--- title: "What RERA disclosure rules mean for co-broked listings" description: "A plain-speaking breakdown of RERA's disclosure requirements for Dubai co-broke deals, covering Form I, split agreements, and how to get paid without a dispute." category: "dubai-market" readingTime: 12 --- ## The deal that nearly didn't pay out Picture it: a buyer's agent in JVC brings a qualified buyer to a listing held by another agency in Business Bay. Both agents shake hands on a 50/50 split, the viewing happens, the offer comes in, Form F gets signed, the client pays — and then the money stalls. The listing agency's accounts team says they need "authorisation." The buyer's agent has nothing in writing. Four weeks later, the buyer's agent is still chasing a cheque for work they demonstrably did. This is not an edge case. It is the most common way commission disputes begin in Dubai, and it has a specific cause: the co-broke arrangement was never documented before the client paid. Everything that follows — the delay, the dispute, the call to DLD — traces back to that gap. RERA's disclosure rules exist precisely to close that gap. Understanding what those rules actually require, what forms they attach to, and where they leave agents exposed is the difference between getting paid on completion day and waiting months for what you already earned. ## What RERA's framework actually says about co-brokerage RERA operates under the Dubai Land Department (DLD) and is entrusted with setting rules, policies, and procedures governing real estate transactions in the emirate. Its reach covers not just how properties are listed and sold, but how agents are licensed, how listings are advertised, and critically for co-broke situations, how commission arrangements between agencies are documented. Must display an active BRN on every listing and to every client on request; must use RERA-standard contracts; cannot advertise a property without a valid Trakheesi permit tied to that listing; must disclose representing both sides of a deal rather than concealing a dual role; and cannot collect commission without a signed agency agreement in place. That last point carries the most weight in a co-broke deal. The commission arrangement between two agencies is itself a form of agency agreement — and RERA requires it in writing. RERA does not fix commission rates by law. However, RERA plays a critical role in regulating how commission is handled: only RERA-licensed brokers and agents can legally earn commission in Dubai. That means the co-brokerage chain is only as strong as its weakest licensed link. If the agent bringing the buyer is not RERA-registered, the entire basis for claiming a split weakens considerably before you even get to the paperwork. Agents are required under RERA rules to disclose their commission arrangement to all parties. This is the disclosure rule that most agents think is optional. It is not. And in a co-broke situation, it creates obligations that run in two directions at once: between the two agencies working together, and toward the clients on both sides of the deal. ## The paper trail: Form A, Form B, Form F, and the one that agents forget Most agents working in Dubai know the core RERA forms. RERA introduced Form A (seller-agent agreement), Form B (buyer-agent agreement), and Form F (sale purchase agreement), all legally binding. These are the documents most agents think of when they think about compliance — and in a single-agent deal, they are enough. In a co-broke deal, they are not enough. There is a fourth form that governs the relationship between the two agencies, and it is the one most frequently skipped. ### Form I: the agent-to-agent agreement RERA created Form I, which is used when two RERA-certified agents agree to work together. A Form I ensures that both agents' listings and clients are protected and promotes agents working together, regardless of which real estate company they represent. RERA Form I is a contract between the seller's and buyer's agents, used to protect the rights of agents, clients, and listings. It ensures a professional relationship between agents and is required when two or more agents are involved in a joint property transaction. The form itself captures the essentials of the co-broke arrangement: Form I confirms which agent introduced the buyer and how commissions will be shared. It includes property details and permit number, contact details of both agencies, buyer acknowledgment of both brokers' roles, and the commission-split agreement. Without Form I, the split you agreed verbally over WhatsApp is not an enforceable position. It is a claim one party has to prove and the other party can deny. Without this agreement, agents risk losing their commission or facing legal complications. ### Form F and what it should already contain The Dubai Land Department Form F covers property and financial details and the commission to be paid to the seller's and buyer's agents. That means by the time Form F is signed, both commission amounts — listing side and buying side — should already be declared. If the split is not reflected in the documentation at Form F stage, the agent who has been promised a share has to go back to recover it after the fact. The sequence matters. Form I should exist before Form F is executed. If the buyer's agent is bringing a client to someone else's listing, the co-broke arrangement needs to be formalised at the point the collaboration begins — ideally before the first viewing, certainly before an offer is submitted. These forms need to be signed before an agent can legally claim commission on a deal. ### Trakheesi and who actually owns the listing Before co-broking even starts, there is a layer underneath that shapes the whole arrangement. A Trakheesi permit is the Dubai Land Department advertising approval that every property advertisement in Dubai legally needs before it goes live — a Dubai broker needs one for each listing they publish, on any channel. Issued through the DLD's Trakheesi system and regulated by RERA, the permit gives each advert a number that ties it to a real, verified listing. The Trakheesi permit belongs to the listing broker. It is tied to their Form A and their agency's license. When a buyer's agent introduces a client to that listing, they are working with a property that the listing broker has formal, registered authority to market. Each permit ties a specific listing to a verified RERA-licensed broker, a verified seller authorisation (Form A), and an active title deed. This matters for disclosure because both clients need to understand who is actually authorised to handle what. If a buyer's agent is sending clients to listings they have no Trakheesi permit for, they are dependent entirely on the listing broker's cooperation to get paid — and that cooperation needs to be locked in on paper via Form I. 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. Where there is no exclusive mandate — the most common situation in Dubai's secondary market — multiple brokers can legitimately market the same unit. In that environment, co-broking is not just common; it is the normal operating condition of a listing that is widely shared. ## The disclosure obligations that run to the client This is where many agents misread the rules. They treat disclosure as something that happens between agencies — the two brokers talk, they agree a split, they sign Form I, done. But RERA's disclosure framework runs to the client as well, and that has specific implications in a co-broke deal. ### What the client needs to know RERA requires all commissions to be clearly disclosed in writing in the representation agreement (Form A for sellers, Form B for buyers) before the transaction proceeds. For the buyer's agent, that means the commission they expect to earn needs to be disclosed in the Form B they have their client sign. For the listing agent, it is in Form A. Neither agent can add a co-broke share silently after the fact. Both buyers and sellers must be aware of the commission structure before signing a Sales and Purchase Agreement. That creates a clear sequence: the client agrees to the commission in Form A or Form B, the agencies agree their split in Form I, and then Form F is executed with those numbers already locked. ### The dual-agency scenario — and why it is different A co-broke deal involves two agents from two different agencies, each with their own client. A dual-agency deal involves one agent acting for both buyer and seller. These are legally distinct situations and the disclosure obligations are different. Dual agency is legal in Dubai but requires written disclosure. RERA mandates that agents inform both parties in writing before representing both sides. Failure to disclose is a licensable offense. Dual representation is not automatically barred, but an agent has to make both parties aware of the arrangement rather than quietly collecting commission from each side without either party knowing. In a genuine co-broke deal, each agent has their own client and there is no conflict-of-interest issue in the dual-agency sense. But the disclosure obligations still run to each client: each agent must tell their own client what commission they are earning, and both clients should understand — through Form F — what both agents are taking. Transparency is not optional at either end. ## Where payment stalls and disputes begin Understanding the rules is one thing. Understanding where the system breaks down in practice is more useful. ### The verbal split that nobody formalised The most common breakdown: two agents agree a split on the phone. Seventy-thirty, fifty-fifty, whatever the negotiation produces. No Form I is signed before the deal moves forward. The client pays the listing broker. The listing broker then has to release the buyer's agent's share — and at this point, the buyer's agent is at the complete discretion of an agency that may have internal reasons to delay, dispute, or renegotiate. Commission disputes are fact-specific — who introduced whom, what was signed, what was paid. Without Form I, the buyer's agent cannot point to a document that answers all three questions definitively. They can point to WhatsApp messages, call logs, and viewing records — but these are weaker than a signed form. ### The Trakheesi permit problem in shared listings When a listing is shared informally — one broker verbally telling another it is available, no formal co-broke agreement — the buyer's agent who introduces a client has no registered interest in that listing. The Trakheesi permit belongs to the listing broker's agency. If the deal closes and the listing broker decides not to pay, the buyer's agent has no Trakheesi paper trail proving their involvement. This is why the sequence matters so much. Before a buyer's agent shows a client a listing that belongs to another agency, there needs to be a Form I in place. Not after the offer comes in. Not after Form F is signed. Before. ### The off-plan wrinkle Off-plan co-brokerage operates through developer marketing agreements. The developer authorises a primary network of agencies, and secondary brokers either operate under a developer's NOC or bring clients to authorised agencies for a referral arrangement. For off-plan property, RERA demands escrow accounts, which hold buyer money until construction milestones are achieved. That regulated escrow structure means developer payments to agencies run through a defined channel — and referral payments to secondary brokers depend on what was agreed in writing before the developer disburses. In off-plan, the developer pays the listing broker. The listing broker pays the referring broker. If the referring broker's share was not documented in advance, they are at the back of a queue they were never formally added to. ### The VAT gap All commissions are subject to 5% Value Added Tax (VAT) under UAE law. In a co-broke deal where the split is, say, AED 100,000 total commission, VAT is charged on the gross amount collected from the client. Both agencies need to consider which agency is invoicing the client for VAT purposes and how the inter-agency payment is handled to avoid a situation where VAT is incorrectly applied twice or, worse, not remitted correctly. This is not a disclosure issue per se, but it is a payment-structure issue that needs to be sorted in the Form I stage, not after. ## What a clean co-broke arrangement actually looks like The mechanics of a properly structured co-broke deal are not complicated. They just require discipline at the start of the collaboration rather than firefighting at the end. ### The pre-collaboration steps Before any client introduction happens across agency lines, both agents should be working from a position where: - Both agents hold valid, current RERA broker cards - The listing broker has a signed Form A from the seller and a valid Trakheesi permit - The buyer's agent has a signed Form B from their buyer - Both agents have agreed and signed Form I, specifying the exact split, property details, and which agent introduced which client - Both clients understand — through their respective Form A and Form B — that commission is being paid, and approximately how much Commission agreements between agents — for instance, when a buyer's agent and a seller's agent split a fee on a co-broke deal — are governed by RERA Form I, which must be formally signed before any commission is disbursed. This prevents the informal arrangements that create disputes in less regulated markets and gives both parties a documented, enforceable position. ### During the deal Form F, when executed, should reflect the total commission that will be paid — listing side and buyer side — consistent with what both Form A and Form B already disclosed. Brokerage laws in Dubai mandate that commission must be tied to a written agreement, often included in the Memorandum of Understanding. Once conditions of the contract are met, the commission becomes payable. The MOU is not where the split first gets decided; it is where it gets confirmed. If the deal involves a resale, the NOC process and DLD transfer give both agencies a natural checkpoint. Commission should be collected at the same time the transfer completes — not after, not subject to some internal accounts queue. The moment the deal is done and money moves, commission should move with it. ### When disputes reach DLD and RERA If a co-broke arrangement breaks down after the deal, the remedy runs through the DLD and RERA's complaint mechanisms. The Dubai Land Department regulates registered brokers and handles complaints about broker conduct — this is the route for unregistered practice, double-dipping, misrepresentation, or fee disputes with a brokerage. Complaints can be raised through DLD's official channels. If a commission dispute arises, RERA's dispute resolution mechanism handles the case. Having a written agreement is essential to win any dispute. That last sentence is the whole argument for getting Form I signed before the deal moves forward. A dispute without paper is a dispute you lose on process before you even argue the facts. ## The practical checklist for any co-broke deal This is not exhaustive legal advice — it is the working checklist that keeps agents out of trouble: - **Verify both licences.** Before agreeing anything, check that both agencies are RERA-registered. An unlicensed party cannot legally earn commission, and dealing with one puts your own position at risk. - **Get Form I signed before the first introduction.** Not before Form F. Before the buyer sees the property. The form should name the property, specify the permit number, state the split percentage, and identify both agencies unambiguously. - **Make sure Form B is already in place.** The buyer's agent needs their Form B signed before they introduce the client to any third-party listing. Without it, they have no documented representation agreement. - **Confirm the Trakheesi permit is live.** Before sending a client to a listing, check the permit exists and has not expired. Every property advertisement — on portals or social media — must carry a valid Trakheesi advertising permit number issued through the Dubai Land Department and supervised by RERA. - **Get the split reflected in Form F.** Both commission amounts — listing side and buying side — should appear in the MOU. If the numbers in Form F do not match what was agreed in Form I, there will be a problem at payment time. - **Agree when and how each side gets paid.** The ideal outcome is that both agencies receive their share at the same time the deal closes. Any arrangement where one agency collects all of the commission and then remits to the other creates a payment dependency that turns into leverage if the relationship sours. ## The principle that changes how you work The reason co-broke disputes happen at scale in Dubai is not bad faith — most of the time, it is a failure to formalise what both agents genuinely agreed. The spoken arrangement felt solid. The deal was moving. Nobody wanted to slow things down with paperwork. And then payment time arrived and the agreement turned out to mean different things to different people. RERA's disclosure rules are not bureaucratic obstacles. They are the mechanism that converts a gentleman's agreement into an enforceable one. Form I exists because the DLD understood that agents would work across agency lines constantly, and that without a standard form to capture those arrangements, commission disputes would consume everyone's time and erode trust in the market. The principle to take from all of this is simple: in a co-broke deal, nothing should happen to the client before everything has been agreed between the agents — in writing, on the right form, with the split specified. Not a rough percentage to be finalised later. Not a "let's see how the deal goes." The exact number, on paper, signed by both agencies, before the client walks through the door. When that is in place, payment is not a negotiation that happens after the deal. It is an obligation that has already been documented and can be enforced. The deal closes, the money moves, and both agents get paid on the same day — because that outcome was agreed before the viewing, not debated after Form F. That is what clean co-brokerage looks like. It is not complicated. It just requires doing the paperwork first.