Decree No. 22 of 2022 created a dedicated register of real estate investment funds at the Land Department and named the conditions for entry: a valid licence, real property assets of at least AED 180,000,000, no suspension of trading, and a registration fee of AED 10,000. A fund on the register may own beyond the restrictions that apply to non-nationals, and pays a reduced rate when it buys — 2% instead of the usual 4%; on the way out the rate is the ordinary one. Worked through the official text on the Dubai Legislation Portal.
Verified on 15 September 2026 against official sources: the text of Decree No. 22 of 2022 comes from the Dubai Legislation Portal (dlp.dubai.gov.ae). Source links sit next to every number and again at the end. This is not legal advice and not investment advice: whether it applies to a particular fund is for the Land Department to determine.
A private buyer in Dubai deals with two simple rules: you may own on listed plots, and a transfer costs 4%. Real estate investment funds have a separate regime, and it changes both rules at once.
The document is Decree No. (22) of 2022 Approving the Grant of Privileges to Real Estate Investment Funds in the Emirate of Dubai, issued on 7 July 2022.
A dedicated register at the Land Department
Article 4 creates a special register — the Real Estate Investment Funds Register, maintained by the Land Department. That is the key to everything else: the decree's privileges go not to "a fund" in general but to a fund entered on this register.
Four conditions for entry
Article 5(a) lists the requirements, and three of the four are externally checkable:
| Condition | Value under the decree | article |
|---|---|---|
| a valid licence from a competent authority | mandatory | 5(a) |
| real property assets | at least AED 180,000,000 | 5(a) |
| status on the financial markets | trading not suspended | 5(a) |
| registration fee | AED 10,000 | 5(a) |
The hundred-and-eighty-million-dirham threshold is the line between a retail investor and a subject of this regime. It is named in the decree itself, not inferred by us from practice.
First privilege: where the fund may own
Article 8 allows a fund on the register to acquire ownership and long-term rights over property beyond the restrictions applicable to non-UAE nationals, in areas designated for the purpose.
Compare the general rule: for a non-national individual, ownership is open on plots listed by number, in three forms — ownership without a time limit, usufruct, and a lease of up to 99 years. How that general rule works is covered in the article on Regulation No. 3 of 2006, and the forms of right themselves here.
Second privilege: half the fee on the way in
Article 10 sets the rates for the fund's transactions. The asymmetry is the point: a purchase by the fund costs half of what a sale by the fund costs.
| Transaction | Rate of market value | Who pays, under the decree | article |
|---|---|---|---|
| purchase of property by the fund | 2% | seller and purchaser in equal shares, unless otherwise agreed | 10 |
| sale of property owned by the fund | 4% | seller and purchaser in equal shares, unless otherwise agreed | 10 |
| registration of a usufruct or long-term lease by the fund | 2% | owner or landlord and tenant or holder in equal shares | 10 |
| assignment of a usufruct or long-term lease | 4% | the fund and the new tenant or holder in equal shares | 10 |
The phrase "unless otherwise agreed" appears on every line: the decree sets a default allocation, and the parties may agree otherwise. For comparison, what makes up the ordinary transfer fee for a private buyer is covered separately.
Third privilege: property can be contributed in kind
Article 13 permits property to be contributed to the fund's capital in kind, and sets a flat fee for each property transferred — AED 50,000, rather than a percentage of value. For a portfolio of expensive assets that is a fundamentally different arithmetic from a percentage rate; for cheap ones, the opposite.
How an investor should read this
- The regime is addressed, not sectoral. The privileges attach to a fund on the register, not to any company buying property.
- The entry threshold is a stated figure. AED 180,000,000 of real property assets is a condition of the register, not a market benchmark.
- A break on the way in, the ordinary rate on the way out. 2% on purchase and 4% on sale means the regime cheapens building a portfolio rather than flipping it.
- The split of the fee is a default, not a fact. "In equal shares unless otherwise agreed" is a negotiating point.
- An in-kind contribution is priced differently. A flat AED 50,000 per property only compares with a percentage once you put real numbers in.
What we are NOT claiming here
- That a registered fund may own anywhere. Article 8 speaks of designated areas and of going beyond the restrictions on non-nationals, not of an absence of territorial rules.
- Any tax consequences. The decree concerns Land Department fees, not taxes; VAT on property is a separate subject.
- A list of funds on the register. The register is maintained by the Land Department; we do not reproduce it.
- The application procedure or processing times. We do not quote those from the decree, because we worked only through the conditions and the rates.
- Any yield. There is not a single figure about returns in this article: it is about fees and admission conditions.
Sources
- Decree No. (22) of 2022 Approving the Grant of Privileges to Real Estate Investment Funds in the Emirate of Dubai — Dubai Legislation Portal: Article 4 (the Real Estate Investment Funds Register at the Land Department), Article 5(a) (four conditions for entry, including real property assets of at least AED 180,000,000 and a fee of AED 10,000), Article 8 (ownership beyond the restrictions on non-nationals in designated areas), Article 10 (rates of 2% and 4% and the equal-shares default unless otherwise agreed), Article 13 (in-kind contribution of property to capital, AED 50,000 per property). Issued 7 July 2022.
