Decree No. (22) of 2022: Key Features of Dubai’s Real Estate Investment Funds Law
Real Estate & Construction and Hotels & Leisure Focus
Lynsey GrossiSenior Associate,Real Estate
Ena TahricTrainee Solicitor,Real Estate
Decree No. (22) of 2022 ‘Approving the Grant of Privileges to Real Estate Investment Funds in the Emirate of Dubai’ (Real Estate Funds Law), issued by the Ruler of Dubai, is a landmark law designed to enhance Dubai’s status as a global real estate investment hub. The law grants a range of privileges to real estate investment funds, aiming to attract international capital and stimulate long-term growth in the Emirate’s property market. Below is a summary of the key features of this law.
The decree applies to:
all real estate investment funds licensed and regulated by competent authorities, including the Securities and Commodities Authority and the Dubai Financial Services Authority of the Dubai International Financial Centre; and
all real property (excluding vacant land) in the Emirate of Dubai, including special development zones and free zones, but excluding real property in the Dubai International Financial Centre.
Decree No.22 of 2022 marks a pivotal step in enhancing Dubai’s appeal to institutional real estate investors.
The primary objectives are to:
Promote Dubai as a premier global destination for real estate investment;
Incentivise funds to invest in diverse real estate projects;
Attract international real estate investment funds; and
Increase long-term capital returns for fund shareholders.
A dedicated “Real Estate Investment Funds Register” is maintained by the Dubai Land Department (DLD).
To register, a fund must:
Hold a valid license from a competent authority;
Own real estate assets valued at no less than AED 180 million at the time of application;
Not be suspended from trading its shares in Dubai’s financial markets; and
Pay a registration fee of AED 10,000.
The DLD, in coordination with relevant entities, regularly verifies ongoing compliance with these requirements.
Registered funds enjoy significant ownership rights:
They may acquire freehold ownership of real property in areas designated for non-UAE nationals.
They may also acquire freehold, usufruct, or lease rights (up to 99 years) in other areas, as determined by a special Real Estate Investment Funds Committee, provided the property’s market value is at least AED 50 million and it generates investment returns.
The Real Estate Funds Law prescribes reduced DLD fees for property transactions involving registered funds:
A 2% fee on the market value of the property purchased by the fund;
A 2% fee on the market value of the property in respect of the registration of usufruct or long-term lease rights by the fund; and
A special AED 50,000 fee applies for transferring ownership of in-kind property contributions from fund founders to the fund.
The Chairman of the Executive Council may modify or add privileges for funds.
The President of the DIFC is authorised to set privileges for funds operating within the DIFC.
The DLD appoints accredited valuers for property asset valuation.
Decree No.22 of 2022 marks a pivotal step in enhancing Dubai’s appeal to institutional real estate investors. While its adoption has been gradual, it lays a strong foundation to attract more real estate investment funds to the Emirate, reinforcing Dubai’s position as global real estate hub.
For further information,please contact Lynsey Grossi.
Published in June 2025
