The Interim Property Register in Dubai: How Off-Plan Ownership Is Recorded

Dubai operates a dual-register system for real property. The Interim Property Register captures off-plan transactions before construction is complete — governed by Law No. (13) of 2008, administered through the Oqood portal, and backed by escrow protections that apply from the moment of registration.

What the Interim Property Register Is and Why It Exists

The Dubai Land Department (DLD) maintains two parallel registers for real property. The permanent Property Register, established under Law No. (7) of 2006, records completed ownership by way of title deed. The Interim Property Register exists alongside it to capture transactions where construction is still in progress and no title deed has yet been issued.

Article 2 of Law No. (13) of 2008 Regulating the Interim Property Register in the Emirate of Dubai defines it as the documents maintained by the DLD — in written or electronic format — in which sale contracts, off-plan sales, and other pre-completion legal dispositions are registered prior to inclusion in the permanent Property Register.

Before 2008, no mandatory registration mechanism existed for off-plan sales in Dubai. Buyers who paid deposits or instalments held only contractual claims with no public record at the DLD, creating conditions for double-selling, unregistered encumbrances, and unresolvable disputes. Law No. (13) of 2008 addressed this directly by mandating provisional registration for all off-plan dispositions and rendering any unregistered transaction legally void.

The Legal Framework

Law No. (13) of 2008 is the primary statute. Article 3(1) establishes the foundational rule: any sale or legal disposition of an off-plan unit that is not entered in the Interim Property Register is void. This applies equally to sales, mortgages, and any other encumbrance.

Article 4 prohibits developers from commencing sales before taking possession of the land and obtaining the required regulatory approvals. Article 6 confirms that units already registered in the Interim Property Register may subsequently be disposed of by way of sale, mortgage, or any other legal disposition — provided each such transaction is itself recorded.

The law has been amended three times. Law No. (9) of 2009 updated the definitions and default procedures. Law No. (19) of 2017 introduced a structured framework for buyer defaults, including mandatory DLD notification and mediation. Law No. (19) of 2020 refined the termination and refund provisions, updating the permitted retention percentages and refund timelines.

Executive Council Resolution No. (6) of 2010, the Implementing Bylaw, added further requirements: developers must obtain a demarcation certificate and take actual possession of the plot before commencing off-plan sales; a penalty of AED 10,000 applies for late registration applications; and a developer may not refuse to hand over a unit or register it in the buyer's name on the basis of financial dues unrelated to the sale agreement for that specific unit.

Registration Through the Oqood Portal

All provisional registration applications are submitted by the developer through the DLD's Real Estate Developers Portal — Oqood. The buyer does not submit the application directly but must provide the signed SPA and valid identification documents.

The process follows five steps. The developer logs into the Oqood portal and selects the relevant registration service. Property unit and transaction details — buyer information, sale value, payment terms — are entered. Required documents are uploaded: for individual buyers, a copy of the signed SPA, valid UAE ID, and passport for non-residents; for corporate buyers, trade licence, memorandum of association translated into Arabic, shareholder certificate, and power of attorney where applicable. Payment is made via Noqodi wallet or by deduction from the project's escrow account. The DLD processes the application within one business day, after which a provisional registration e-certificate is issued and sent by email to the buyer.

The SPA must be submitted for registration within 90 days of signing. The developer bears responsibility for meeting this deadline. An application submitted within the window is deemed compliant even if the DLD processes it after the 90-day period has elapsed. Failure to apply within the deadline attracts a penalty of AED 10,000, and without registration, the buyer holds no recognised legal interest in the DLD's records.

Buyer Protections

The legislative framework surrounding the Interim Property Register provides several layers of protection.

Voidness of unregistered transactions. The central protection under Article 3(1) is that any unregistered off-plan disposition has no legal effect. Each registration is verified against the DLD's central database, preventing a developer from selling the same unit to multiple buyers without detection.

Mandatory escrow accounts. Law No. (8) of 2007 Concerning Escrow Accounts for Real Estate Development requires every developer to open a dedicated escrow account for each project. All buyer payments must be deposited into this account and may only be released upon verified construction milestones. This operates in parallel with the Interim Property Register, protecting the buyer's financial outlay independently of the provisional registration record.

Prohibition on unauthorised fees. Article 8 of Law No. (13) of 2008 prohibits developers from charging any fees on the sale, resale, or other legal disposition of off-plan units beyond administrative costs approved by the DLD.

Structured default procedures. Under Article 11, as amended by Law No. (19) of 2020, a developer must notify the DLD of any buyer default, after which the DLD issues a 30-day notice to the buyer and attempts mediation. Only upon exhaustion of this process may the developer proceed with termination. 

Dispositions Available While in the Interim Register

A unit that remains in the Interim Property Register is not frozen. Article 6 of Law No. (13) of 2008 expressly permits three categories of further disposition, each of which must itself be recorded through Oqood.

Resale. A buyer may transfer their off-plan interest to a third party, subject to the standard 4% registration fee on the new transaction value and, in most cases, a developer No Objection Certificate under the terms of the original SPA.

Provisional mortgage. An off-plan unit may be mortgaged while in the Interim Property Register. Mortgage-linked purchases can be processed simultaneously with the initial sale registration at an authorised DLD Trustee Centre.

Rent-to-own registration. Lease-to-own contracts for units under construction are registered provisionally through the DLD's dedicated rent-to-own service within the Oqood portal.

Transition to the Permanent Property Register

The Interim Property Register is by design temporary. Upon project completion and issuance of the completion certificate, the developer must register all sold units in the permanent Property Register in the names of buyers who have fulfilled their contractual obligations. The DLD's completing initial procedures service is the Oqood pathway through which the provisional record converts into a permanent title deed. Where the 4% fee was collected at the provisional stage, the buyer at this point pays only the title deed issuance fee of AED 250 and the applicable map fee. The buyer then receives an electronic title deed certificate, and the record migrates from the Interim to the permanent register.

Where a developer fails to complete this process, Article 7 of the law grants the DLD authority to register the unit in the buyer's name on its own initiative, provided the buyer has fulfilled all contractual obligations.

Registration status can be verified through the Dubai REST application or through a formal property status inquiry at EGSH or another authorised Real Estate Registration Trustee Centre, which accesses the DLD's central database directly.

All information reflects publicly available government sources and legislation as of 2026. Fees, thresholds, and procedural requirements are subject to change. Registration in the Interim Property Register records a provisional interest — it does not constitute final ownership. Applicants are advised to verify current requirements directly with the DLD or an authorised Real Estate Registration Trustee Centre before initiating any transaction. This content does not constitute legal or financial advice.
https://egsh.ae/