What a developer may do with your project's escrow account: the 5% they cannot take without someone else's consent

Checked against the official sources on 17 September 2026: the Dubai Land Department service cards "Withdrawal of Project Profits", "Depositing a mortgage into an escrow account application", "Escrow Account Transfer" and "Request for approval for issuing no objection letter to close the project escrow account". All pages were read in their raw form; every figure carries its source link, and the sources are listed at the end.

What an escrow account is and where its protection ends we covered separately. That piece was about the principle. This one is about which operations a developer may actually perform on the account, because each has its own service card, and those cards carry conditions no summary mentions.

All four services are addressed to the developer: applicant status is companies, the channel is the Oqood portal and the trust account system, none carries a fee, and each takes three business days. They are worth reading as a buyer: the conditions describe what protects your money while the building is unfinished.

Taking the profit: the 5% that stays regardless

The description: "This service allows a real estate developer to apply for withdrawal of surplus amounts available in the real estate project's escrow account." — an application to withdraw surplus from the project's account.

The card splits the case in two — a project under construction and a completed one — and both variants carry the same line:

"Ensure that an amount equivalent to 5% of the net collections is available in the project completion escrow account. This amount may not be released unless a No Objection Certificate (NOC) is obtained from the Jointly Owned Property Management."

Five per cent of net collections must sit in the project completion escrow account, and it cannot be released without the consent of Jointly Owned Property Management. That is not a fee or a tax — it is a retention that outlives construction itself and is unlocked by another party's signature. The keyholder is the same management that later approves your building's service charges.

The remaining conditions for a project under construction:

• the project status must be active;
• compliance with the project's financial risk and solvency standards before applying;
• a recent Department technical report — not older than three months — with no red flags in the final stages;
• the balance in the main escrow account must cover the remaining construction costs;
• a declaration by the developer to continue building without interruption regardless of collections, within a timeline approved by the project consultant, with a commitment to cover additional financial claims.

For a completed project the list is shorter but stricter in substance: a Department technical report confirming 100% completion, the same 5%, and closing the escrow account or transferring it to the company's account with the title (Oqood) system updated accordingly.

Read the penultimate point again, because it answers the question "can the developer pull the money and walk away": a surplus may be withdrawn only if what remains covers the cost of finishing. How the completion percentage underpinning all of this is calculated is covered here.

There are only two documents: the developer's declaration and undertaking to cover all project expenses, and a no-objection letter from the mortgaging bank, if there is one.

Putting a bank loan into escrow: the bank undertakes not to block your registration

The description: the service lets a developer apply to deposit a mortgage over units or land plots into the escrow account in order to complete the project.

The most important thing on this card is the second required document, and it protects the buyer rather than the bank:

"An undertaking by the financing bank to deposit the loan amount to the escrow account and not to demand to impose limitations on mortgage or otherwise, and to allow the units sold to be registered at the real estate registry in the names of the investors."

The bank undertakes to deposit the loan into escrow, not to demand limitations on the mortgage, and to allow sold units to be registered in the investors' names. By the terms of the service, the developer's loan must not become an obstacle to registering your ownership.

The first document is the financing agreement itself. The conditions split into a funds deposit and a settlement or financing instalment; both require a Department technical report and the absence of a red flag, a declaration to keep building regardless of collections, and an undertaking to cover other claims, including payments due to project consultants. The settlement variant repeats outright both the 5% in the completion account and the requirement that the main account's balance cover the cost of finishing.

Here the Department contradicts itself on the report's age, and we are not smoothing it over. The profit-withdrawal and account-transfer cards say "not older than three months"; this one says "not exceeding 4 months old" — four. Both wordings are quoted as printed; which one governs a disputed case neither card explains.

Moving the account to another trustee: you must be notified

The description: the service lets a developer move the project's escrow account from one Account Trustee to another. There are nine conditions, and the fourth is about you directly:

"4- Developer’s commitment to notify all unit owners of the new escrow account number."

The developer's commitment to notify ALL unit owners of the new escrow account number. The practical point is obvious: paying to the old details after a transfer is a risk, and the notice the developer is bound to give is what removes it.

Three more of the nine conditions are worth knowing:

• the transfer is permitted only for the purpose of directly financing the project — with written financing approval from the new escrow agent;
• a no-objection letter from the previous trustee, committing to keep the old account open for no less than 3 months and no more than 1 year and to immediately transfer to the new account any deposits collected after the transfer;
• a no-objection letter from the new trustee, committing not to activate the account until all documents are received from the previous trustee — within 3 working days and subject to the authority's approval.

Plus: active project status, a technical report no older than three months with no red flags, the previous trustee uploading all financial data into the system, and — as a separate item — a financial report for the project if the request is filed in the first quarter of the year.

Three documents: written financing approval from the new trustee and two no-objection letters, from the previous and the new trustee.

Closing the project account: a card whose name diverges from its description

The fourth service is named "Request for approval for issuing no objection letter to close the project escrow account", but its description says something else:

"This service allows customers to submit an application to obtain approval for the recovery of the project guarantee amount."

The description is about recovering the project guarantee amount, not about closing an account. We quote both formulations as printed and do not decide for the Department which describes the service more accurately. What that guarantee is, is covered here.

There are two conditions, and both are phrased unusually bluntly:

• the developer must not have any outstanding financial obligations towards the project;
• the developer should refrain from making unfounded promises regarding service fees.

The second is a rare case of a regulator writing a ban on a marketing promise into a service's conditions. Two documents: a no-objection letter from the management company and a certificate confirming completion of the project. The channel is unusual: the official email of the Jointly Owned Property department rather than a portal. Three business days; partners — banks.

Do not confuse them: jointly owned property has its own account and its own system

Two more services in the catalogue carry the word "escrow", and they are not about the project but about your building's account in the Mollak system: transferring the jointly owned property account from one bank to another (one business day, via Mollak, requiring the regulator's approval before the old account is closed and the balance transferred together with the approved budget and expenditure records) and accrediting authorised signatories (one business day, requiring the company director or the financial director to be present in person, with the company licence as the only document).

That is a different surface: there it is residents' money for running the building, here it is buyers' money for construction. The jointly owned property account deserves an article of its own; here we only separate two accounts that the word "escrow" makes easy to confuse.

What an off-plan buyer should take from this

• 5% of net collections stays in the project completion account, and only the consent of Jointly Owned Property Management unlocks it — not the developer alone.
• A surplus may be withdrawn only if what remains covers the cost of finishing — that is a condition of filing, not a wish.
• By the terms of the service, the developer's loan must not obstruct registering units in investors' names — the bank gives that undertaking in writing.
• You must be notified when the escrow account moves, and the old account is kept open for between three months and a year.
• The technical report underpins the whole structure, and the Department states its shelf life two ways: three months on three cards, four on one.

What we are not claiming here

• What happens if these conditions are breached. The cards state conditions of filing, not sanctions.
• How to verify the 5% is observed. The requirement is stated; the cards offer no public way to see the account balance.
• Who notifies the owners, and how. The obligation is stated; the form and channel of the notice are not.
• Which report age is correct — three months or four. Both wordings are quoted; the source offers no clarification.
• What happens to the 5% if Jointly Owned Property Management withholds consent. The card does not describe that case.
• What banks and account trustees charge. The Department's services are free; third parties' tariffs are not the cards' subject.

Sources

• Withdrawal of Project Profits — Dubai Land Department service card: withdrawal of surplus from the project account, free of charge, 3 business days, status — companies, two sets of conditions (project under construction and completed) including the mandatory 5% of net collections in the completion account released only on an NOC from Jointly Owned Property Management, a technical report no older than three months with no red flags, the balance covering the remaining construction cost, a declaration to keep building regardless of collections, and for a completed project a report confirming 100% completion plus closing or transferring the account with the Oqood system updated; two documents; channel — the developers' portal and the trust account system.
• Depositing a mortgage into an escrow account application — service card: depositing a loan over units or land plots into escrow, conditions for deposit and for settlement, a technical report "not exceeding 4 months old", the 5% in the completion account and the balance covering the remaining cost in the settlement variant, two documents — the financing contract and the bank's undertaking to deposit the loan into escrow, not to demand limitations on the mortgage and to allow sold units to be registered in the investors' names; 3 business days, status — companies.
• Escrow Account Transfer — service card: moving the project account from one account trustee to another, free of charge, 3 business days, status — companies, nine conditions including the commitment to notify all unit owners of the new account number, transfer only for the purpose of directly financing the project, the previous trustee's NOC keeping the old account open for 3 months to 1 year and immediately transferring later deposits, the new trustee's NOC not to activate the account until documents are received within 3 working days, a technical report no older than three months, and a financial report if filed in the first quarter; three documents; channel — the developers' portal and the trust account system.
• Request for approval for issuing no objection letter to close the project escrow account — service card: the name refers to closing the project escrow account, the description to obtaining approval for recovery of the project guarantee amount; two conditions (no outstanding financial obligations towards the project, and refraining from unfounded promises regarding service fees), two documents (the management company's NOC and a project completion certificate), channel — the official email of the Jointly Owned Property department, 3 business days, status — companies, partners — banks.
• Request to obtain approval for transferring the escrow account from its current bank to another financial institution — jointly owned property service card: the regulator's approval before closing the old account, transfer of the balance together with the approved budget and expenditure records, updated details through Mollak; 1 business day, status — companies, partners — banks; no issued documents, data is viewed in Mollak.
• Request of approval to accredit authorized signatories on the escrow account — service card: accrediting authorised signatories, condition — the presence of the company director or the financial director, document — the company licence, 1 business day, status — companies, partners — banks.