resale deal, your entitlement to a fee traces back to your Form A with the owner. On an off-plan deal, the authorisation traces back to the developer’s NOC. Commission is paid by the developer, not the buyer. When buying off-plan from a developer (whether through an agent or directly at the sales office), the commission is built into the developer’s cost structure and paid to the agent by the developer.
That sounds cleaner than a resale split. In practice, off-plan commission disputes arise when multiple brokers claim the same buyer — because the developer’s marketing permit authorises many brokers to market the same project, and “who registered the client first” becomes the contested question. The permit tells you who is allowed to advertise. It does not protect you from a race to register the same buyer at the developer’s sales office.
Every advert must display its Trakheesi permit number, and for off-plan it must also show the developer name, escrow account number and expected completion date, per the portal advertising rules.
That requirement about the escrow account number is not a technicality. Dubai law requires developers selling off-plan to channel buyer payments into regulated escrow accounts. The escrow account law applies to all real estate developers working in Dubai and those who sell units off-plan, and, in return, receive payments from purchasers or investors as well as from the financiers of the project. When your off-plan advertisement carries that escrow number, you are giving buyers a verifiable reference point for the project’s regulatory standing. It is also the first signal that the project is legitimate and registered — which should matter to every agent putting their RERA card’s reputation behind it.
The 2024 update: Primary Project versus Primary Unit
The Primary Unit permit was introduced by the DLD in April 2024 as a separate category specifically for advertising individual units within an off-plan project, such as a specific apartment, villa, or plot. Prior to this update, a developer or broker needed only the Primary Project permit to promote both the project and its individual units. Following the 2024 change, two separate permits are required: a Primary Project permit for project-level advertising, and a Primary Unit permit for each individual unit listing on any platform.
For agents managing off-plan inventory, this distinction has direct operational impact. Project-level social posts, billboard campaigns, and portal banner ads require the Project permit. The specific unit you’re listing on a portal requires its own Unit permit. Missing the Unit permit while showing the Project permit does not make you compliant. RERA’s inspection division monitors all channels.
The QR code and what it changed
It generates a QR code for a real estate advertisement; when a buyer scans it, the code links to verified property data held by the DLD, letting them instantly confirm that both the listing and its Trakheesi permit are genuine. The DLD requires the QR code to appear on real estate advertisements, which is why compliant Dubai listings now display it.
Since 24 April 2023, DLD’s Madmoun service has made a QR code mandatory on print and audiovisual property advertisements — scanning it verifies RERA approval and the property’s details.
This shift has a subtle but important effect on how disputes play out. A buyer who scans a listing’s QR code can verify the listing’s legitimacy in seconds. That means a buyer introduced to a property by an unlicensed referrer — or by an agent whose permit has lapsed — leaves a verifiable digital trail. If that agent later claims commission, the date and details of their permit can be checked against when the buyer was introduced. Gaps in permit coverage can be exposed. Having a continuous, uninterrupted permit record for your listing is not just a compliance issue. It is a paper trail that supports or undermines your commission claim.
The compliance consequence of getting it wrong
Agents found listing properties without a valid permit face disciplinary action from RERA, including fines and — in repeat or serious cases — the suspension or cancellation of their RERA registration. A suspended agent cannot legally operate in Dubai’s real estate market.
RERA conducts regular inspection campaigns to audit advertising permits and enforce compliance with the rules and circulars applicable in the emirate. The DLD has publicly confirmed that violations are subject to progressive fines starting at AED 50,000, with the penalty escalating for repeat or multiple offences. In serious cases, RERA may proceed to cancel the violating company’s real estate licence entirely.
These are not edge cases from years ago. In the first half of 2024, DLD fined 256 brokers for advertising non-compliance after 450 field inspection tours and 1,530 advertisement inspections.
The permit system is actively enforced. And portals are part of that enforcement architecture. Property portals operating in Dubai are required to authenticate advertisements through their integration with the DLD system. They must also remove any listing flagged by RERA for non-compliance. The advertiser bears full legal responsibility for any violation.
Your listing gets pulled. Your brokerage gets fined. The client loses confidence. And if the deal was close to signing, a pulled listing can complicate everything — including your ability to prove you were the agent of record when the buyer made their decision.
Where the split lives — and why it so often goes unrecorded
Here is the thing: the Trakheesi permit, Form A, Form F — none of them, individually, record the commission split between two co-broking agencies. They record each party’s relationship with their client. The inter-agency split is governed by Form I.
RERA Form I comes into play when two RERA certified agents, one representing the seller and the other the buyer, decide to collaborate. This formal agreement is designed to safeguard the clients and listings of both agents. Additionally, it explicitly outlines the commission split between them, solidifying a professional partnership and commitment between the collaborating agents.
Form I clearly defines how the total commission will be divided between the listing agent and the buyer’s agent. It ensures both agents adhere to RERA’s code of ethics while collaborating. It specifies which agent is responsible for particular tasks, such as coordinating with the developer or attending the final transfer at the Trustee office.
By having a signed Form I, both agents are legally bound to cooperate in the best interest of their clients, preventing potential “poaching” of clients or disputes over fees.
That is the mechanism. What happens in practice? In a market without exclusive mandates as the default, where the same property can appear under four brokerages’ permits simultaneously, a buyer’s agent often brings a client to a listing without ever formalising the split. The buyer’s agent assumes the fee is fifty-fifty. The listing agent assumes nothing is owed because the buyer’s agent “just called”. The deal proceeds. Form F gets signed. Commission hits one brokerage’s account. And then the conversation about who gets what begins — after the money has already been collected.
That is the worst possible moment to start that negotiation. One side has the cash. The other has a phone record and a memory. Without Form I on file, there is no binding split agreement. The dispute that follows is expensive, slow, and damages both agencies’ professional standing.
What Form F records about commission
Form F is the most important of all RERA forms. It replaced the old handwritten MOU, standardising all sale agreements. It is now issued digitally through the Dubai REST App or Trakheesi, ensuring that every deal is registered within the DLD system.
The Dubai Land Department Form F will cover property and financial details and the commission to be paid to the seller’s and buyer’s agents. However, it is important to note that Form F by RERA is only a valid contract after it has been signed by the seller and the buyer. It must also be witnessed and dated by the agent.
Form F records each side’s commission. It does not, in itself, resolve how the listing-side commission is split internally between two agencies when both have a claim. What it does do is create the formal record of what is owed and by whom — and it is signed under the DLD’s system, so it is part of the regulatory paper trail. If your commission figure is wrong on Form F, disputing it after the fact is significantly harder than correcting it before the client signs.
This commission is typically due upon signing the Memorandum of Understanding (MOU), also known as Form F, though some agents collect at the point of title transfer.
The timing matters. If commission is due at Form F and the split has not been agreed before that document is signed, you are already behind.
VAT sits on top of your fee — and on the co-broke portion too
Dubai real estate agency fees attract VAT at five percent. This is not a theoretical consideration — it is a real cost that appears on every invoice a brokerage issues for commission. Both sides of a co-broke deal need to account for it. The listing side collects the total commission (inclusive of VAT) from the client. When it distributes the co-broking portion to the buying agency, VAT applies on that inter-agency payment as well if the paying brokerage is VAT-registered.
Where this creates friction: if the split was agreed informally as a round number — say, two percent to each side — but neither party discussed VAT on the B2B transfer, one side ends up bearing more of the effective cost than intended. Agreeing the split in net terms versus gross terms before anyone signs anything is a practical matter, not a pedantic one.
Ejari and rental deals: the permit chain is shorter, but the disputes are the same
For leasing, the Trakheesi permit for the listing is still required. For leasing: the broker should hold the owner authorisation or leasing brokerage agreement required under the current DLD and RERA process.
Once a tenancy is agreed, when a business user logs in to the DLD portal, the single sign-in grants access to Trakheesi alongside other DLD services including Ejari, Oqood, the Rental Disputes Centre (RDC), Registration Trustee services, and Mollak. Ejari registration of the tenancy contract is mandatory and happens within this same ecosystem.
In rental deals, the commission is typically paid at contract signing — or in line with the first post-dated cheque the tenant hands over. In a co-broke rental, both agencies must agree before signing who collects what, from whom, and when. A common point of dispute: the listing agency collects the full commission from the landlord’s side, tells the buyer’s agency they will be paid after the landlord pays — and the landlord delays, or disputes the amount, or pays in stages. The buying agent, who has already handed the tenant their key, is now waiting for a payment that depends on a chain of events they cannot control and were never party to.
This is the same structural problem as in sales. The split is undocumented. The money passes through one party before reaching the other. The recipient has leverage the earner does not.
The sequence that prevents every version of this problem
Walk through what a clean deal looks like, step by step, when two agencies are involved.
Before the listing goes live:
- Listing agency holds a signed Form A from the owner, with a clearly agreed commission rate.
- Listing agency obtains its Trakheesi permit. The permit number goes on every advertisement.
- If the property is off-plan, the listing brokerage holds a valid developer NOC and — since April 2024 — the relevant Primary Unit permits for individual units being advertised on portals.
When a co-broking agency introduces a buyer:
- Both agencies sign Form I before the viewing becomes a negotiation. The split is agreed in writing at this point: percentage, which side pays whom, and timeline.
- The split agreement sits between the two agencies. It is independent of what the client pays or when they pay it.
At Form F (MOU) stage:
- Each agency’s commission is stated correctly on Form F. Both agents witness and date the document.
- Commission is due at this stage in the standard Dubai market practice.
- VAT on the inter-agency payment is discussed and agreed, not assumed.
At payment:
- The ideal outcome is that both agencies receive their respective fees simultaneously, from the transaction itself, rather than one agency distributing to the other after collecting.
That last point deserves emphasis. When one agency collects everything and then distributes to the other, there is a window — sometimes days, sometimes weeks — where one party holds money that contractually belongs to another. Delays accumulate. Disputes start. The documentation from Form I, Form F, and the Trakheesi permit trail matter most in that window, because they are the only evidence of what was agreed and when.
Why a lapsed permit is not just a compliance problem
There is one more angle agents underestimate. A Trakheesi permit has a validity period tied to the listing. Validity is tied to the specific listing; renewed as needed when the listing period expires. If your permit lapses and the portal pulls the listing, but you continue to market the property through WhatsApp or social media without a live permit, you are in violation — and your marketing history for that property becomes contested. If a commission dispute later turns on when and how you were actively marketing the unit, a gap in your permit record is a gap in your case.
When a mandate lapses, the broker can no longer legally market the property, and active Trakheesi permits should be cancelled. Keeping permits current is not a back-office task to delegate indefinitely. It is a live record of your authorisation to earn on that listing. Let it lapse and you have, in a regulatory sense, stepped back from the listing — even if you never intended to.
The principle that makes all of this simpler
Dubai’s regulatory architecture is actually working in the agent’s favour. Form A, the Trakheesi permit, Form I, Form F — these documents exist to establish exactly who is authorised to do what, who is owed what, and when payment is due. The system has the tools to make every deal clean and every fee uncontested.
The problem is not that the tools do not exist. The problem is the sequence: agents agree things verbally, close the deal, and then try to formalise the split when one side already has the money. At that point, the regulatory paper trail either supports your claim or it does not.
The principle is simple: agree the split in writing before the client pays. Have every document — Form I for the inter-agency arrangement, Form F for the client-facing numbers, and the Trakheesi permit for the listing’s legitimacy — in place before the deal reaches the point where money changes hands. When the payment comes in, both parties collect simultaneously, at agreed amounts, against a signed record.
That is not an optimistic description of how things should work. It is a description of how the system was designed to work. Every element is already there. The only question is whether you use it before you need it, or reach for it too late.
