The Market That Changed the Rules
Picture the scene. It is early 2023 and a developer launches a new off-plan project in Business Bay. Within 48 hours, the project WhatsApp group has 200 members. A hundred of them claim to have buyer leads. Forty are posting the same units on the same portals at different prices. Twenty have never met the developer’s sales team. And almost none of them have a signed authorisation to advertise. The buyer who calls the cheapest listing has no idea which agent, if any, will actually close the deal, or what commission that agent agreed with whom.
The DLD recorded more than 180,000 property transactions in 2024 as the off-plan boom drove a surge in broker registrations. That volume, and the chaos that came with it, forced the regulator’s hand. What followed was not a single dramatic overhaul. It was a sequence of tighter rules, reinforced compliance requirements, and clearer documentation standards — rolled out across Trakheesi, the RERA broker licensing regime, the forms framework, and advertising oversight. Taken together, they represent the most concentrated period of brokerage regulation tightening Dubai has seen in years.
This piece walks through what actually changed, why it matters to agents working live deals, and where it all points for anyone who wants to avoid disputes and get paid cleanly.
The Licensing Floor Got Raised
The most fundamental change is to what it takes to hold and keep a broker card. The baseline requirement — complete DREI training, pass the RERA exam, register in the Trakheesi system — has not changed in its structure. What changed is the seriousness with which renewal is enforced and the clarity of the consequences for letting a licence lapse.
RERA announced a mandatory prerequisite for brokers: every broker must pass the test of the Dubai Real Estate Institution (DREI) — the educational arm of the department — in order to renew their Real Estate Brokerage Licence. This is not optional additional development. It is the gate. No test result, no renewal.
The real estate broker licence is valid for one year and must be renewed annually. Renewal requires Continuing Professional Development (CPD) training and payment of renewal fees.
RERA’s official letter also included a notice pertaining to the cancellation of expired brokers’ licences. Any licence that has expired for six or more months will be cancelled ten days from the date of the circular’s issuance. That is a hard clock. An agent who lets a licence quietly expire does not just face a fine — they have to restart the entire registration process from the beginning.
Unlicensed brokerage carries heavy fines, and repeat offenders can face criminal charges.
Why does this matter to a working agent? Because in a shared deal, the other party’s licence status is now more relevant than ever. If the agent on the other side of a co-broke arrangement has an expired card, their commission claim has no regulatory standing. Their agency cannot invoice. The deal stalls. And if a dispute lands in front of RERA, the unlicensed party has no protection. Every agent needs to verify BRN status before signing a Form I — not as a formality, but as basic deal hygiene.
One additional change worth noting: the AED 5,000 bank guarantee once required for brokerages was abolished in 2024, lowering the entry cost for new brokerage firms. That sounds like good news. In practice, it accelerated the influx of new firms into the market — which is precisely why enforcement on advertising and conduct tightened in parallel.
Advertising Got a Much Harder Edge
For years, the requirement to hold a Trakheesi permit before publishing a listing existed on paper. Enforcement was uneven. The post-2023 period changed that.
In Dubai, every property advertisement — on portals, Instagram, Facebook, YouTube, or WhatsApp — must carry a valid Trakheesi advertising permit number issued through the Dubai Land Department and supervised by RERA. Every channel. That WhatsApp message with the floorplan you sent to a buyer contact at 10pm? If it advertises a specific property, it needs a permit.
Trakheesi is the Dubai Land Department’s permit system for real estate advertising, supervised by RERA. Before any property ad is published, the advertiser applies through the system and receives a permit number — and that number must appear on the ad itself. One permit, one property, one authorised advertiser. That last part is what most agents miss. The permit is not a general licence to advertise; it is a per-listing authorisation that connects three things: the property being advertised, the broker or developer advertising it, and the owner’s written consent for that specific marketing.
In April 2024, the DLD made a structural change to how permits are classified in the off-plan space:
The DLD and RERA introduced several changes to the Trakheesi system during 2024 and 2025 that affect how developers and brokers obtain and manage advertising permits. The most significant update came in April 2024, when the DLD separated Primary Project and Primary Unit permits into distinct categories. Previously, developers and brokers holding a Primary Project permit could use it to advertise both the project and its individual units. Following the update, a separate Primary Unit permit is now required for each individual unit being advertised on any platform. This change applies to all off-plan listings and requires developers and their authorised brokers to maintain two separate active permits for comprehensive project marketing.
The practical consequence: an agent working an off-plan deal who has only a project-level authorisation cannot legally advertise the specific unit they are trying to sell. They need unit-level clearance. Agents who skip this step — because the developer verbally authorised them, or because the project-level permit used to be enough — are now exposed to violation notices.
The system that verifies all of this is not human-monitored at a reasonable scale. The DLD’s Real Estate Advertising Governance Platform has monitored more than 279,000 property ads and automatically modified 29 percent of them, per DLD’s April 2025 update. That is automated enforcement. The machine is reading listings and flagging them in real time. An expired permit or a price mismatch between the ad and the permit will trigger a modification or removal without a phone call from a compliance officer.
Advertising without a valid permit is a RERA violation with fines reported to start at AED 50,000. RERA has suspended licences, blacklisted companies, and taken legal action against repeat offenders.
The enforcement number makes the point: in 2024, penalties collected exceeded AED 12 million from non-compliant companies.
The message is clear. The regulator is not waiting for complaints. It is actively monitoring, and the system is now automated enough to catch volume violations at scale. Every listing needs a valid permit, attached to a valid Form A, before it goes live anywhere.
Form A and the Three-Broker Cap
According to RERA, a property owner can only complete three Form A documents at a time and deal with a maximum of three brokers — one form for each broker. This rule — sometimes called the three-broker rule — has existed for some time, but its relevance has sharpened as the market has become more crowded.
The discipline it imposes is not just about the seller’s relationship with agents. It directly affects how a listing is managed as a shared deal. When a seller signs a Form A with your agency, they are giving you the right to market that property. That right is not transferable to another agent without a further structure — specifically, the Form I.
RERA confirms that the agent has the right to market the property by reviewing the Form A. No listing can go live without Form A approval. And after the signing, the contract must be approved by the Trakheesi system of DLD, which will assign a permit number to the property advertisement.
This creates a chain of accountability that now has regulatory teeth. The Form A connects the owner to the listing agency. The Trakheesi permit connects the listing agency to a specific advertisement. If another agent wants to bring a buyer and share the commission, that second agent connects to the deal through a Form I — not through an informal phone call.
Form I: The Document That Protects Your Split
This is where the regulation connects most directly to the friction that working agents actually feel.
When two agents work together on one deal — one representing the buyer, the other the seller — Dubai requires them to use an Agent-to-Agent Agreement called Form I. This form ensures both agents get their fair share of the commission.
The Agent-to-Agent Contract, officially known as Form I, is a legally binding agreement used in Dubai to formalise the collaboration between two real estate agents. This form is mandatory whenever both sides of the transaction are represented by licensed agents.
When two brokers collaborate on a deal, the commission structure must be agreed upon in advance. Without a clear Agent-to-Agent agreement, many agents end up in costly disputes or losing their commission entirely.
The standard split in the market gives a useful reference point: in Dubai, there is no official law dictating the exact split for Agent-to-Agent commissions, but the commonly accepted standard for sale transactions is usually a 50/50 split of the total commission. That is the starting point. The actual split can be negotiated differently — but whatever it is, it must be in writing, in the Form I, before the deal moves to Form F.
Negotiated splits — in large or complex deals — can be agreed between brokerages before the deal closes. Agents are required under RERA rules to disclose their commission arrangement to all parties.
This disclosure requirement is new in its practical enforcement emphasis. The old culture of keeping the split confidential from the buyer and seller is not consistent with how RERA now expects deals to be documented. Brokerage laws in Dubai mandate that commission must be tied to a written agreement, often included in the MOU.
The DLD’s Real Estate Brokerage Practice Guide — issued in November 2024 — reinforces the documentation chain. Should the contracting parties reach an agreement through the Trakheesi system, the concerned department will hold a meeting to discuss any breach and try to reach an amicable settlement. In the event that an amicable solution is not reached, parties must resort to the judicial authorities to settle the dispute. The implication is that disputes are first handled through the Trakheesi-linked process — which means documented deals fare vastly better than undocumented ones.
The VAT Reality Every Agent Needs to Own
All commissions are subject to 5% Value Added Tax under UAE law. This has been the rule since VAT was introduced in the UAE, but it continues to generate disputes in co-broke deals.
The VAT applies to the agency’s invoice to the client. In a shared deal, each agency invoices their own client. Where it gets complicated is when the split between agencies is being calculated: does the 5% apply before the split or after? The answer is that VAT is applied on the commission each agency earns from its client — it is not an internal calculation between agents.
Real estate agent commission in Dubai is 2% of the property purchase price, regulated by RERA. On a AED 2 million apartment, the buyer pays AED 40,000 plus 5% VAT — totalling AED 42,000.
When two agents split a 2% commission on a AED 2 million deal, they are dividing AED 40,000 between their agencies. Each agency then invoices its respective client for its portion, with VAT on top. The problem that surfaces in disputes is when one agency collects the full commission and is supposed to pass the other agency’s share across. That inter-agency transfer is not a client transaction — it is a business-to-business settlement between two licensed firms, and it should be documented as such, ideally with the Form I specifying not just the percentage but the exact AED amount and the payment trigger.
Getting this wrong is not just an accounting problem. It creates a recoverable dispute only if the Form I was signed in advance. Without it, the unpaid agent has no documented claim.
Off-Plan Deals: The Escrow Buffer and What It Means for Commission Timing
Off-plan commission is one of the most frequent causes of payment delay — and the regulation around it is distinct from the resale market.
When a buyer purchases an off-plan unit, their payments go into the developer’s regulated escrow account, held under Dubai’s off-plan escrow law. Off-plan investments are protected with regulated escrow accounts and developer oversight. That account exists for the buyer’s protection — it ensures developer funds are applied to construction and not to operating expenses. It is not an agent commission holding mechanism.
Developer commissions to brokers are paid by the developer from their operating funds — not from the escrow account. This means the broker’s commission is dependent on the developer’s payment cycle and internal processes, not on the buyer’s payment. The gap between the client paying (booking fee, first instalment) and the broker being paid by the developer can be weeks. In some cases, if the developer’s internal payment process is slow or the deal falls through before a qualifying milestone, the commission may not flow at all.
This is a regulatory reality, not a flaw in the market. But it is the reason that agents working off-plan need to understand exactly what triggers commission payment from each developer — at booking, at SPA signing, at a percentage of the unit price paid? — before committing to a timeline with their agency or a co-broke agent.
RERA 2025 introduced mandatory milestone disclosures and real-time project updates. Developers must submit progress reports via the official digital portal and maintain an active compliance log. This increased transparency is helpful for tracking project progress, but it does not automatically accelerate commission payment. The developer’s payment obligation to brokers remains a contractual matter between the developer and the brokerage, governed by the developer’s broker agreement — which is separate from RERA’s buyer-focused oversight of the escrow account.
Ejari and the Rental Side: What Changed for Leasing Agents
Rental deals have their own documentation chain, and it has tightened. An Ejari registration is the mandatory registration of a tenancy contract with RERA. Without it, the tenancy has no legal standing in Dubai — meaning the tenant cannot make complaints to the Rental Disputes Centre and the landlord cannot enforce the contract through official channels.
All lease contracts must be registered with RERA. Contracts should detail the property description, lease purpose, duration, rent amount, payment method, and the landlord’s identity if not the owner.
The practical implication for agents: the commission is only fully secured when the Ejari is completed. A signed tenancy contract with post-dated cheques issued does not, by itself, put the agent in an unassailable position. If the Ejari is never registered — because the landlord delays, or the tenant moves in without completing the process — the agent’s commission claim rests on weaker ground.
In rental deals, the post-dated cheque structure also creates a specific friction point. Landlords commonly collect rent through a series of post-dated cheques covering the full lease term. The agent’s commission is typically paid separately, often in a single cheque. But if that commission cheque is not cleared at the time of lease signing — if it is post-dated, or if the agent’s invoice is submitted after the cheques are handed over — the opportunity to be paid at the same moment as the deal is done has been missed. That timing gap is where most rental commission disputes begin.
Dubai offers multiple avenues for resolving real estate disputes. The RDC handles tenancy-related issues, while RERA manages developer and brokerage disputes. The Rental Disputes Centre handles landlord-tenant disputes about the tenancy itself. Broker conduct sits with DLD/RERA — but if a commission issue has spilled into the tenancy, the RDC may become relevant too.
The Compliance Burden Is Now Real
What has changed across all of these areas is not that the rules are new — most of the underlying framework has existed for years. What has changed is enforcement density and automation.
In 2024 alone, RERA issued warnings to 23 real estate brokerage firms for violating advertising regulations. According to Gulf News reports, RERA conducts daily media monitoring to catch violations. Daily monitoring. Not quarterly sweeps.
RERA now mandates that all listings — online or offline — must be registered and verified through the regulatory database. Unauthorised or inflated listings face penalties, protecting buyers from misrepresentation.
The proliferation of informal brokerage networks and unlicensed intermediaries in Dubai’s off-plan market creates opacity for buyers and accountability gaps across the market. The regulatory response to that observation has been enforcement — more of it, more consistently, and increasingly via automated systems rather than human inspectors.
For a working agent, the practical compliance list is not complicated:
- Hold a valid, renewed RERA licence at all times.
- Ensure every listing carries a valid Trakheesi permit that matches the property type, price, and your agency’s authorisation.
- In off-plan deals, confirm you have unit-level permits, not just project-level ones.
- Get Form A signed before any listing goes live anywhere.
- Get Form I signed before any co-broke conversation becomes a serious deal.
- Register every tenancy with Ejari.
- Invoice with VAT correctly, from the right entity.
None of this is new in principle. What is new is that the cost of skipping any step has become measurable and consistently applied.
Where Disputes Actually Start — and What Eliminates Them
The regulatory changes described above have closed off several informal practices. But they have not, by themselves, solved the core problem that Dubai agents face in shared deals: the split is agreed verbally, the deal closes, the client pays — and then the argument starts about who gets what and when.
The Form I addresses this structurally. But even a signed Form I leaves one gap open: the question of timing. The form records the agreed split. It does not guarantee that the paying party releases both agents’ shares simultaneously. In practice, the listing agency collects from the client, and the co-broke agent waits for a transfer. That wait is where disputes are born.
The Dubai real estate market is structurally complex when it comes to commission management. Brokerages routinely handle developer co-broking agreements, RERA-regulated commission structures, performance-tiered split structures, project-specific bonus schemes, and multi-agent team deals — all simultaneously. Managing these variables manually creates chronic errors, agent disputes, delayed payments, and compliance risks under DLD and RERA regulations.
The solution that the regulations are pointing toward — whether they say it explicitly or not — is this: get the split agreed in writing before the Form F is signed. Get it confirmed by both agencies before the client’s manager’s cheque is issued. And structure the deal so that everyone is paid from the same trigger, at the same moment.
That is not a regulatory requirement. It is the logical conclusion of a regulatory environment that has made documentation the difference between a recoverable dispute and an unrecoverable one.
The Principle That the New Rules Are Pointing Toward
The tightening of Trakheesi enforcement, the harder line on licence renewals, the automated monitoring of listings, the mandatory Form I for co-broke deals, the Ejari requirements for rentals, the VAT compliance on invoices — none of these individually is a revolution. Together, they form a consistent direction of travel.
Dubai’s regulator is building a market where every party’s role, entitlement, and timing is documented before the money moves. The agents who are adapting to this — who treat the paper trail not as a burden but as protection — are the ones who avoid disputes and collect in full. The agents who are still closing deals on handshakes and sorting out the split by WhatsApp voice note after the NOC comes through are the ones who end up in front of RERA’s dispute process.
The principle is simple. Agree the split before the client pays. Sign it. Document every agent’s entitlement and the specific trigger that releases their payment. Then make sure all parties — both agencies — receive their portion at the same moment, from the same deal closing event.
That is not a new idea. It is what Form I was always designed to achieve. The changed regulatory environment has simply made the cost of ignoring it too high to justify.
