---
title: "What recent RERA reforms mean for shared deals"
description: "How tighter RERA and DLD rules on licensing, forms, and enforcement are changing who gets paid, how, and when in a co-brokered Dubai deal."
category: "dubai-market"
readingTime: 12
---
## The deal everyone remembers losing sleep over

Picture a secondary market villa in Arabian Ranches. The listing sits with Agency A under a Form A. No exclusive mandate — a seller who wanted maximum exposure signed with two other brokerages as well. A buyer's agent from Agency B brings the offer. Both sides spend three weeks negotiating price, NOC conditions, and a 10% deposit structure. Form F gets signed. Everybody is smiling.

Then the cheque clears into Agency A's account and the smile fades on Agency B's end. There is a WhatsApp exchange about what the split was supposed to be. Agency A remembers 60/40. Agency B remembers 50/50. Nothing was signed between the two agencies before the MOU went to the client. Now the deal is registered at the DLD Trustee office, the buyer has the title deed, and the two agencies are arguing about AED 30,000 while the Trakheesi system has no record of any agreed split.

This situation is not unusual. It has been common enough, for long enough, that RERA's recent wave of reforms is — in part — a direct response to it.

## What has actually changed, and why it matters for shared deals

Dubai's real estate regulatory framework continues to evolve, with digital transformation playing a significant role in 2025–2026. To understand what the reforms mean for co-brokered transactions specifically, it helps to separate the changes into three layers: who can legally be in a deal, what documentation is mandatory before the deal moves forward, and how disputes are handled when things go wrong.

### Layer one: the licensing bar is higher now

The DLD recorded more than 180,000 property transactions in 2024 as the off-plan boom drove a surge in broker registrations. Now RERA is tightening licensing standards — and raising what it takes to qualify. The practical consequence for any shared deal is blunt: the other agent in the room must be fully licensed, or the commission framework the deal rests on is legally exposed from the start.

The licensing framework exists — and RERA has progressively strengthened enforcement — but the pace of market influx created pressure on quality-assurance mechanisms. JLL MENA's 2024 market intelligence flagged the proliferation of informal brokerage networks and unlicensed intermediaries in Dubai's off-plan market as an ongoing concern, noting that the complexity of project launches creates opacity for buyers and accountability gaps across the market.

This matters directly to anyone co-broking. Only an agent holding an active RERA broker card, working under a brokerage with a valid Dubai trade license, can lawfully collect commission, and the listing must carry a valid Trakheesi permit. If the agent you are splitting with turns out to be unlicensed — or working as a freelancer under someone else's card — your signed agreement with them may be unenforceable. Worse, you may face regulatory scrutiny for having facilitated the arrangement. The first check in any shared deal is now non-negotiable: verify the other agent's BRN and the brokerage's ORN before Form I is signed, not after.

Trakheesi enforcement is increasingly automated. The integration between RERA's permit system and major property portals means that listings without valid permit numbers are flagged or removed faster than before. This flow-on effect is significant for shared listings: if the listing agent's Form A is not in the system cleanly before a co-broker brings a buyer, the entire transaction timeline can be disrupted.

### Layer two: the documentation sequence is now treated as non-negotiable

Every form that RERA mandates is legally binding the moment it is signed. This means the terms, obligations, and commission agreements written into these documents are enforceable under Dubai law. An agent cannot fall back on verbal agreements or informal understandings once a deal is underway.

That sentence alone explains most of the commission disputes that end up in front of the RDSC or at the DLD's mediation service.

The form sequence in a secondary market shared deal runs like this:

- **Form A** — the listing agreement between the seller and the listing agent, specifying the commission rate and whether the property can be co-brokered
- **Form B** — the buyer representation agreement between the buyer and the buyer's agent, establishing who the buyer is working with and on what terms
- **Form I** — the inter-agency agreement between the listing agent and the buyer's agent, which specifies the split and defines each agent's role in the transaction
- **Form F** — the Memorandum of Understanding that commits buyer and seller to the agreed price and terms, and references commission arrangements for both agents

Before the buyer's agent can arrange viewings, share the property's details, or participate in negotiations, both agents must sign Form I. A complete Form F includes the agent commission details.

Form I clearly defines how the total commission will be divided between the listing agent and the buyer's agent, ensures both agents adhere to RERA's code of ethics while collaborating, specifies which agent is responsible for particular tasks such as coordinating with the developer or attending the final transfer at the Trustee office, and legally binds both agents to cooperate in the best interest of their clients, preventing potential "poaching" of clients or disputes over fees.

The reforms make the sequencing more critical because enforcement is now tighter at every step. Agents need to ensure Form A is submitted and approved before a listing goes live, not after. And by the same logic: Form I must be signed before viewings begin, not after the buyer has made an offer and the split suddenly needs to be formalised under pressure.

### Layer three: how RERA handles it when the split goes wrong

RERA has provided a service to assist real estate brokers in resolving disputes relating to contract (F). Should the contracting parties reach an agreement by submitting the application through the Trakheesi system, the concerned department will hold a meeting to discuss the breach and try to reach an amicable settlement. In the event that an amicable solution is not reached between the parties, the parties must resort to the judicial authorities to settle the dispute.

That last sentence is the one that costs agents months and tens of thousands of dirhams. RERA's mediation role is constructive, but it is not a binding adjudicator for inter-agency commercial disputes. Once amicable settlement fails, the matter moves to the courts — and at that point, what matters is what was written down and when.

If a commission dispute arises, RERA's Rental Disputes Settlement Centre handles the case. Having a written agreement is essential to win any dispute. An agent walking into that hearing with a signed Form I, a signed Form F referencing the split, and a clear paper trail through Trakheesi is in a fundamentally different position from an agent with screenshots of a WhatsApp conversation and a memory of what was agreed on the phone.

## The off-plan dimension: where shared deals get genuinely complicated

In 2025, 69% of residential properties sold in the real estate market were off-plan. At that volume, the majority of shared deals in Dubai right now are not secondary market re-sales — they are developer units being co-brokered between a primary market agency and a buyer's agent.

The off-plan context changes several things at once.

First, the commission flow is different. Developer commission is typically paid by the developer, not the buyer, and it is released in tranches tied to construction milestones. This means the buyer's agent who sourced the client may wait for payment not just until the deal is closed, but until payment milestones hit on a project that might complete in 2027 or 2028. Developers launching off-plan projects must register the project with DLD and open a project-specific escrow account. Buyer payments are deposited into this account and can only be used for the construction of that specific development. This prevents misuse of funds and protects investor capital. That is the regulated escrow mechanism operating as intended — protecting the buyer. But it tells you nothing about when the referring agent sees their share of the developer's brokerage commission, which sits entirely outside that account and is governed only by what was agreed between the agencies.

Second, RERA caps the referral share at 30% of the brokerage commission. Anything higher requires a separate tri-party agreement between the two brokerages and the client, filed with the Dubai Land Department within 48 hours of signing. Most agents working co-brokered off-plan deals operate on a 70/30 split when one agent supplies the buyer and another holds the developer relationship. But working above that 30% cap — as happens often when a buyer's agent is particularly well-positioned or the deal is a large-volume transaction — requires a tri-party agreement that is explicitly filed with the DLD. Agents who skip that step are not just risking a future dispute; they are operating outside the documented framework that RERA expects.

Third, and most practically: who pays whom, and when, in an off-plan shared deal, is almost entirely determined by whatever the two agencies agreed in writing before the booking was made. A developer's SPA does not settle an inter-agency split. The developer pays whichever brokerage is registered on the deal. What happens to that money after it lands in that brokerage's account is a function of the agency agreement, not regulation.

## Where the payment actually stalls

The honest account of why agents wait for their split — and sometimes never receive it — comes down to four recurring points of failure.

**The split was agreed verbally.** In a market moving as fast as Dubai's, it is easy to take a referral call, shake hands on 50/50, and get on with bringing the buyer. Nobody wants to slow the momentum. But a verbal agreement has no standing in a Trakheesi-based enforcement environment. Commission becomes legally payable only once a signed representation is in place and the transaction the agent was engaged to complete actually goes ahead. In Dubai, the form — not a viewing or a phone call — is what establishes the agent's entitlement to a fee.

**Form I was signed after Form F.** This happens more than it should. The buyer's agent shows the property, the buyer makes an offer, Form F gets drafted in a hurry — and then someone remembers Form I hasn't been signed yet. By that point, the listing agent has leverage. The buyer is committed. The split negotiation is now asymmetric.

**The VAT position is unclear.** All commissions are subject to 5% VAT under UAE law. In a shared deal, both agencies need to have issued their respective VAT-compliant invoices before payment can be processed correctly. If one agency is VAT-registered and the other is not — or if VAT was not addressed in the Form I — there is a gap in what can actually be invoiced and paid cleanly. This is not a minor administrative detail; it is a reason that payments sit pending for weeks.

**The paying agency treats the split as a second priority.** Once the client's commission has landed in the listing agency's account, the operational pressure to pay the co-broker diminishes. The co-broker has no standing in the client's transaction — the client dealt with the listing agency. Without a form that creates a legally documented obligation and a clear payment timeline, the co-broker's position is that of an unsecured creditor chasing a favour.

## What RERA's reforms are actually telling agents to do differently

Strip away the regulatory language and the direction is clear. RERA's response has included enhanced monitoring of broker conduct complaints, periodic enforcement actions against unlicensed operators, and a sustained push to raise standards. The practical signal to agents working shared deals is that the regulator expects documentation to precede every step, not follow it.

Brokerage fees must be agreed upon in writing and included in contracts for transactions. That has always been the rule. What is different now is the tightening of the system around it: Trakheesi integration is more automated, portal compliance is enforced in near-real-time, and new rules require agents to renew their licenses more frequently and complete ongoing training to stay updated on current laws.

The cumulative effect is that every licensed agent working in this market in 2026 has less room to operate on informal agreements. The system is designed to make documentation the path of least resistance — not because RERA is hostile to agents, but because documentation is what makes every agent's claim enforceable.

Every property sale, rental, or sub-agency agreement in Dubai must be backed by an official RERA form — a document that defines responsibilities, commissions, and legal obligations for all parties involved. The reforms have not created new obligations so much as they have removed the operational slack that allowed agents to treat those obligations as optional.

### For rental transactions

The shared deal problem is not confined to sales. In rental transactions, Ejari is the equivalent checkpoint. RERA requires all tenancy contracts to be registered through the Ejari system. This registration ensures the agreement is enforceable and protects both parties in the event of a dispute. When two agents share a rental deal — one finding the landlord, one finding the tenant — the commission split between them is governed by whatever was agreed in writing before the tenancy agreement was signed. Post-dated cheques are still the dominant payment method for annual rent in Dubai; the agent who waits to sort the split until the cheques have been issued to the landlord is already negotiating from a weak position.

## The three-broker rule and what it does to split dynamics

The three-broker rule, established by DLD in October 2022, states that a property cannot be listed with more than three brokers at a time. The purpose is to reduce the number of listings so that clients looking for properties can have a better experience.

For shared deals, this rule has a specific consequence that is sometimes overlooked. A seller working with three agencies simultaneously has signed Form A three times. Each of those agencies believes it has a claim to commission if it brings the buyer. The moment a buyer's agent from a fourth brokerage enters the picture, the listing agency's ability to co-broke is constrained — they need to route the buyer through one of the existing Form A holders, or handle it themselves.

More practically: the three-broker cap means that agents who co-broke with a listing agency need to understand that the listing agency's Form A defines the terms of what can be shared. Under RERA regulations, a seller can sign Form A with a maximum of three brokers at any given time. This prevents the market from being flooded with duplicate listings and ensures quality control. The co-brokering agent who does not verify the listing agency's Form A before agreeing to work together cannot know whether the commission clause in that Form A allows for a split that matches what was verbally promised.

## The principle that removes the friction

Every friction point described above — the disputed split, the withheld payment, the VAT gap, the delayed co-broker — has the same root cause. The split was not fully agreed, signed, and reflected in every relevant document before the client paid.

Not mostly agreed. Not agreed in principle. Agreed, signed, and documented in a way that creates a parallel obligation to pay the co-broker at the same moment the listing agency receives the client's commission.

When both agents have signed Form I with a precise split percentage, both have issued VAT-compliant invoices reflecting their respective shares, and the mechanism for releasing each share is agreed before the client hands over a single dirham, the dispute has nowhere to start. The listing agency cannot reasonably withhold the co-broker's share because that share is documented. The timing is clear. The amount is clear. The VAT position is clear.

The closer a shared deal's payment structure resembles a simultaneous, pre-documented disbursement — rather than a sequential process where Agent A gets paid first and then decides when and how much Agent B receives — the less room there is for the payment to stall, the relationship to sour, or a complaint to be filed.

RERA's reforms are pushing the market in exactly that direction. Digital forms, automated permit verification, tighter licensing enforcement, and mandatory pre-deal documentation are all steps toward a market where the commission agreement exists before the client commitment, not after. The agents who read those reforms correctly and restructure their co-broking practice accordingly will spend less time chasing and more time closing.

The principle is simple: agree the split, sign it, and arrange to be paid at the same time as everyone else. Everything else in the reformed framework is designed to make that the normal way a Dubai shared deal works.