---
title: "The licensing rules that affect co-broking in Dubai"
description: "What RERA, Trakheesi, Form A, Form I, and Form F actually mean for how co-brokered deals are split, proved, and paid in Dubai."
category: "dubai-market"
readingTime: 11
---
## The deal everyone pictures, and the one that actually happens

Two agencies. One buyer, one seller. Each agent does their job, the Form F gets signed, the trustee office transfer happens, and both sides collect. Clean.

That is not always what happens. What actually happens — more often than anyone in the market wants to admit — is that the listing agent collects the full commission from the seller at the trustee office, then the conversation about the buyer's agent's share turns cold. Or the split agreed on a WhatsApp voice note is not the split that gets paid. Or neither party can prove who agreed to what because nothing was signed before the client moved. The commission dispute that follows is not a mystery. It is the predictable result of a market where the licensing framework makes the co-broking relationship possible, but does not automatically enforce the split between the two agencies involved.

To work co-brokered deals in Dubai without getting stung, an agent needs to understand not just that there are rules, but exactly which rules govern which part of the transaction — and where those rules stop, leaving the split entirely dependent on what the two agencies agreed in writing before the money moved.

## Who is allowed to be in the deal at all

The starting point is licensing. The Dubai Land Department oversees the real estate sector through the Real Estate Regulatory Agency (RERA), which sets the licensing standards, training rules, exams, and compliance requirements for brokers. Only an agent holding an active RERA broker card, working under a brokerage with a valid Dubai trade licence, can lawfully collect commission, and the listing must carry a valid Trakheesi permit.

That last point matters for co-broking in a way that is often missed. The Trakheesi permit is not just a marketing technicality. The permit links to a specific property, a specific broker, and a valid listing agreement, and permits are valid for the duration of the listing contract and must be displayed on all marketing materials, including online portal listings, social media posts, and print advertisements. A buyer's agent who picks up a lead on a property marketed by another brokerage is entering a transaction where the permit — and the authority it represents — belongs to someone else. That has real consequences for how the co-brokered relationship has to be structured.

Every legitimate brokerage in Dubai holds an Office Registration Number (ORN) from RERA, and every individual agent holds a Broker Registration Number (BRN). Before two agencies agree to work a deal together, both agents should verify that the other is actively licensed. The DLD broker registry is public. The check takes sixty seconds and removes any later claim that one party did not know they were working with an unlicensed operator — a claim that would complicate any subsequent dispute.

## The listing side: Form A and what it controls

Every secondary market co-broking situation starts with a property being listed under Form A. The Dubai Land Department has stated that real estate brokers require written authorisation from property owners before they can market any units, and the mandatory "Real Estate Marketing Agreement" — Form A — is the core of this electronic permit system through Trakheesi.

Form A is the listing agency's document. It sets out the commission agreed with the seller, any exclusivity status, and the marketing authority. According to RERA, a property owner may conclude no more than three Form A agreements simultaneously and engage a maximum of three brokers — one contract for each broker engaged. This is the market context in which co-broking operates: most Dubai secondary listings are non-exclusive, which means the listing agent knows there may be other agents with competing buyer introductions, and the seller has potentially authorised other agencies to market the same property.

Owners who allow unregistered marketing expose themselves to disputed commission claims and complications when the transaction reaches Form F. This regulatory architecture is deliberate: it gives DLD and RERA full visibility over who is marketing what, on whose authority, and at what price.

The critical point for the buyer's agent: Form A defines the seller's commission obligation to the listing agency. It says nothing about the buyer's agent, and it does not create any entitlement for a second agency. The buyer's agent's right to a share of the transaction has to be established separately — on a different document, signed between the two agencies, before the deal closes.

## Form I: the document that makes the split enforceable

Form I comes into play when a buyer's agent identifies a suitable property that is listed by a different agent. Before the buyer's agent can arrange viewings, share the property's details, or participate in negotiations, both agents must sign Form I. This protects the listing agent's client relationship, ensures the buyer's agent receives their agreed share of commission, and prevents disputes about who facilitated the sale.

The agent-to-agent agreement specifies the property in question, the names and RERA registration details of both agents, the commission split arrangement (typically 50/50 of the total commission), confidentiality obligations regarding client information, and terms governing how the agents will cooperate through the transaction.

Form I specifies which agent is responsible for particular tasks, such as coordinating with the developer or attending the final transfer at the Trustee office. By having a signed Form I, both agents are legally bound to cooperate in the best interest of their clients, preventing potential "poaching" of clients or disputes over fees.

The split most commonly seen is 50/50, but that is convention, not law. The split written into Form I is the split that governs. If two agencies agree 60/40 and that is what Form I says, that is what is enforceable. If they agree 50/50 verbally and sign nothing, the buyer's agent's position in any later dispute is close to zero.

A verbal commission split agreement is not enforceable under RERA regulations. If a dispute arises between two agents over who is owed what, the agent without a signed Form I is in a very weak position.

In fast-moving markets like Dubai, agents sometimes proceed on trust or a phone call agreement when time is short. This almost always creates problems if the deal becomes complicated. The standard response to time pressure — "let's get the Form I sorted after we lock the client" — is precisely backwards. The Form I needs to be in place before the viewing, before the offer, and certainly before the MOU.

## Form F: where commission appears, and what it does not settle between agencies

Form F is the Contract of Sale between the buyer and seller — often referred to as the Memorandum of Understanding (MOU). 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.

Commission appears in Form F as an amount owed by the client — the seller pays their agent, the buyer pays their agent. Most agents consider commission earned when the buyer and seller sign the MOU, and this is the standard expectation supported by RERA in disputes. That is when entitlement crystallises. Payment may happen at transfer rather than at MOU signing, but the right to the fee is established at Form F.

Here is what Form F does not do: it does not resolve the internal split between two agencies. Form F records each side's commission obligation to their own agent. How the listing agency and the buyer's agency then divide what gets paid is a matter entirely between those two agencies — and entirely dependent on Form I. The two documents work together but serve different purposes. Treating Form F as sufficient documentation for a co-brokered split is a mistake agents make at the start; they usually only make it once.

## The payment gap: why the money stalls

A shared listing closes. Form F is signed. The buyer's commission is due. In a clean deal, the buyer's agent collects directly from the buyer — and the seller's agent collects from the seller — and the two agencies never need to exchange money between themselves. That is the cleanest structure: each client pays their own agent, each agency is independently paid.

The most common structure in Dubai is a co-brokerage arrangement where the buyer pays 2% commission to their agent and the seller pays 2% commission to their agent. Each side pays their own agent directly. That is the cleanest structure and the one that creates the clearest incentive alignment — each agent is financially accountable to the party they're representing.

The friction arises when that clean structure breaks down — when the seller's commission covers both sides and the listing agency is expected to pay the buyer's agent out of the commission it receives. At that point, the buyer's agent is dependent on the listing agency's goodwill and speed. If the listing agency's internal processes are slow, if there is a dispute about what was agreed, or if the deal was done without a signed Form I, that payment can take weeks, quarters, or never arrive at all.

All commissions are subject to 5% Value Added Tax (VAT) under UAE law. The brokerage must be VAT-registered and provide a valid tax invoice. In a co-brokered deal where one agency is paying another, both agencies need proper VAT invoices in place. A payment made between agencies without correct VAT documentation creates a compliance problem for both — and yet agents routinely omit this step because they are focused on the deal, not the paperwork that follows it. The split invoice is not optional. It is part of the complete transaction record.

## Off-plan co-broking: a different payment structure

Off-plan transactions work on a fundamentally different commission flow. The buyer does not pay the broker's commission — the developer does, out of the project's sales margin. In Dubai off-plan, the developer pays the broker's commission, not the buyer. The price the buyer pays for a unit is the developer's list price whether they come through a broker or walk into the sales office directly.

This changes the co-broking dynamic significantly. The developer's NOC authorises specific brokers to sell a project's units, and the developer's commission schedule sets what gets paid and when. A buyer's agent co-broking on an off-plan unit is usually working under a referring agency arrangement with an authorised broker, and the split is agreed between the agencies — again, in writing, before the client registers.

The Dubai Land Department and RERA require the use of regulated escrow accounts for off-plan property transactions to protect buyers and maintain transparency. The escrow law — Law No. 8 of 2007 — means that buyer instalments go into a project-specific, RERA-regulated escrow account held by an approved trustee bank. The funds are released to the developer only after verified construction milestones are achieved, ensuring the buyer's money is used strictly for project completion. Broker commissions are paid by the developer outside this structure — typically in tranches aligned with the buyer's payment milestones.

The practical consequence for co-brokering: the referring agency's commission can be delayed for months, because the developer's payment is itself linked to milestones. A buyer's agent who has referred a client to an authorised broker on an off-plan project needs written confirmation of the split — the percentage, the payment trigger, and the timeline — before the client registers. A verbal arrangement on an off-plan referral is even harder to enforce than a verbal arrangement on a secondary deal, because the money is coming from a third party on a schedule neither agency controls.

## Rentals: co-broking, Ejari, and the cheque

Co-broking on rentals follows the same Form I logic, but the payment mechanics are different. Commission is due when the Ejari-registered tenancy contract is signed and the security deposit and first cheque are handed over. Ejari registration is not optional — a tenancy contract without Ejari has no legal standing in Dubai, and it is the registration that provides the documentary anchor if a commission dispute needs to go to the Rental Disputes Settlement Centre.

When two agencies share a rental deal, the timing pressure is acute. The tenant typically hands over multiple post-dated cheques at signing. The landlord's agent collects the security deposit and cheque payment at that point, and the co-brokering buyer's agent needs their share to move at the same time. If it does not — if it is left as a "we'll sort it after" — the follow-up becomes the friction. The listing agency has its money. The buyer's agency is chasing.

The 5% commission rate is not written into Dubai's tenancy law; it is the figure RERA recognises as customary and the one referenced when a commission dispute reaches the Rental Disputes Centre. Disputes that reach the RDSC (also known as the Rental Disputes Settlement Centre) require documentary evidence — filing through the RDC requires Ejari, the tenancy contract, identity copies, and proof of correspondence. An agent pursuing a co-broking split dispute at the RDSC will need a signed Form I and a paper trail showing exactly what was agreed. Without those, the hearing is difficult.

## The BRN and ORN checks that protect both sides

One licensing check that gets skipped in the urgency of a shared deal: verifying that the counterpart agency and agent are genuinely licensed and active.

After passing the RERA exam, the broker registers under a licensed firm and receives a BRN. This number appears on all marketing materials, business cards, and listing advertisements. An agency's ORN and an individual agent's BRN are both publicly searchable through the DLD's broker registry. Before signing a Form I and proceeding with a co-brokered deal, both agencies should confirm — not assume — that the other is currently registered. 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. A lapsed licence on either side is not just a compliance problem — it is a problem for the enforceability of any agreement signed.

The reason this matters beyond technicality: only an agent holding an active RERA broker card, working under a brokerage with a valid Dubai trade licence, can lawfully collect commission. Unlicensed brokerage is a violation; reported penalties commonly start at AED 50,000 and RERA can suspend or revoke a licence. Engaging with an unlicensed counterpart agent puts your own agency's licence position in a complicated place. It also renders the Form I you signed with them significantly weaker if the matter ends up in dispute.

## Where disputes actually start

Most co-broking commission disputes in Dubai do not start at a complex point. They start at the same point, every time: the split was discussed but not signed before the client moved.

The sequence is familiar. Agent A has the listing. Agent B calls with a buyer. Agent A says "sure, we split 50/50" — on the phone, via WhatsApp, in voice note. Agent B shows the property. The buyer likes it. The price is agreed quickly. Everyone is focused on the MOU. Form I is not raised because both agents are confident the deal is solid and they trust each other. The Form F gets signed. The client pays. And then the split conversation — which should have been documented two weeks earlier — is now happening under completely different circumstances, with one agency in possession of the full fee and the other trying to enforce an unwritten agreement.

Skipping or incorrectly completing a RERA form does not just create inconvenience. It can result in a transaction being rejected by the Dubai Land Department, a commission dispute with no legal basis for resolution, or a regulatory complaint against the agent or brokerage involved.

The other friction point is the structure of payment when one agency receives a single commission and is expected to pay the other out of it. The gap between when the listing agency collects and when it pays the buyer's agency — even in perfectly good-faith arrangements — is a source of tension. Accounts departments have processes. Invoices need approvals. VAT documents need to be correct. What both agents assumed would take three days takes three weeks. By week two, the relationship is strained.

## The principle that removes the friction

There is a clean version of every co-brokered deal, and its structure is not complicated. Every element that protects both agencies is agreed and signed before the client pays. The split percentage is on a signed Form I. Both agents' BRNs are confirmed active. Both agencies' VAT invoices are prepared and exchanged. The payment trigger — whether it is the Form F signing or the transfer — is explicitly agreed. And wherever the structure of the deal allows it, both agencies are paid at the same moment the client's money moves, rather than one agency collecting and then paying the other from what it holds.

That last element — simultaneous payment from the commission source, rather than one agency collecting and disbursing to the other — is where the real protection lies. When the buyer's agency and the listing agency are paid at the same moment from the same transaction, there is no waiting, no chasing, and no period during which one party holds the other's money. The dispute that starts because "the other agency still hasn't paid me" cannot happen if the other agency was never holding the money in the first place.

The licensing framework — Trakheesi, Form A, Form I, Form F, the BRN, the ORN, the VAT invoice — is the structure Dubai has built to make co-brokered transactions transparent and enforceable. None of it works without one thing: agents using it completely, in the right sequence, before the deal closes rather than after the commission has landed. The form that gets skipped because the deal moved fast is always the form that is missing when the dispute starts.

Sign the split before the client signs anything. Confirm the licences before the deal moves. Issue the VAT invoice before the cheque clears. Get paid at the same time the other side gets paid. That is not an advanced strategy. It is what the framework was designed to support — and it is what every clean co-brokered deal in Dubai actually looks like.