How off-plan project registration and escrow work in Dubai

In Dubai a developer can't sell one off-plan unit until the project is registered with the Dubai Land Department and has its own escrow account with an accredited bank. Registration needs a 30% guarantee. The developer can build 30% of the project first, post a bank guarantee for 30% of construction, or deposit cash equal to 30%. Once sales start, buyers' money goes into the escrow account and can only be spent on that project.

The rules below are as they stood on 6 October 2026. At the end we look at what this year's register says about how developers are getting through.

What do you need before you can sell off-plan in Dubai?

Two laws do the heavy lifting. Law No. 8 of 2007 covers escrow accounts and the register of developers. Law No. 13 of 2008 set up the interim real estate register, where off-plan sales to buyers are recorded, the step most people know as Oqood. The working detail, including the 30% condition and the fees, comes from DLD and its regulator RERA and sits on DLD's service pages.

Table: what DLD's Register Project service asks for, as listed on 30 September 2026. Source: Dubai Land Department; Law No. 8 of 2007.

The escrow application has its own list in Law 8 of 2007 (Art. 6). It includes a statement of the project's estimated costs and revenues certified by an accredited auditor, and the standard sale contract the developer will use with buyers. Advertising off-plan units, at home or at overseas exhibitions, needs DLD's written permission (Art. 5).

The 30% condition: three routes

Table: the three ways to meet DLD's 30% registration condition. Source: DLD Register Project page, updated 30 September 2026.

People get three things wrong here.

The threshold is 30%, with three routes. Plenty of guidance online still describes a 20% threshold with four routes. That was right until about late 2018. DLD's current page says 30% and lists three.

The 30% is administrative. Neither Law 8 of 2007 nor Law 13 of 2008 contains a 20% or 30% figure. DLD and RERA set it, so it can change without a new law. Get the current figure confirmed in writing before it goes into a feasibility model.

The cash route may use a different base. On the same DLD page, the Arabic text of the cash-deposit option refers to 30% of the project value, while the other two routes refer to construction. The Arabic text prevails, so a developer using the cash route should get RERA to confirm in writing what the 30% is a percentage of.

What does registration cost?

Table: fees on DLD's Register Project page, as of 30 September 2026. Source: Dubai Land Department.

The 4% belongs to the development agreement and nothing else. Other land interests are charged at different rates, so don't apply it more widely. The fees are small next to the guarantee. What the gate really costs is the capital or credit the 30% ties up, and for how long.

How does the escrow account work once sales start?

Each off-plan project has its own escrow account, opened in the project's name with an escrow agent accredited by DLD (Law 8/2007, Arts. 7, 9 and 10). A developer with five projects runs five accounts.

Buyers' payments go in. So does any loan raised against the project: if a developer mortgages a project to borrow, the lender pays the money into the escrow account (Art. 13).

The money can only be spent on building that project, and the developer's creditors cannot attach it (Art. 9). DLD's guidance says payments go to the project's contractors, consultants and marketing, with marketing capped at 5% of total sales.

RERA keeps track of progress. It reviews registered projects periodically and asks developers to update completion rates and expected completion dates through technical reports. A report expires three months after it is filed, and DLD charges a fee to renew it.

When the developer receives the completion certificate, the escrow agent keeps back 5% of the account. That 5% is released one year after the units are registered in buyers' names (Art. 14).

If a project stalls, the escrow agent must consult DLD and then act to protect buyers, either by seeing the project finished or by refunding their payments (Art. 15).

RERA also has rules on how far construction must progress before sales receipts can be drawn, and it can exempt projects close to completion. These are administrative and change from time to time. Treat any specific threshold you are quoted as something to confirm in writing.

Two sanctions in the law matter for planning. A developer that fails to start building within six months of getting permission to sell off-plan, without an acceptable reason, can be struck off the register (Art. 17). And the offences in Art. 16, which include knowingly selling units in a fraudulent project and taking project money, carry a fine of at least AED 100,000, a jail sentence, or both.

What does the 2026 register show?

Between January and September 2026, DLD's project register recorded 250 newly registered projects with 78,376 homes and AED 51.3bn of declared project value.

Table: projects added to the DLD project register by month, January–September 2026. Homes = apartments plus villas. Declared value is the project value filed at registration. Source: DLD project register, Peak Trust Research.

Registrations dropped to 10 projects in May, and have run at 21–27 a month since June. We don't set these counts against earlier years, because the register's coverage of older registration dates hasn't been shown to be complete.

The register also hints at which route developers take. In early October, 160 of the 250 projects registered this year still showed 0% construction, 75 showed 1–29% and 15 showed 30% or more. A project at 0% today can't have qualified by building, so on the register's own figures most 2026 registrations met the 30% with a bank guarantee or a cash deposit.

Table: construction progress recorded for projects registered January–September 2026, as of the register update of 4 October 2026. Source: DLD project register, Peak Trust Research.

The completion dates filed for these projects sit a median 2.6 years after registration. Our guide to Dubai's handover pipeline adds up what that means for supply.

What it means for developers

• Pick the route before you fix the launch date. Building to 30% delays the first sale but saves the guarantee cost. A guarantee or deposit gets you to market sooner and ties up credit or cash instead. Whichever you choose sets the scheme's capital profile, and that shapes what the payment plan can offer.
• Plan cash flow around the escrow account. Sales receipts pay for this project only, and marketing above 5% of sales has to be funded from elsewhere.
• Budget for the 5% retention. It sits in escrow for a year after units are registered to buyers, so don't count it as profit before then.
• Get the administrative numbers in writing: the 30%, its base on the cash route, and any drawdown threshold. DLD and RERA set them, not the law.
• Start on time. The six-month start rule in Law 8 of 2007 is a real risk for a scheme that registers early and then waits for the market.

For investors

Escrow is the main protection an off-plan buyer has in Dubai. Before paying, check that the project is on DLD's register with its escrow account, that your money goes into that account rather than to the developer or an agent, and that your purchase is recorded in the interim register. Registration means the project cleared the gate. It doesn't mean it will finish on the date filed, or that its launch price is in line with what the area has recorded. Our market dashboard shows registered prices by area.

Peak Trust advises developers on registration route, escrow and launch structure. See our work with developers.

Related: Launch Watch: every project DLD registered in 2026 · Studios up, two-beds down: Dubai's off-plan unit mix