Real Estate

Owners of two-storey villas in Dubai who wish to rent each floor to a different family must consider both the emirate’s tenancy regulations and the rules governing shared accommodation before entering into separate lease agreements.

The landlord-tenant relationship in Dubai is primarily regulated by Law No. (33) of 2008, which amended Law No. (26) of 2007 Regulating the Relationship between Landlords and Tenants in the Emirate of Dubai. Under Article 4(1), the contractual relationship between a landlord and tenant must be governed by a written lease contract containing key details, including a clear description of the leased property, the purpose of the lease, the term, the rent and its payment method.

This means that where a villa owner intends to lease the ground floor to one family and the first floor to another, each tenancy arrangement should clearly identify the particular premises being leased and comply with the applicable registration requirements.

New Rules For Shared Accommodation

The position also needs to be considered in light of Dubai Law No. (4) of 2026 Concerning the Regulation of Occupancy and Management of Shared Accommodation in the Emirate of Dubai, which came into force on August 26, 2026.

The law establishes a regulatory framework for properties designated for shared accommodation and gives Dubai Municipality responsibility for regulating the activity. It applies to real estate units across Dubai, including properties located in private development areas and free zones, as well as owners authorised to designate their properties for shared housing.

The legislation defines shared accommodation as the joint residence of a group of individuals or families where space within a real estate unit is allocated to each of them for living purposes and facilities or services such as kitchens, dining rooms, bathrooms and outdoor areas are shared.

The law also establishes the concept of a real property unit designated for shared housing after meeting the conditions, controls and standards prescribed by the legislation and related decisions.

A digital platform, referred to as the digital window, is also provided for under the law. It is intended to receive, study and decide applications for permits and other requirements connected with the organisation and management of shared accommodation, as well as facilitate monitoring and inspections.

Separate Floors May Be Different

The distinction between separate tenancies and shared accommodation is important for villa owners. If a property owner leases the entire ground floor independently to Family A and the entire first floor independently to Family B, with each family occupying a self-contained residential area and neither family sharing facilities or services with the other, the arrangement may not necessarily fall within the statutory definition of shared accommodation under Article 2 of Dubai Law No. (4) of 2026.

In such circumstances, the arrangement may instead be treated as two separate residential tenancies, provided the physical configuration of the property and the proposed use comply with applicable Dubai regulations.

The position can be different where portions of the villa are allocated to different families or groups and they share facilities or common areas. Where residents share facilities such as kitchens, bathrooms, dining areas or other services within the property, the arrangement is more likely to fall within the definition of shared accommodation.

In that situation, the owner must comply with the requirements of Dubai Law No. (4) of 2026, including any applicable conditions and the requirement to obtain the relevant permit before designating the property for shared accommodation.

Dubai Municipality Has Regulatory Role

Dubai Municipality is the competent authority responsible for regulating shared accommodation under the new law. Article 5 gives the municipality broad powers to establish the framework governing the activity.

These powers include preparing policies and strategic plans, determining the conditions for allocating a property for shared housing, setting the maximum number of residents permitted in a unit and specifying the minimum space and shared facilities required.

The municipality is also responsible for determining the areas where shared accommodation may be permitted, taking into account factors such as urban planning, population density, infrastructure, sewage systems and the social character of residential neighbourhoods.

The authority is further empowered to create and manage the digital window through which applications and related requirements for shared accommodation can be handled.

Lease Contracts Must Be Clear

Even where a villa arrangement does not constitute shared accommodation, landlords must still comply with Dubai’s tenancy rules. Each lease should clearly identify the premises being rented, its intended purpose, duration and rent. Where different floors are leased to different families, the contracts should accurately describe the relevant floor or self-contained portion rather than creating uncertainty about the property covered by each tenancy.

The tenancy arrangements must also comply with the applicable requirements for registration with RERA through Ejari.

The fact that a villa has two floors does not, by itself, automatically mean that each floor can be rented separately. The owner must consider whether the property is legally configured and authorised for the proposed use and whether the arrangement creates shared accommodation within the meaning of the 2026 law.

Owners Should Check Before Leasing

Villa owners considering separate tenancies should therefore establish whether the proposed arrangement involves genuinely independent residential units or whether the occupants will share facilities and services.

Where there is uncertainty, the owner should approach Dubai Municipality for clarification before entering into the tenancy arrangements. This is particularly important where the proposed occupation could fall within the regulatory framework for shared accommodation.

If the arrangement is permitted, the owner should ensure that each tenancy agreement complies with Dubai’s tenancy legislation and that the relevant contracts are properly documented and registered.

The introduction of Dubai Law No. (4) of 2026 therefore adds an important regulatory consideration for villa owners. Renting different floors to different families is not necessarily prohibited, but the legality of the arrangement depends on how the property is configured, how it is occupied and whether the occupants share facilities or services.

Owners should establish the applicable requirements before renting individual floors rather than assuming that separate physical floors automatically qualify as separate, unrestricted residential tenancies.

People living in shared accommodation in Dubai are required to have a tenancy agreement covering the space allocated to them, under the emirate’s new law regulating the occupancy and management of shared housing.

Dubai Law No. 4 of 2026 applies to real estate units across the emirate, including properties located in special development areas and free zones. It establishes rules governing owners, landlords, authorised operators and occupants, while setting out requirements intended to regulate shared accommodation and prevent overcrowding and unregulated housing. The law came into force on August 26, 2026.

However, the law specifically excludes real estate units designated for collective labour accommodation from its scope. This means the separate tenancy-contract requirement for individual occupants under the shared housing law does not apply to residents of accommodation falling within the excluded labour housing category.

Separate Agreement For Each Occupant

Under Article 25, a landlord must enter into a tenancy agreement with each occupant of a shared housing unit, register the agreement in the electronic shared housing register and provide the occupant with a copy.

The law defines an occupant as an individual who rents the space allocated to him or her in a shared housing unit for residential purposes under the applicable rules and the tenancy agreement. It also defines a tenancy agreement as the contract between the landlord and occupant under which the landlord allows the occupant to reside in the designated space for an agreed period in return for rent.

The requirement therefore goes beyond a general arrangement under which one person rents an entire property and informally allocates beds or rooms to other residents. Each occupant covered by the law must have a contractual arrangement identifying the space provided for residential use.

The tenancy agreement must also be entered in the shared housing register. The law provides that a tenancy agreement and any amendment to it must be registered to be effective. An unregistered agreement generally cannot be relied upon by the landlord or authorised establishment to exercise contractual rights. However, the law protects a bona fide occupant from the consequences of non-registration and allows such an occupant to enforce the agreement against the owner or establishment, as applicable.

Landlord Responsibilities

The law places a number of obligations on landlords of shared housing. In addition to entering into and registering an agreement with each occupant, the landlord must ensure that the terms of the tenancy or management agreement comply with the conditions and requirements attached to the relevant permit.

The landlord must hand over the designated space on the date agreed in the tenancy agreement and allow the occupant to use it throughout the contractual term in accordance with the agreed conditions. The space must also be in a condition suitable for the intended use and purpose.

The landlord is also required to comply with the maximum occupancy limit specified in the permit and display a sign in a prominent position showing relevant information about the authorised party and the category of shared housing. The law further requires landlords to notify the relevant authority when certain information concerning the owner, establishment or occupants changes.

These provisions are intended to establish a more formal relationship between landlords and individual residents rather than leaving occupants dependent on informal arrangements with other tenants or intermediaries.

Rent And Contract Period

The law requires the tenancy agreement to specify the rental period, with the agreement continuing until the end of that period unless it is terminated in accordance with the law. The parties may renew the agreement by mutual consent.

Rent must also be specified in the tenancy agreement. Unless the parties agree otherwise, the occupant is required to pay rent monthly and in advance.

The law provides that the rent includes charges for electricity and water consumption unless the parties agree otherwise. Where those charges are payable by the landlord, the landlord remains responsible for paying them to the relevant service provider.

This creates a clearer contractual framework for occupants who rent an individual room, bed space or other designated area within a shared property.

Occupants Cannot Sublet

The new law also places restrictions on what occupants can do with their allocated spaces. An occupant may not sublease or otherwise rent out the space allocated to him or her to another person. Any tenancy agreement entered into in violation of this prohibition is considered null and void.

Occupants are also prohibited from using their designated space for purposes other than residential use, allowing another person to reside in or use it, or carrying out economic activities within the shared housing unit.

They must comply with applicable environmental, health and public-safety requirements and take reasonable care of the property and the space assigned to them. They are also prohibited from making alterations, renovations or maintenance works without authorisation.

The restrictions are significant for shared accommodation arrangements in which an existing occupant informally rents out a bed or room to another person. Under the new framework, the right to lease the shared housing unit is restricted to the owner or an authorised establishment.

Labour Camps Remain Excluded

A key distinction under the law is between regulated shared housing and collective labour accommodation. Article 3 expressly excludes real estate units designated for collective labour accommodation from the law. Consequently, the provisions governing individual tenancy agreements under the shared housing regime do not apply in the same manner to residents of accommodation that falls within the collective labour accommodation category.

At the same time, the law covers shared accommodation occupied by individuals or families who are allocated separate spaces while sharing facilities such as kitchens, dining areas, bathrooms and other common areas.

The distinction is important because not every property containing multiple workers or residents will necessarily be treated as collective labour accommodation. The legal classification of the accommodation and the applicable regulatory requirements determine whether the shared housing law applies.

Special Rules For Companies And Students

The law also permits government entities, companies and private institutions to lease shared housing units for their employees and workers, where providing accommodation forms part of their obligations. Educational institutions may similarly arrange shared accommodation for their students, subject to the required permit and applicable standards.

In such cases, employees, workers and students residing in the authorised units may be exempt from entering into individual tenancy agreements.

However, the law still imposes relevant obligations on the organisations providing or allocating the accommodation, as well as on the residents, to the extent appropriate to the nature of the organisation and the occupants.

The framework therefore distinguishes between ordinary shared housing arrangements, where individual occupants generally require tenancy agreements, and specific institutional accommodation arrangements covered by the special provisions of the law.

For ordinary shared housing, the central requirement is clear: an occupant should have a formal tenancy agreement for the space allocated to him or her, and the agreement must be registered in the shared housing register. Collective labour accommodation, however, is expressly excluded from the scope of Law No. 4 of 2026.

Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) has proposed fines of up to SR50,000 for violations involving real estate transaction tax, including providing inaccurate information about property transactions.

The authority has invited public comments on a draft regulation titled “Classification of Violations and Penalties for Real Estate Transaction Tax”. The consultation on Article 15, Paragraph 3, is being conducted through the Istitlaa public consultation platform from September 3 to October 3.

Under the proposed regulation, anyone who violates a provision of the Real Estate Transaction Tax Law or its implementing regulations could face a fine of up to the amount of tax due or SR50,000, whichever is higher.

ZATCA said the draft is intended to classify violations and corresponding penalties related to real estate transaction tax, while improving governance, standardising enforcement procedures and increasing clarity and transparency for parties involved in property transactions.

Saudi Arabia’s Real Estate Transaction Tax is currently imposed at a rate of 5% on qualifying real estate transactions. The current law came into force on April 10, 2025.

The proposed penalties cover several forms of non-compliance. Failure to register a real estate transaction could attract a fine ranging from SR5,000 to SR50,000.

A similar fine range would apply to failure to retain the required tax documents and records within the legally prescribed periods.

Failure to co-operate with ZATCA during inspection procedures or to provide information requested by the authority could result in a fine ranging from SR1,000 to SR50,000.

The draft also covers cases where taxpayers prevent ZATCA employees from carrying out inspections. This includes refusing access to books, records, invoices or accounting documents, or preventing officials from making or retaining copies of documents required for inspection.

Such violations could also attract fines ranging from SR1,000 to SR50,000.

The draft further proposes fines of between SR1,000 and SR50,000 for violations of provisions contained in the implementing regulations or related bylaws.

ZATCA’s existing guidance states that providing incorrect information about the value of a real estate transaction, where this results in the non-payment or underpayment of tax, may be treated as a tax-evasion violation. The penalty under the existing framework can range from the amount of tax due to three times that amount.

The proposed classification would therefore provide a more detailed framework for determining penalties for different types of non-compliance with the real estate transaction tax regime.

The Dubai Real Estate Court has ordered a buyer to pay two property sellers Dh7.52 million, representing 80 per cent of a Dhs9.4 million deposit, after he failed to complete a Dh47 million property purchase.

The court also ordered the buyer to pay interest at 5 per cent annually from the date the lawsuit was filed until full payment, along with legal expenses and lawyers’ fees.

The two sellers filed a lawsuit against the buyer and a real estate brokerage company, seeking payment of the Dh9.4 million deposit after the buyer backed out of the purchase of a unit in a project in Dubai’s Business Bay area.

According to the case documents, the sellers entered into a sale agreement with the buyer in May for a total consideration of Dh47 million.

Under the agreement, the buyer was required to pay a Dh9.4 million deposit when signing the contract, with the remaining Dh37.6 million payable upon registration and transfer of ownership by June 2026.

The buyer issued a cheque for the Dh9.4 million deposit and handed it to the real estate brokerage company. The brokerage told the court that it was holding the cheque as a trustee and was prepared to release it to whichever party the court determined was legally entitled to it.

The sellers told the court that they had prepared the documents required to complete the ownership transfer. However, the buyer failed to pay the outstanding balance or complete the purchase within the agreed timeframe.

The court also found that there was no evidence of a written agreement extending the deadline. The contract expressly required any amendment to its terms or dates to be made in writing.

Contract Allowed Seller to Retain Deposit

The court noted that the agreement expressly gave the sellers the right to terminate the contract and retain the deposit if the buyer failed to pay the full purchase price or complete the transaction by the agreed date for reasons attributable to the buyer.

The additional contractual terms, however, provided for the deposit to be divided between the sellers and the brokerage company. Under those terms, 80 per cent of the deposit was payable to the sellers, while the remaining 20 per cent was allocated to the brokerage.

The court concluded that the buyer had breached his contractual obligations by failing to complete the transaction.

As a result, the sellers were entitled to 80 per cent of the Dh9.4 million deposit, amounting to Dh7.52 million, rather than the full value of the cheque.

Buyer Ordered to Pay Interest

In addition to the Dh7.52 million, the court ordered the buyer to pay legal interest at an annual rate of 5 per cent from the date the lawsuit was filed until the amount is paid in full.

The buyer was also ordered to bear the legal expenses and lawyers’ fees incurred by the sellers. The court dismissed the remaining claims.

Dubai’s new shared housing law has come into force, bringing a comprehensive regulatory framework for a sector that has long operated in a largely informal manner. Dubai Law No. 4 of 2026 on the Regulation of Occupancy and Management of Shared Housing came into effect on August 26, 2026, 180 days after its publication in the Official Gazette.

The law applies across Dubai, including private development zones and free zones, and covers property owners, occupants, licensed establishments and tenancy and management contracts relating to shared housing. Collective labour accommodation is excluded from its scope.

The legislation is intended to regulate shared accommodation, protect the rights of owners and occupants, improve health and safety standards, curb overcrowding and unregulated housing, address building and land-use violations and promote greater fairness in the rental market.

Who Can Live in Shared Housing?

The law specifically identifies six categories eligible for shared housing: families, individual women, individual men, female students, male students, and government employees and workers of private companies and establishments.

However, eligibility for shared housing does not mean that every category can occupy every property. Dubai Municipality has the authority to establish specific standards for each category based on the type of property and can subsequently amend, remove or add categories.

Shared housing is defined as accommodation where individuals or families are allocated designated spaces within a property for residential purposes while sharing facilities and services such as kitchens, dining rooms, bathrooms and outdoor areas.

Which Properties Can Be Used?

The law permits several types of properties to be designated for shared housing, including residential apartments, standalone houses, residential complexes, mixed-use buildings, townhouses and multi-storey buildings.

But a property cannot simply be converted into shared accommodation because an owner or tenant wants to rent out individual spaces. A permit must first be obtained from the relevant authority.

Properties must meet applicable planning and building requirements as well as health, safety, fire prevention, environmental, security and electrical safety standards. Authorities can also determine the maximum number of occupants, the space to be allocated to each occupant and the facilities and services that must be provided.

Permits are Mandatory

One of the central requirements of the new law is that no individual or legal entity may designate a property for shared housing without obtaining the required permit.

The permit is generally valid for one year and can be renewed for similar periods. The relevant authority may, at the owner's request, issue a permit for two years. Applications for renewal must normally be submitted at least 30 days before the permit expires.

The law also regulates who can commercially operate shared housing. Leasing rights are restricted to the property owner and authorised establishments. A licensed establishment may manage a property for the owner or lease the property from the owner and sublease it to occupants.

Tenants Cannot Sublet Their Spaces

The new framework draws a clear line between authorised shared housing and informal subletting. An occupant cannot re-rent the space allocated to them or allow another person to live in and use that space. Any sublease entered into by an occupant is considered invalid under the law.

This means that a person renting a room or designated space in a licensed shared property cannot turn that space into another rental arrangement or commercially accommodate another person without authorisation.

The law does not specifically establish a numerical limit on ordinary social visitors. However, occupants are prohibited from allowing another person to reside in and benefit from their allocated space. The distinction is therefore between a visitor and someone who is effectively occupying the space as a resident.

Rent is Monthly and in Advance by Default

The law establishes monthly advance payment as the default arrangement for shared housing. Under Article 19, the rent must be paid in advance on a monthly basis unless the landlord and occupant agree otherwise in the tenancy contract. This means the monthly payment requirement is a statutory default rather than an absolute prohibition on other payment arrangements.

The rent is agreed in the tenancy contract and includes the occupant’s use of common facilities and services.

Electricity and water consumption charges are also included in the rent by default unless the parties agree otherwise. Even when the parties agree to deal with these charges separately, the landlord remains responsible for paying the relevant utility provider.

Tenancy Contracts Must Be Registered

The law creates a dedicated electronic Shared Housing Registry administered by the Dubai Land Department. Management contracts, tenancy contracts, amendments to those contracts and occupant information must be recorded in the registry. A tenancy contract must be registered to be effective under the law.

Importantly, however, failure to register a contract does not prejudice a good-faith occupant, who may still enforce the tenancy contract against the owner or authorised establishment.

The Dubai Land Department is also responsible for establishing the required information for tenancy and management contracts and developing standard contract templates.

Occupants Get Specific Protections

The law provides several protections for occupants. A change in ownership of a shared housing property does not, by itself, terminate the existing tenancy. The occupant can continue living in the property according to the terms of the existing contract.

An occupant can also terminate the tenancy during its term by giving at least 30 days’ notice, or the longer notice period specified in the contract. Where advance rent has been paid, the occupant may seek its return, subject to a deduction equivalent to one month’s rent.

If the amount due is not returned within 30 days after the request, the occupant may approach the execution judge to seek recovery.

When Can an Occupant Be Evicted?

The law sets out specific circumstances in which an occupant may be required to leave before the tenancy expires. These include failure to pay rent within 30 days of receiving a payment notice, unlawful use of the property, cancellation of the property's permit, a change in approved land use, serious structural problems, demolition or redevelopment requirements and certain circumstances in which the owner seeks to recover the property for personal use or use by a first-degree relative.

An eviction application must be submitted to the execution judge. An interested party can challenge an eviction decision within seven days of being notified, in accordance with the applicable procedures.

Owners and Operators Have Wider Responsibilities

Landlords and authorised operators must comply with the approved occupancy limits and ensure that the property continues to meet the applicable technical and safety requirements.

They must register tenancy contracts, provide occupants with copies of their contracts, maintain the property, carry out required repairs and ensure that no unauthorised alterations or changes of use are made.

They must also provide occupants with rules governing the property and a multilingual guide explaining their rights and obligations, emergency contact details and permitted uses of the accommodation.

Marketing requirements have also been introduced. Advertisements for shared housing must include the approved trade name of the establishment and its permit number. Misleading advertising or advertising a property for a purpose that is not authorised under the permit is prohibited.

What are Occupants Prohibited From Doing?

Occupants must comply with health, environmental and safety requirements and take reasonable care of their allocated space.

They cannot use the space for purposes other than residential accommodation, allow another person to reside in or benefit from it, conduct economic activities from the property or sublet their allocated space.

They must also allow authorised inspectors to enter the property when required for regulatory inspections.

Fines Can Reach Dh1 Million

The new law introduces significant penalties for violations. A breach can attract a fine ranging from Dh500 to Dh500,000. If the same violation is repeated within one year, the fine can be doubled, subject to a maximum of Dh1 million.

Authorities may also suspend an establishment’s activity for up to six months, cancel a permit, coordinate the cancellation of a commercial licence, cut public services from a non-compliant property until the violation is rectified, refuse certain transactions relating to the property and, in appropriate cases, order the evacuation of a non-compliant property.

The law also provides for inspections and enforcement measures, with authorised officials empowered to investigate violations and inspect relevant records and properties in accordance with the law.

Existing Operators Have Time to Comply

The law does not require existing shared housing operators to become compliant overnight. Owners who had already designated their properties for shared housing, as well as establishments already operating in the sector before the law came into force, have one year from August 26, 2026 to bring their arrangements into compliance.

The Director General of Dubai Municipality may extend this period once where necessary.

A More Regulated Shared Housing Market

The new law effectively moves Dubai’s shared housing sector towards a licensed and monitored model. Shared accommodation remains available to a broad range of residents, including families, men, women and students, but its operation is now subject to permits, occupancy standards, registered contracts, safety requirements and regulatory oversight.

For residents, the framework provides clearer contractual rights and protections. For landlords and operators, it introduces greater compliance responsibilities and potentially substantial penalties for violations.

The legislation also gives Dubai Municipality and other competent authorities powers to develop detailed standards and implementing rules, meaning the regulatory framework for shared housing is likely to become more specific as those measures are introduced.

When a tenancy in Dubai comes to an end, the condition in which the property is returned is frequently the final point of contention between landlord and tenant. Faded paint, worn flooring and minor surface marks are often treated by landlords as chargeable damage, while tenants regard the same conditions as the inevitable result of ordinary occupation.

Buying off-plan is, by definition, an act of trust. The purchaser commits substantial funds to a unit that does not yet exist, relying on floor plans, specifications and marketing materials rather than a finished product. Construction realities, design revisions and authority requirements mean that some divergence between the original concept and the delivered unit is common and often lawful.

But when a change is significant enough to affect the value, function or character of the property, it can raise real legal questions about the developer's contractual authority to make the change and about what remedies, if any, the purchaser may pursue. This article explains how that question is approached under UAE law, with particular focus on Dubai, which has one of the country's most developed off-plan regulatory frameworks.

What is a Material Change to an Off-Plan Property?

There is no single statutory definition of a "material change" that applies uniformly to every off-plan transaction in the UAE. Whether a change is material is a fact-specific question, assessed against the Sale and Purchase Agreement (SPA), the approved plans and specifications registered with the relevant authority, and the significance of the deviation to the purchaser's bargain.

Examples of changes more likely to be treated as material include a substantial reduction in unit size, a significant alteration to the approved layout or floor plan, removal or substantial downgrading of promised amenities, materially inferior finishes or materials compared with those specified, changes affecting the unit's use, access or views, or relocation of common facilities that formed part of the purchase decision.

Minor variations, such as a change of paint supplier, a similar-quality substitute fitting or an adjustment required by a technical authority, will generally not meet this threshold, particularly where the SPA expressly permits such adjustments.

It is important not to conflate promotional material with contractual terms. Brochures, renderings and sales presentations may shape a purchaser's expectations, but the SPA and its registered annexes will ordinarily be the primary reference points for determining what was actually promised and what recourse may exist if it is not delivered.

The UAE Legal Framework

Real estate regulation in the UAE is substantially Emirate-specific. Each Emirate maintains its own land department and rules governing off-plan sales, escrow arrangements and developer obligations. A rule that applies in Dubai will not automatically apply in Abu Dhabi, Sharjah or elsewhere, and purchasers should identify the applicable Emirate's regime before relying on any specific provision.

In Dubai, the principal legislation includes:

• Law No. (8) of 2007 Concerning Escrow Accounts for Real Estate Development in the Emirate of Dubai, which requires developers selling units off-plan to be licensed, registered with the Dubai Land Department (DLD), and to deposit purchaser payments into a project-specific escrow account supervised by the Real Estate Regulatory Agency (RERA). This law is primarily concerned with the financial protection of purchaser funds rather than defining "material change", but it underpins the regulatory relationship between developer, purchaser and authority.
• Law No. (13) of 2008 Regulating the Interim Real Property Register in the Emirate of Dubai, as amended, including by Law No. (9) of 2009 and Law No. (19) of 2020, which governs the Oqood interim registration system for off-plan units and sets out procedures relevant to termination of an off-plan SPA, particularly in cases of purchaser default. This framework is a key reference point when considering how an SPA may be terminated and what portion of payments a party may be entitled to retain or recover, although its provisions are directed principally at purchaser default rather than developer-driven changes.
• The UAE Civil Transactions Law (Federal Decree-Law No. 25 of 2025), which supplies the general federal law of contract applicable across the UAE, including principles concerning the binding effect of contracts, good-faith performance, breach and compensation. These general principles may be relevant to disputes concerning departures from agreed specifications, alongside specific Dubai legislation.

RERA and the DLD also issue administrative circulars, registration requirements and project-specific approvals that may be relevant to a particular dispute. Because these instruments and requirements can change and may be project-specific, their current content should be verified directly with the DLD rather than assumed.

When Can a Developer Legally Change the Property?

Most Dubai off-plan SPAs contain a variation clause permitting the developer to substitute materials, amend specifications, alter layouts or make changes required by government authorities, provided replacements are of equal or better quality. Such clauses are common and generally enforceable, but they are not unlimited licences to alter the property as the developer sees fit.

The scope of the clause, what it covers, whether it is qualified by "equal or better quality" language, and whether it excludes fundamental elements such as unit size or unit identity must be examined closely. A change that falls outside the clause's actual wording, or that is inconsistent with the essential character of what was sold, may not be validly authorised by that clause, even where the SPA contains a general variation provision.

When Can a Change Become a Legal Problem?

A change becomes potentially problematic where it exceeds what the SPA's variation clause permits, or where no such clause covers it, and the deviation is significant enough to affect the value, usability or fundamental characteristics of the unit or project as originally contracted.

This is where the distinction between a legitimate technical adjustment and an actionable breach becomes important. The assessment is inherently fact-dependent. There is no bright-line rule under which a particular percentage reduction in size, or a specific category of amenity change, automatically amounts to a breach. The contractual wording, nature and extent of the change, and its practical impact on the purchaser must be considered together.

What Remedies May Be Available to the Purchaser?

Purchasers should not assume that a material change automatically gives them a right to cancel the SPA and obtain a full refund. Depending on the SPA terms and applicable law, potential steps may include requesting documentation and clarification from the developer, formally objecting in writing, seeking compliance with the contracted specifications and, where genuinely justified, pursuing contractual or statutory remedies, including compensation or, in appropriate cases, termination.

Whether termination, damages or specific performance is available, and on what terms, depends on the SPA and the applicable legal principles. These remedies are legally distinct and are not interchangeable. A purchaser should therefore obtain advice on the specific contractual and factual circumstances before taking steps that could affect the status of the SPA or payments already made.

What Should an Off-Plan Buyer Do?

Purchasers who believe a material change has occurred should preserve the signed SPA and all annexes, approved floor plans and specifications, sales brochures and marketing material, payment records, written correspondence with the developer, including any notice of the change, and photographs or construction updates documenting the unit's progress. These documents, particularly the SPA and approved plans, form the primary basis on which any claim would be assessed.

Escalation typically begins with formal written communication to the developer, followed, where unresolved, by engagement with the relevant DLD/RERA mechanisms available for the dispute, or recourse to the competent courts or arbitration where applicable. RERA is a regulatory authority rather than a court, and the availability of a particular escalation route depends on the nature of the project, the contractual arrangements and the dispute.

Purchasers should also avoid relying solely on verbal assurances from sales representatives or project personnel. Any proposed change, explanation or commitment should, where possible, be documented in writing. Maintaining a clear record can become particularly important if the dispute later turns on what the purchaser was told, what the developer agreed to deliver, or whether a variation was properly notified and authorised.

Conclusion

A developer's ability to modify an off-plan property in Dubai is real but not unconstrained. It is shaped by the wording of the SPA's variation clauses, the approved plans registered with the authorities and the general principles of UAE contract law. Equally, a purchaser's remedies for a material change are not automatic. They depend on whether the change genuinely falls outside what was contractually permitted and on the specific facts of the case.

Given how fact-sensitive these questions are, and the differences that can exist between Emirates and individual SPAs, purchasers and developers should have the actual contract and project documentation reviewed before drawing definitive conclusions about their legal position. A careful assessment at an early stage can help establish whether a proposed change is a permissible variation or one that may give rise to a contractual dispute.

Ask most tenants what happens if they fall behind on rent and you will get one of two answers: the law will provide a fairer payment plan, or a landlord who refuses to negotiate is breaking the rules. Both assumptions are wrong. Here is what Dubai’s tenancy law and the UAE Civil Code actually provide, and where a tenant facing genuine financial difficulty may still have room to negotiate.

Rent Payment Schedules Are a Matter of Contract, Not Statutory Right

Most Dubai tenancies operate through post-dated cheques, divided into one, two, four, six or twelve payments, with the arrangement agreed before the lease is signed. Once it is recorded in the Ejari-registered contract, that is the agreed payment schedule. A tenant’s ability to pay monthly rather than annually is something negotiated at the beginning of the tenancy. It is not a right granted by Law No. (26) of 2007.

So, when financial hardship strikes six months into a twelve-month lease, there is no provision in the law that allows a tenant to demand a switch to monthly payments. Reaching such an arrangement requires the landlord’s agreement, and that agreement should be recorded in writing before either party relies upon it.

Landlords Are Not Legally Required to Grant a Payment Plan

Nothing in Dubai’s tenancy law requires a landlord to restructure rent payments because a tenant is experiencing financial difficulty. Refusing a revised schedule does not, by itself, place the landlord in breach of the law. The original contract continues to determine what is owed and when payment is due.

That said, many landlords may agree to some flexibility. Finding a replacement tenant can cost more than accommodating a short delay from an otherwise reliable tenant, and landlords understand this. However, tenants should view such flexibility as goodwill, not an entitlement. Clients on both sides of these disputes often assume the other party has a legal obligation that does not actually exist, and correcting that assumption can be important before negotiations begin.

The Hardship Doctrine Offers a Narrow Route, Not a Guarantee

There is a hardship concept in UAE law, although it is easy to overstate its scope. Article 224 of the new Civil Code, Federal Decree-Law No. (25) of 2025, which took effect on 1 June 2026, allows a court to reduce an obligation, or in certain circumstances unwind a contract, where an unforeseen and exceptional public event makes performance sufficiently onerous to threaten serious loss. It replaced Article 249 of the former 1985 Civil Code, which allowed only a reduction and not rescission. Anyone dealing with a lease signed before 1 June 2026 remains subject to the older, narrower provision.

The threshold is high in either case. A pay cut or job loss, on its own, is unlikely to meet it, and a judge determines the outcome. A tenant cannot rely on hardship as a basis for simply withholding rent. The provision is worth knowing about, but it should not form the foundation of a strategy without careful legal assessment.

What Happens if Rent Goes Unpaid

Article 25(1)(a) of Law No. (26) of 2007, as amended, gives a landlord grounds to seek eviction during the tenancy when rent remains unpaid for thirty days after formal written notice. For non-payment, that is the relevant route to mid-term eviction, and the landlord cannot proceed before the required notice has been served.

Those thirty days exist for a reason. A missed payment does not automatically bring a tenancy to an end, and it should not be treated as though it does. The notice period gives a tenant a genuine opportunity to settle the outstanding amount, begin discussions with the landlord or determine the best course of action before the dispute escalates.

What Tenants in Financial Difficulty Can Actually Do

Speed helps more than anything else. A tenant who sees financial trouble coming should inform the landlord in writing before the payment falls due, ideally with a specific proposed schedule rather than a general request for patience. If the landlord agrees to change the payment terms, the arrangement should be documented and, where appropriate, reflected in an updated Ejari record so that it can be relied upon later if necessary.

If no agreement is reached and a formal notice to pay has already been served, the tenant’s remaining recourse may involve the Rental Disputes Settlement Centre, where the circumstances of the case, including any genuine hardship and payment history, may be relevant. None of this replaces legal advice once a formal notice has been received. Thirty days can pass faster than it sounds.

Rent difficulties rarely look the same twice, but the legal position remains broadly consistent. A payment plan is negotiated, not automatically owed, and the principal protection available to a tenant comes from the applicable notice period and, in rare cases, the courts — not from an assumption that the law will intervene on their behalf. Tenants who act early and put arrangements in writing generally have far more room to negotiate than those who wait for the system to act for them.

The Ministry of Justice (MoJ) is expanding access to legal and real estate services through a nationwide network of external service centres, allowing citizens, residents and businesses to complete a growing range of government transactions closer to where they live and work.

The initiative is designed to reduce travel time, improve convenience and enhance the customer experience by integrating government services into shopping malls, government service complexes and other high-traffic locations.

The ministry’s network currently comprises 10 external service centres. Visitors can access a wide range of services at these locations without having to travel to the ministry’s headquarters.

All centres operate during morning hours, while four also provide evening services to accommodate working professionals and members of the public who may be unable to visit during regular office hours.

The ministry has also introduced a mobile service office at Qatar Mall and Katara during evening hours. The service extends government facilities to high-footfall locations and provides greater flexibility for customers.

The external centres primarily provide real estate registration and notarisation services. Selected locations also process transactions on behalf of other government entities, including services related to banks, companies and vehicle documentation.

Two dedicated offices specialise in transactions involving non-Qatari ownership and usufruct rights in real estate, supporting Qatar’s regulated property investment framework.

Recent official figures highlight the scale of the legal and real estate sector supported by the ministry. Qatar currently has 703 registered real estate brokers, 424 registered experts and 306 licensed practising lawyers.

The MoJ’s physical service network is complemented by its digital transformation programme, which provides a broad range of online services covering notarisation, property registration, legal information and application tracking.

The digital platforms help reduce the need for in-person visits, while external centres continue to provide services that require physical verification, document authentication or other procedures that must be completed in person.

The ministry also publishes open data on completed real estate registration and documentation transactions, supporting greater transparency and enabling the monitoring of service performance.

The wider government service network continues to record strong demand. Official figures show that Government Service Centres delivered more than 146,000 services during the third quarter of 2025.

The Ministry of Justice ranked among the busiest government entities, completing more than 11,000 transactions in September 2025 alone.

The figures underline the growing importance of decentralised government services and integrated service centres in improving accessibility, convenience and operational efficiency.

By combining strategically located external centres, extended operating hours, mobile service offices and expanding digital platforms, the Ministry of Justice is continuing to bring legal and real estate services closer to the public while maintaining efficiency, accuracy and high standards in transaction processing.