The formula "including Special Development Zones and free zones, such as the DIFC" appears in the urban planning law, the waste law, the building codes and the public health law. What a Special Development Zone actually is, none of them says — the definition sits in a separate instrument, Decree No. 22 of 2009. The same decree introduces a term that matters to owners: Service Fees — charges payable by owners and tenants of real property for the zone's infrastructure and public utilities, the rules for which are issued in coordination with the Land Department and RERA.
Verified against official sources on 2026-09-16: the text of Decree No. 22 of 2009 comes from the Dubai Legislation Portal (dlp.dubai.gov.ae), credited to the Supreme Legislation Committee of the Emirate, 2015. The portal notes that the English version is a translation and that the Arabic text prevails in case of conflict. This is not legal advice: a specific property is judged on its own documents.
Reading primary sources back to back, one formula keeps recurring. The urban planning law, the waste law, the building code decree, the construction safety decree, the 2026 waste bylaw and the public health law all extend themselves to "Special Development Zones and free zones". None of them explains what a Special Development Zone is.
The definition lives in a separate instrument — Decree No. (22) of 2009 Concerning Special Development Zones in the Emirate of Dubai, issued on 31 May 2009; it is published in the Official Gazette and comes into force on the day of publication (Article 6). It has six articles in total.
The definition
"Special Development Zones: Land, compounds, and areas owned by the PCFZC or DW, owned by their affiliated entities and companies in the Emirate, located within their jurisdictions, or located within the areas determined by the PCFZC or determined by a legislation issued by the Ruler, including, without limitation, Nakheel, Limitless, Dubai Maritime City, Estithmar, and Dubai Multi Commodities Centre." — Decree No. (22) of 2009, Article 1
Note how the definition is built: it is not geographic but proprietary. A zone is defined not by coordinates but by who owns the land and whose jurisdiction reaches it. The examples are given "including, without limitation" and are stated as of 2009.
Three exclusive powers
Article 2 vests the Ports, Customs and Free Zone Corporation with exclusive responsibility in Special Development Zones for three things:
- supervising the regulation of all matters related to infrastructure and the provision of public utilities;
- issuing all types of licences in Special Development Zones;
- determining, estimating, imposing, charging and collecting service fees and other fees for public utilities and for those licences, and using the proceeds as it sees fit.
The second point meets something we covered separately: under the economic activities law 13/2011 a "business" is one licensed by the Department, excluding those licensed in free zones; and Resolution 11/2025 sets out how a zone company steps outside its zone to operate.
What "Service Fees" means in this decree
The term is worth knowing because it does not coincide with the jointly owned property service charge.
"Service Fees: Any fees or charges payable by the owners or tenants of real property, or payable by establishments located in Special Development Zones in return for the use, utilisation, or development of infrastructure and Public Utilities, or for any other services offered or provided in Special Development Zones." — Decree No. (22) of 2009, Article 1
Infrastructure here means land, property, structures and facilities in the zone owned by the Corporation or by Dubai World and available to owners and tenants: roads, bridges, beaches, parks, water bodies, breakwaters and ports. Public utilities means gas, water, power, sewage and wastewater treatment, central cooling and other ancillary services.
And the key procedural rule is Article 3:
"The PCFZC will issue the rules for determining and estimating Service Fees in Special Development Zones in coordination with the Land Department and the Real Estate Regulatory Agency." — Decree No. (22) of 2009, Article 3
So the Corporation writes the rules for calculating them, but in coordination with the DLD and RERA. How the service charge works under the jointly owned property regime is a separate structure under Law 6/2019, and the two should not be conflated: different sources of rules, different addressees.
Article 4 leaves regulations on infrastructure, licences and public utilities to the Corporation's Chairman; Article 5 repeals conflicting provisions of other instruments.
What we do NOT claim here
- Which areas are Special Development Zones today. The 2009 decree names examples "including, without limitation"; the definition is tied to ownership and jurisdiction, not to a map. The status of a given district must be checked against current legislation, not against this list.
- The present corporate structure of the named entities. The Ports, Customs and Free Zone Corporation, Dubai World and the listed companies are named as they appear in the 2009 text; we have not verified or described their position today.
- Service fee amounts or the method of calculating them. The decree contains neither: the rules are issued by the Corporation in coordination with the Land Department and the Agency. We have not read those rules and quote no amounts.
- How zone service fees relate to the jointly owned property service charge. We show that these are different concepts from different instruments; we will not assert what happens where they meet in a particular development.
- Whether the Mollak system applies in the zones. The decree does not touch the question and we have not read the relevant instruments on it.
- The contents of the instruments in the preamble — Law No. 1 of 2001, Law No. 4 of 2001 on free zones, Decree No. 19 of 2005 and Law No. 3 of 2006.
Sources
- Decree No. (22) of 2009 Concerning Special Development Zones in the Emirate of Dubai — Dubai Legislation Portal: issuance by the Ruler of Dubai on 31 May 2009 and entry into force on the day of publication (Article 6); preamble references to Law No. 1 of 2001, Law No. 4 of 2001 on free zones, Decree No. 19 of 2005 and Law No. 3 of 2006; definitions of Special Development Zones through ownership of land and jurisdiction with an open list of examples, of Service Fees as charges payable by owners and tenants of real property, of Infrastructure including roads, bridges, beaches, parks, water bodies, breakwaters and ports, and of Public Utilities including gas, water, power, sewage and central cooling (Article 1); the Corporation's exclusive responsibility for supervising infrastructure and public utilities, issuing all types of licences, and imposing and collecting service fees (Article 2); issuance of the rules for determining and estimating service fees in coordination with the Land Department and the Real Estate Regulatory Agency (Article 3); the Chairman's power to issue regulations on infrastructure, licences and public utilities (Article 4); repeal of conflicting provisions (Article 5).
