Repairing a building in Dubai: three tiers of works and when a permit is needed — Resolution 109/2022

Verified against official sources on 2026-09-16: the text of Administrative Resolution No. 109 of 2022 comes from the Dubai Legislation Portal (dlp.dubai.gov.ae), the copyright line naming the Supreme Legislation Committee of the Emirate. The portal notes that the English version is a translation and that the Arabic text prevails in case of conflict. This is neither engineering nor legal advice: a specific building is judged on its own documents and inspection.

"Do I need a permit to repair a flat or a façade?" is a question with a written answer in Dubai, and the answer is not organised by the size of the budget. The Municipality splits maintenance into three tiers according to what is being repaired, and each tier has its own procedure.

The document is Administrative Resolution No. (109) of 2022 Regulating the Licensing of Maintenance Works, issued by the Director General of Dubai Municipality on 20 April 2022 (19 Ramadan 1443 A.H.) and coming into force on the day of publication in the Official Gazette (Article 7). The preamble names Decree No. 45 of 2021 on the Dubai Building Code, the 1961 Order establishing the Municipality, Local Order No. 3 of 1999 on construction works and its amendments, Executive Council Resolution No. 15 of 2021 on the Municipality's organisational structure, and Administrative Resolution No. 10 of 2019 on replacing engineering firms and contracting companies and issuing completion certificates.

Three tiers and the line between them

The definitions are in Article 1, the procedures in Articles 2–4:

Tier of works	What it covers (lists are open-ended)	Permit and completion certificate
Basic	repair of non-structural defects: interior and exterior painting; replacement of floors, doors and suspended ceilings; maintenance of electrical works, sewerage and sanitary installations, air conditioners, fire-fighting systems, sanitary pipe insulation	neither a Municipality permit nor a completion certificate is required
Structural	repair of structural defects that may compromise durability but not structural safety: cracks in the elements of the main structure, defects in external façades	permit and completion certificate are self-issued through the building permit system
Specialised	repair of defects that may compromise structural safety: subsidence and cracks in ceilings, beams, columns; fall of concrete cladding; substantial rust in reinforcing steel; modification of main structural elements, including reinforcement, buttressing and adding new elements	the permit is issued through the system, the completion certificate subject to the Municipality's approval of the works

Note how the line is drawn: between the second and third tier stands not the size of the crack but what it puts at risk — the durability of the building or its structural safety. That question is answered by an engineer, not by the owner.

Basic tier: no permit, but six requirements

The absence of a permit does not mean the absence of rules. Article 2 lists what is mandatory even in ordinary repairs:

1. the works are carried out by a contractor pre-qualified by the Municipality;
2. architectural or structural alterations that may compromise the safety of the building or any of its façades may not be made;
3. the planning and construction legislation applied by the Municipality, with all its specifications and conditions, is complied with;
4. public safety conditions and requirements commensurate with the volume of works are complied with;
5. the requirements of the Directorate General of Civil Defence and of other authorities are complied with where their legislation so requires;
6. when painting external façades, colours that blend in with the surroundings and adjacent buildings are used, as authorised by the Municipality.

The first and the sixth are the ones owners learn about last. Even painting a wall on the outside is not an entirely private matter.

Structural tier: the permit is self-issued, but it takes evidence

Article 3 requires four things for the permit: the application is filed by a consulting engineer or contractor pre-qualified by the Municipality through the building permit system; photographs of all structural defects with their locations specified are attached; a proposed repair process with information about the materials is submitted; the prescribed fee is paid. On completion, the certificate is self-issued through the same system.

During implementation the same prohibitions and requirements apply as in the basic tier: no alterations compromising the safety of the building, compliance with construction legislation, public safety and civil defence requirements.

Specialised tier: the laboratory comes before the repair

Here the procedure is markedly stricter (Article 4):

• the application is filed by a pre-qualified consulting engineer or contractor through the system;
• the drawings of the works are submitted to the Municipality for approval;
• photographs of all defects with their locations are attached;
• before the works begin, the necessary laboratory tests of the concrete and reinforcing steel of the main structural elements are carried out;
• a repair process approved by the consulting engineer and based on the test results is submitted, with all necessary structural information and calculations and the specifications of the materials — to ensure the structural integrity and durability of the building throughout its lifetime;
• the prescribed fee is paid;
• the works are implemented by a pre-qualified contractor;
• the completion certificate is issued through the system subject to the Municipality's approval of the works.

And the key provision for an owner is Article 4(d):

"…the consulting Engineer and the Contractor appointed to implement the Specialised Maintenance Works will be jointly liable for the authenticity of all the information provided to the DM, and for ensuring the safety of the implemented Specialised Maintenance Works and their conformity with the plans and specifications submitted to the DM." — Administrative Resolution No. (109) of 2022, Article 4(d)

For the most dangerous tier the law does not leave liability with a single performer: both answer, and not only for the result but for the authenticity of the information on which the permit was issued.

Who checks

Article 5: control and audit of maintenance works in the Emirate is carried out by the Engineering and Planning Sector of the Municipality — verifying that appointed contractors comply with the technical specifications, requirements and procedures of the planning and construction legislation and of this resolution, and taking action against violators. Implementing instructions are issued by the Executive Director of that Sector (Article 6).

How an owner or buyer should read this

Three practical consequences.

First. If a building shows cracks in columns or beams, cladding is falling off, or reinforcing steel is visibly and substantially rusted, that is not cosmetic repair under the Municipality's classification but the third tier, with laboratory tests and approved drawings. An offer to "have a contractor patch it in a week" runs against the procedure.

Second. Even basic repair must be carried out by a pre-qualified contractor — a criterion a buyer or tenant can ask the management company about.

Third. Structural defects in a new building are a separate story: there the ten-year liability of the developer applies, and the requirements for the construction itself come from the Building Code and the law on the quality and safety of buildings. Resolution 109/2022 answers a different question: in what order to repair, not who is to blame.

What we do NOT claim here

• Fee amounts. The resolution says "the prescribed fee" and contains no sums; we have not read the tariff instruments and quote no figures.
• Which tier a specific defect belongs to. The line is drawn by the threat to durability or to structural safety — an engineering assessment, not a conclusion from an article.
• The list of pre-qualified contractors or the pre-qualification procedure. The resolution does not contain them; the register is kept by the Municipality.
• The content of the implementing instructions. They are issued by the Executive Director of the Engineering and Planning Sector (Article 6); we have not seen their texts.
• The content of Local Order No. 3 of 1999 on construction works. Permits and completion certificates are issued under its requirements and procedures; we have not read its text.
• Additional approvals inside a jointly owned building. Whether an owners association or committee must consent to works on common elements is a question for the jointly owned property rules, not for this resolution.
• The calendar date of commencement. The resolution takes effect on the day of publication; we did not verify that date. The date of issue is 20 April 2022.

Sources

• Administrative Resolution No. (109) of 2022 Regulating the Licensing of Maintenance Works — Dubai Legislation Portal: issue by the Director General of Dubai Municipality on 20 April 2022, corresponding to 19 Ramadan 1443 A.H., and commencement on the day of publication (Article 7); the preamble naming Decree No. 45 of 2021 on the Dubai Building Code, the 1961 Order establishing the Municipality, Local Order No. 3 of 1999 on construction works, Executive Council Resolution No. 15 of 2021 and Administrative Resolution No. 10 of 2019; definitions of a building, of maintenance works and of their three kinds — basic (a list of non-structural works, no permit and no completion certificate), structural (a threat to durability, self-issued permit and certificate) and specialised (a threat to structural safety) — and of the permit, the completion certificate and the Dubai Building Permit System (Article 1); six requirements for basic works, including a pre-qualified contractor, the ban on alterations compromising the safety of the building and its façades, civil defence requirements and authorised colours for external painting (Article 2); four conditions for a structural works permit — application by a pre-qualified consulting engineer or contractor through the system, photographs of defects with locations, a proposed repair process with materials information, payment of the fee — the self-issued completion certificate and the requirements during implementation (Article 3); the conditions for specialised works — approval of drawings by the Municipality, photographs of defects, laboratory tests of concrete and reinforcing steel before the works, an engineer-approved process based on the test results with calculations and material specifications, payment of the fee, implementation by a pre-qualified contractor, a completion certificate subject to the Municipality's approval, and joint liability of the consulting engineer and the contractor for the authenticity of the information and the safety of the works (Article 4); control and audit by the Engineering and Planning Sector and action against violators (Article 5); implementing instructions issued by the Executive Director of that Sector (Article 6).