A Dubai brokerage runs on four permissions, and the trade licence is only the first

The economic department licenses the company; the Land Department licenses the practice

Dubai splits property brokerage between two authorities and gives each a different half of the question. The Department of Economy and Tourism decides that a company may exist — this legal form, this activity, this address — and issues the trade licence that says so. The Dubai Land Department, acting through the Real Estate Regulatory Agency, decides whether that company and the people inside it may actually broker anything.

Law No. 16 of 2007 is where the second half comes from, and it is worth reading for what it hands over. RERA is established as a public corporation attached to the Land Department, and its functions include licensing and regulating real estate brokerages and supervising their activities, issuing the bylaws that govern the training and certification of brokers, and monitoring real estate advertisements published in the emirate's media. Three separate controls — the firm, the individual, the advertisement — sit inside one law, and not one of them is the trade licence.

So the thing people call "the brokerage licence" is four permissions, granted by two authorities, attaching to three different things, each running on its own clock.

Read the right-hand column first. Three of the four expire on an annual cycle a founder cannot influence, and the fourth expires faster than anything else in the business — which is why brokerages fail compliance on advertising far more often than on anything to do with formation.

The activity you pick is the whole application, and it is picked before the licence exists

Everything downstream is decided by the line you select from the activity directory. The Department of Economy and Tourism licenses against a classified activity, and the Land Department's approval is granted against that same activity. Choose "real estate brokerage" and you are inside RERA's brokerage regime. Choose an adjacent line — property management for third parties, owners' association management, real estate development, valuation, short-term letting — and you are inside a different set of conditions administered by the same authority through the same application. What each of those adjacent businesses asks for that brokerage does not is worked through on a brokerage licence does not let you manage a building, value it, or let it by the night.

They are not interchangeable and they are not cumulative. The Land Department's own licensing service treats them as separate activity types with separate conditions: some carry a bank guarantee, some require named staff to be approved individually, and some are open only to applicants who can evidence ownership or control of land. The individual card is not universal either — the service page names activities that do not require one, among them development, exhibitions, buying and selling land, representation offices and private property management. That exemption list is the clearest evidence of what the card actually is: a control on brokering, not a badge for working in property. A firm licensed to broker is not thereby licensed to manage, and the second permission is a fresh application rather than an amendment. The full set of activity types, sorted by the condition attaching to each, is on the real estate licence Dubai does not issue.

The general point is worked through in Choosing a sector is choosing which second authority has to approve you. What is specific to brokerage is that the second authority is not a one-off approver. It stays.

The sequence is fixed, and the trade licence is not the first step in it

The order below is not a suggested workflow. It is the order in which each authority will refuse to look at you until the step before is done — and the first station, activity selection, is the only one where the shape of the business is still free.

Two things fall out of that sequence that a quotation will not tell you. Premises come before the second approval, not after it, so the tenancy is a cost incurred against a permission you do not yet hold. And the individual cards are downstream of the firm's approval, so a brokerage cannot legally trade on day one of its licence — there is a gap between the trade licence issuing and the first person being able to act, and it has to be funded.

Whether a free zone entity can broker Dubai property is a question to ask, not an assumption to make

The usual statement is that a free zone licence does not permit brokerage of Dubai mainland property, so the jurisdiction decision is made for you. That is the right instinct, stated too firmly.

The Land Department's own licensing application carries a distinct set of terms for free zone licences, requiring the applicant to obtain a No Objection Certificate from their own licensing authority and file it with the application. A route that has its own published conditions is a route, not a closed door — free zone entities do present at that counter, and the Department has a documented way of handling them. Separately, Dubai Executive Council Resolution No. 11 of 2025 allows free zone establishments other than those in the DIFC to apply to the Department of Economy and Tourism for a branch licence inside the emirate or a permit to carry out specified activities, with the eligible activity lists to be published. Whether brokerage appears on those lists changes the answer.

So the honest position is narrower than the common one: a free zone licence is not by itself a permission to broker Dubai property, and the route that might make it one has to be confirmed with the Land Department for the specific entity and the specific activity. Anyone stating it more definitively, in either direction, is describing a position they have not checked. Get it in writing before the free zone fee is paid, because the fee is annual and the answer is not.

The card belongs to the person, and it walks out of the building with them

The individual permission is the one founders consistently misunderstand, because they treat it as a staff cost rather than as a licence held by someone else.

Each person who brokers holds their own card, issued after certified training and a RERA examination covering Dubai property law, brokerage conduct, contract types, client disclosure and anti-money-laundering duties. The published conditions run to the person, not the employer: an age floor, residence, a certificate of good conduct. The card renews on its own annual cycle, and it is attached to the individual and to the firm they are working through — which is why moving between brokerages is a transfer rather than a new hire's first day.

Three consequences follow, and none appears on a setup quotation.

An unlicensed person cannot broker, and cannot be made compliant by supervision. A junior sitting alongside a card-holder is not covered by that card. Whatever they are doing — sourcing, viewings, negotiating — either falls outside the licensed activity or it is unlicensed practice.

Headcount and licensing cost move together, permanently. Twenty agents is twenty cards, twenty courses and twenty renewals, every year, whether or not those twenty closed anything.

And the public can check. The Land Department publishes both lists — licensed brokers and licensed brokerage companies — as open lookups on its website and through the Dubai REST app. A counterparty can establish in under a minute whether the person in front of them is licensed. So can a client who has been told something optimistic by one of your own staff.

Every advertisement is a separate permission with its own number

This is the control that generates most of the enforcement, and the one people from other markets find hardest to internalise. In Dubai an advertisement is permitted individually.

The Land Department issues advertising permits through Trakheesi across a wide field: newspaper, SMS, outdoor, vehicle, printed, electronic, billboard, classified, promotional campaigns, open house events, exhibitions, project launches, promotion platforms and seminars. A brokerage advertising a property must hold a marketing contract with the owner as part of that application. Issue is quick — the Department states one working day — which is what makes non-compliance a choice rather than an accident.

The permit number is therefore part of the listing, not part of the file. Every portal entry, every board, every social post showing a property carries the number that authorises it. An advertisement without one is a breach whether or not anyone was misled, and the sanction attaches to the licensed firm rather than to the agent who posted it at eleven at night. A brokerage with thirty agents publishing from their own phones has thirty ways to breach a permission the firm holds, and the only workable answer is that nothing is published by anyone other than the person drawing the permits.

The forms are the transaction, not paperwork about it

RERA's unified forms are not a template pack. They are the instruments through which the market's contractual relationships are constituted, and this is where the brokers record earns its keep.

Form A appoints an agent to market an owner's property. Form B appoints an agent to act for a buyer. Form I governs cooperation between two brokerages on one deal. Form F is the sale contract itself, generated only inside the authority's system by a licensed broker.

Two habits follow. A listing without a signed Form A is not an instruction, it is an assumption — and since the ad-permit application asks for a marketing contract with the owner, the missing Form A blocks the advertising permission too. And a Form F offered from outside the system is not a contract with a formatting problem. It is evidence that someone in the chain is not licensed, and the correct response is to end the conversation rather than to fix the document.

The deeper reason to take the forms seriously sits in Law No. 7 of 2006: in Dubai a property right does not exist until it is recorded in the Property record, and an unrecorded transaction is not weakly enforceable, it is void. A brokerage's paperwork either feeds that record or it produces nothing. What that means on the buyer's side of the table is set out in A foreign buyer in Dubai owns one of three different things.

Broking property makes you a supervised reporter of financial crime

The Ministry of Economy and Tourism names real estate firms — brokers and agents explicitly — as one of the four Designated Non-Financial Businesses and Professions it supervises. That status attaches to the activity. It is not triggered by size, by deal value, or by whether you feel like a financial institution.

What it obliges is a programme rather than a filing: a business risk assessment, written policies, customer due diligence on both sides of a transaction, a named compliance officer, enrolment on the Financial Intelligence Unit's goAML platform, and reporting when a trigger is met. The Ministry's own notice to brokers and agents sets the retention period at not less than five years for records and transaction data.

Real estate then carries a reporting duty that most supervised sectors do not. Beyond suspicious transaction reporting, a real estate activity report is due through goAML where a freehold sale or purchase involves cash payments — single or multiple — amounting to or exceeding AED 55,000, or where payment is made in virtual assets or in funds converted from virtual assets. That is a rule about the form of payment, not about suspicion, and it catches ordinary deals done by ordinary clients. Note that it aggregates: a price settled in several cash instalments is not outside it because no single instalment reaches the figure.

The staffing consequence is the part that gets underestimated. Due diligence has to happen before the deal closes, on a counterparty who is in a hurry, by someone with the authority to stop it. In a commission-only sales culture that is a structural conflict, and it is why the compliance function cannot report to the person whose income depends on the transaction completing. The same supervisory logic, in a sector where it is better understood, is set out in Licensing a gold and precious metals business.

Where opening a brokerage is the wrong business to open

The licence is easy to sell and the business is hard to run. These are the cases where the honest answer is that you should not be applying.

The market being strong is the reason. Transaction volume is not a barrier to entry, it is the thing that attracts everyone else to the same doorway. A rising market makes brokerage look easy at the exact moment competition for the same instruction is heaviest, and the costs above are payable in a flat year too.

You want a licence that produces residence quietly. A brokerage carries continuing regulatory duties, inspection, and personal exposure for conduct breaches by people whose cards you sponsored. It is one of the most supervised small-company licences in the emirate. There are quieter activities, and the comparison belongs on the real estate and property investment page.

You cannot fund the gap before the first completion. Licence, premises, cards, permits, portal subscriptions and a compliance function all begin on day one, recur annually, and scale with headcount. Commission does none of those things. A brokerage rarely fails because the licence was expensive; it fails because those costs are front-loaded against income that is back-loaded, and the working capital was sized against a formation quotation rather than a year of operating.

Your model relies on agents working without cards. Sourcing staff, junior negotiators and offshore callers who touch clients are either performing a licensed activity or they are not — and if they are, they need their own cards. A model that only works on the other reading of that sentence does not work.

The plan is to broker off-plan units for one developer. That is a distribution relationship, not a brokerage, and the economics belong to the developer. The licence you need may be real; the business you are describing is a sales channel with a licence attached, and it ends when the developer changes its channel strategy.

You are licensing in a free zone because it was cheaper and you have not confirmed the position. Cheaper is the correct answer to a different question. Until the Land Department has confirmed in writing what that entity may do, the saving is unpriced risk.

What a new brokerage should be able to produce on its first day

1. The exact activity line, quoted from the classification directory, and the Land Department's confirmation of which conditions attach to that line and no other.
2. The trade licence and the Land Department's approval, as two separate documents with two separate expiry dates in the same calendar.
3. A card for every person who will speak to a client, with the renewal date of each one recorded against a named owner in the business.
4. The tenancy, Ejari-recorded, matching the address on both permissions.
5. The insurance the authority requires, in the amount the authority requires it, confirmed with the authority rather than with a broker of insurance.
6. One named person who draws every advertising permit, and a rule that nothing is published by anyone else.
7. The Form A file, complete, with no listing live that does not have one behind it.
8. The AML programme in operation — risk assessment, policies, a compliance officer who can stop a transaction, goAML enrolment done, and a written record of the due diligence on the last deal you would want an inspector to open.
9. The tax position settled before the first invoice. Commission is a supply that carries VAT, VAT enrolment has its own thresholds and timing, and a free zone brokerage's income has to be tested against the qualifying activity and counterparty rules rather than assumed to be outside the corporate tax regime.

Frequently asked questions