The right of way is not only the carriageway: by the bylaw's definition it is the road PLUS the area from its edges to the boundaries of adjacent plots. So the pavement and the forecourt of a building live under RTA rules. Administrative Resolution No. 273 of 2025 names what needs a no-objection certificate (excavation, permanent construction, laying utility lines) and what needs a permit: pavement occupancy, creating an ACCESS POINT to a private car park, a temporary site access, tents for weddings and funerals. Plus a refundable deposit and a black-points system.
Verified against official sources on 2026-09-15: the text of Administrative Resolution No. 273 of 2025 comes from the Dubai Legislation Portal (dlp.dubai.gov.ae), credited to the Supreme Legislation Committee of the Emirate, 2025. 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: specific works are judged on their own documents.
An owner usually assumes their responsibility ends at the plot boundary. Legally, the boundary does not sit where it seems to.
The document is Administrative Resolution No. (273) of 2025 Issuing the Implementing Bylaw of Executive Council Resolution No. (54) of 2021 Regulating Works in the Right of Way in the Emirate of Dubai, issued by the Director General and Chairman of the Board of Executive Directors of the Roads and Transport Authority on 10 March 2025; it is published in the Official Gazette and comes into force on the day of publication (Article 19).
What "right of way" means by definition
"Right of Way: A Public Road and the area extending from the edges of that Public Road to the boundaries of adjacent land plots, as demarcated on the plans approved by the DM." — Administrative Resolution No. (273) of 2025, Article 1
In other words, the strip between the road and your plot boundary is right of way, not "no man's land in front of the building". The same category covers pavements, public squares, bridges, tunnels, public car parks, median strips and the operational facilities of roads. There is also the right of way airspace — the air above it; and a protection zone around certain parts of it, set by a separate resolution.
Two different papers: certificate and permit
The bylaw carefully separates two instruments, and confusing them is expensive.
A no-objection certificate is required for works within the right of way or a protection zone (Article 2): excavation works; permanent construction works; laying utility lines; and any other works determined by the agency that may affect the right of way, a protection zone or utility lines.
A permit is required for occupancy and movement (Article 5). The list is long; here is what matters to an owner of property or a business:
- temporary pavement occupancy: tables, chairs and outdoor seating with sunshades; vending machines and amusement or gaming equipment; planters, farming supplies and seedlings outside agricultural shops; commercial promotional displays; temporary display tables in front of restaurants;
- works to create access points to private off-street car parks;
- submitting an access point design review request;
- construction or modification of pavements;
- works to create temporary access points to construction sites;
- occupancy of any part of the right of way;
- installation of tents for funeral services, weddings or Ramadan iftar;
- movement of heavy, overloaded and oversized vehicles during restricted times and in prohibited zones;
- pavement height reduction and marking of parking spaces outside UAE nationals' residential villas — that is how the line is worded in the text.
Terms
| Paper | Term | Article |
|---|---|---|
| no-objection certificate | a maximum of six months, except certificates for building permits; the specific term is set by a resolution of the agency's chief executive; renewable for the same period, with the application filed before expiry | 4 |
| permit | one year, renewable for the same period, application before expiry | 7(a) |
| a shorter permit | on the applicant's request for certain works per the resolution's schedule — for instance, occupancy involving tables and outdoor seating with sunshades: six months | 7(b) |
Applications go through the agency's system; the requirements for each type of works are published in that system (Article 3). For works near the agency's road facilities, the boundaries of the critical and safe zones specified in the system must be observed.
Who may carry out the works
The bylaw introduces a pre-qualification certificate (Article 8): a document of the agency authorising a contractor or a consultant licensed in the Emirate to design, implement or supervise works within the right of way. The definitions of contractor and consultant themselves refer to a licence for the relevant profession — that same licensing layer we covered separately.
On completion the agency issues a clearance certificate (Article 10) confirming that all permitted works are done.
Emergencies: work first, paper after
Article 13 closes a question that would otherwise be left to discretion. Government entities may carry out works in the right of way before obtaining a certificate or permit only in the listed cases: sudden subsidence of a public road threatening road users' safety; breakage of utility lines; interruption or failure of utility services; repair of rainwater drainage systems and inlets during the rainy season, which runs from 15 October to 30 April each year; and other emergencies determined by the agency in the system.
Commercial use of the right of way and its airspace
Article 14 allows commercial use of the right of way and its airspace on four conditions: the necessary approvals of the competent entities are obtained; a contractor pre-qualified by the agency is engaged; the use does not obstruct pedestrian movement, disrupt utility services or adversely impact traffic flow; and the use does not contravene planning conditions or public health and safety requirements.
The use itself is regulated by a contract between the agency and the user party, which must set out, among other things, the technical and operational requirements, the term and commencement date, the contract price, terms of payment, advance payments and guarantees.
We do not quote a price: it is set by the specific contract, not by this bylaw.
Money and discipline: deposit and black points
| What | As the bylaw puts it | Article |
|---|---|---|
| refundable cash deposit for occupying pavements and areas surrounding buildings and commercial establishments | AED 10,000 | 16(a) |
| refundable deposit in other cases | 10% of the project value, not exceeding AED 1,000,000 | 16(b) |
| when the deposit is partly deducted or forfeited | failure to complete the authorised works per the prescribed specifications and time frames; failure to repair damage to the agency's assets | 16(c) |
| black points | one point for every AED 10,000 of fines imposed; the blacklist at thirty points | 17(a) |
| how points come off | one point for each month without violations; after a year without violations from the last one — all points are removed | 17(b) |
| paid removal of points | AED 30,000 per point, no more than twenty points a year, and only if the person is not blacklisted | 17(c) |
Note how the system is built: black points are calculated from the value of the fines imposed, and this bylaw does not name those fines. So "what a violation costs" cannot be read here — and we substitute no figures of our own.
How this meets the other duties
The right of way is the same ground the neighbouring instruments speak about. The waste law obliges an owner to follow the cleaning scheme for the outdoor areas around the building's parking and to fence construction sites temporarily. The public health law counts roads and pavements within the "built environment" and requires continuous cleaning around it. And the construction safety decree protects workers inside and outside the sites. Different authorities, the same strip of land in front of the building.
What we do NOT claim here
- Fine amounts. This bylaw does not contain them: it only converts the value of fines into black points. We have not read the instrument carrying the schedule of violations and quote no amounts.
- Document requirements and decision timeframes. Article 3 defers expressly to the agency's system, where the requirements for each type of works are set out. We have not worked through it.
- The contents of the technical manuals. Article 15 approves them separately; we have not seen their text.
- The contents of Executive Council Resolution No. 54 of 2021. That is the parent instrument this bylaw implements; we have not read it and quote none of its rules.
- The price of commercial use of the right of way. It is set by the contract between the agency and the user (Article 14), not by this bylaw.
- Which paper a particular case needs. The certificate/permit split and the critical zones are set by the system and the agency's resolutions; we will not map particular works onto an instrument.
- The calendar date of entry into force. The bylaw applies from the day of publication in the Official Gazette; we have not verified that date. The date of issuance is 10 March 2025.
Sources
- Administrative Resolution No. (273) of 2025 Issuing the Implementing Bylaw of Executive Council Resolution No. (54) of 2021 Regulating Works in the Right of Way in the Emirate of Dubai — Dubai Legislation Portal: issuance by the Director General of the Roads and Transport Authority on 10 March 2025 and entry into force on the day of publication (Article 19); definitions of the right of way as a public road and the area up to the boundaries of adjacent plots, the right of way airspace, the protection zone, the pavement, pavement occupancy, utility lines, the authority's assets, the no-objection certificate, the permit, the pre-qualification certificate, the clearance certificate, the contractor, the consultant and the blacklist (Article 1); four kinds of works requiring a no-objection certificate (Article 2); filing through the system, observance of critical and safe zones and verification of documents, designs and public safety requirements (Article 3); a maximum six-month certificate term with the exception for building permits and renewal before expiry (Article 4); the list of works and activities requiring a permit, including pavement occupancy, access points to private off-street car parks, construction and modification of pavements, temporary construction site access, tents for funerals, weddings and iftar, and movement of heavy and oversized vehicles (Article 5); the one-year permit term and the schedule of shorter terms including six months for occupancy with tables and sunshades (Article 7); the pre-qualification certificate for contractors and consultants (Article 8); the clearance certificate (Article 10); five emergency cases including rainwater drainage repairs during the rainy season from 15 October to 30 April (Article 13); four conditions for commercial use of the right of way and its airspace and the mandatory contents of the contract with the authority, including price and guarantees (Article 14); the technical manuals (Article 15); a refundable deposit of AED 10,000 for pavement occupancy and 10% of project value capped at AED 1,000,000 in other cases, with the grounds for deduction (Article 16); one black point per AED 10,000 of fines, the blacklist at thirty points, removal of one point per violation-free month and of all points after a violation-free year, and paid removal at AED 30,000 per point up to twenty a year (Article 17); repeals of earlier instruments (Article 18).
