Developer Bankruptcy and Off-Plan Property in the UAE: What Really Happens to Your Money
Quick Answer: If your UAE off-plan developer goes bankrupt, your money is not automatically lost. Payments in your project escrow account are legally ring-fenced from the developer’s creditors under Article 9 of Law No. 8 of 2007.
If RERA cancels the project, you are entitled to a full refund. The developer cannot retain anything. Any SPA clause that tries to override this is void.
The honest qualifier: how much you actually recover depends on how much remains in escrow by the time action is taken. Early action matters more than litigation strategy.
If you are watching your developer miss construction milestones, reading news about financial distress, or already facing a cancelled project, the first thing to understand is this: the UAE’s legal framework was specifically designed for this scenario. You are not without protection, and you are not without options. The difficulty lies in knowing which system to use, when to act, and what recovery is realistic in your circumstances.
This guide explains exactly what happens when a UAE off-plan developer becomes insolvent or bankrupt. It covers the protection your escrow account provides, the role of the bankruptcy administrator under the new 2024 law, how to claim refunds through RERA and the Dubai Special Tribunal, where you rank among the developer’s creditors, and what recovery percentages look like in practice.
Who this article is for: buyers at any stage of developer distress, from early warning signs to active bankruptcy proceedings. For the broader refund framework, see our off-plan refund guide. For escrow mechanics, see our escrow law guide. For the full Article 11 retention analysis, see our Article 11 reference guide. For the RERA filing route, see our RERA complaint guide. For forum selection, see our Dubai Courts vs DIAC guide. If your developer is merely delayed (not yet in distress), start with our delayed handover guide. If the developer is asserting force majeure, see our force majeure guide. For pre-signing diligence, see our SPA clauses guide.
- →My developer is showing distress signs but still operating
- →RERA has flagged or cancelled my project
- →Bankruptcy proceedings have been filed
- →I want to understand my creditor ranking
- →What does recovery realistically look like?
- →What does the 2024 bankruptcy law mean for me?
- →I bought in Abu Dhabi, not Dubai
- →Practical takeaways
Start Here: The Two-Track System
Most buyers assume that if their developer goes bankrupt, one court, one process, and one outcome follow. The UAE operates differently.
Two parallel systems run at the same time. The federal bankruptcy regime governs the developer. The Dubai real estate protection system governs your escrow.
They do not replace each other. The bankruptcy trustee controls the developer’s corporate assets but cannot touch properly ring-fenced escrow funds. Which system contains the money you are trying to reach determines almost everything about your recovery.
This is why two buyers with identical SPAs in two different projects can experience very different outcomes. One may receive a full refund through RERA within months. The other waits years as an unsecured creditor in a bankruptcy estate with no remaining escrow balance. The difference is not the law. It is the state of the escrow account.
- Law No. 8 of 2007 on Escrow Accounts for Real Estate Development. Article 9 ring-fencing, Article 14 5% retention, Article 15 failure trigger.
- Law No. 13 of 2008 (as amended by Law No. 19 of 2020), Article 11 governing retention on cancellation, with paragraph (b) requiring full refund on non-commencement or RERA cancellation.
- Executive Council Resolution No. 6 of 2010, the implementing bylaw: Articles 23 to 27 on RERA cancellation procedure, Article 25(4) 14-day escrow refund, Article 26 60-day developer shortfall.
- Federal Decree-Law No. 51 of 2023 on Financial Restructuring and Bankruptcy (effective 1 May 2024), with Cabinet Resolution No. 94 of 2024 as the Executive Regulation.
- Decree No. 33 of 2020 establishing the Special Tribunal for Unfinished and Cancelled Real Property Projects, with exclusive jurisdiction and fee-exempt proceedings.
Federal Decree-Law No. 25 of 2025 replaces the 1985 Civil Code from 1 June 2026. Dubai real estate legislation (Law No. 8 of 2007, Law No. 13 of 2008) is not directly affected. But compensation, termination, and damages claims filed after 1 June 2026 must reference the new Civil Code provisions, with article numbers updated.
What Recovery Realistically Looks Like
This is the section most buyers want to skip to. The honest answer requires nuance, because recovery outcomes range from full refunds in months to near-zero after decades. The sections that follow on escrow protection, the RERA cancellation process, the Special Tribunal, and the 2024 bankruptcy law explain why outcomes vary so widely; this section is a preview of what those mechanics produce in practice.
Escrow largely intact, early RERA cancellation
Full recovery within 3 to 6 months. This tends to happen in newer projects with strong escrow discipline, where the developer failed early before significant funds were drawn down. Individual cases have involved full refunds following a 12 to 18 month process, sometimes with statutory interest awarded at the discretion of the adjudicating body.
Escrow partially depleted
Pro-rata distribution typical. DLD’s own guidance states that escrow funds are distributed “either in full or in proportion, depending on the amount available.” A 50% to 70% recovery is not unusual. The developer has 60 days to top up the shortfall; if they cannot, the Special Tribunal takes over. Total timeline 12 to 18 months.
Developer insolvent, escrow exhausted
Recovery can fall to a small fraction of amounts paid. Al Tamimi & Company has observed that the original tribunal’s liquidation process “did not help many investors, as they only received a small portion of their dues after the liquidation of such real estate projects.” Some historical Dubai cases have stretched 15 to 19 years for buyers who paid in full during the 2007 to 2008 boom.
No official RERA data exists on aggregate recovery percentages. Any figures quoted in media or on broker websites should be treated with caution. The legal position is clear. The statistical position is not.
Frequently Asked Questions
Can I lose all my money if my UAE off-plan developer goes bankrupt?
In most post-2008 Dubai projects with properly maintained escrow accounts, no. Escrow funds are legally ring-fenced under Article 9(1) of Dubai Law No. 8 of 2007 and cannot be seized by the developer’s creditors. Where escrow is intact, you can recover substantial amounts or the full sum paid. Where escrow has been depleted and your claim has to be pursued against the developer’s general estate, recovery can drop sharply because you rank as an unsecured creditor under Federal Decree-Law No. 51 of 2023.
How long does it take to get a refund after RERA cancels a project?
Available escrow funds must be distributed within 14 days of the cancellation decision under Article 25(4) of Executive Council Resolution No. 6 of 2010. If a shortfall exists, the developer has 60 days under Article 26 to top up. If the developer cannot pay, the matter moves to the Special Tribunal under Article 27, which can extend the total timeline to 12 to 18 months or longer depending on complexity.
Should I file my refund claim through the DLD violations portal?
No, not for the refund itself. The DLD Rental and Real Estate Violations Service (RVS) handles regulatory complaints and expressly excludes contractual disputes, refund claims, compensation claims, and contract revocation. Refund and compensation claims go through the Real Estate Dispute Settlement Centre for conciliation, then Dubai Courts Real Estate Circuit or arbitration. Both pathways can run in parallel: RVS to trigger regulatory action, Settlement Centre to pursue your contractual refund.
Does Oqood registration make me a secured creditor if the developer goes bankrupt?
No. Oqood registration creates a contractual interest recorded at DLD. It protects you against the developer reselling your unit and gives you legal standing. But it is not a registered mortgage or charge of the type Article 179 of Federal Decree-Law No. 51 of 2023 recognises as creating secured creditor status. In formal bankruptcy, an off-plan buyer with Oqood is an ordinary unsecured creditor in respect of claims against the developer’s general estate, though funds in a compliant escrow account remain protected separately.
What is the Special Tribunal and do I need a lawyer to file there?
The Special Tribunal for Unfinished and Cancelled Real Property Projects is currently governed by Decree No. 33 of 2020. It sits at DLD. Filings are exempt from judicial fees. While you can technically file on your own, the Tribunal’s decisions are final and not subject to ordinary appeal, so most buyers use a UAE-qualified lawyer with real estate disputes experience.
What happens to the project itself if the developer is bankrupt?
Three outcomes are possible. RERA can appoint a replacement developer to complete the project. The bankruptcy trustee can sell the project as a going concern under the restructuring provisions. Or RERA can formally cancel the project, liquidate the escrow account, and refund buyers.
Does it matter if I bought in Dubai or another emirate?
Yes, significantly. Dubai has the most developed framework: Law No. 8 of 2007 on escrow, Law No. 13 of 2008 and its amendments, and the Special Tribunal under Decree No. 33 of 2020. Abu Dhabi has its own framework under Law No. 3 of 2015 with ADREC as regulator, but no equivalent dedicated tribunal. Northern emirates generally rely more heavily on ordinary civil court procedures.
Warning Signs Your Developer May Be in Distress
Early detection changes outcomes. The buyer who acts at the first warning sign typically recovers more, faster, than the buyer who waits until the developer has publicly collapsed.
- Construction delays past the registered completion date. A delay of more than the contractual grace period (commonly 6 to 12 months) without credible progress is a red flag. For the pre-dispute delay framework, see our delayed handover guide.
- Escrow irregularities. Requests to pay instalments into a general business account rather than the project escrow, changes of escrow agent without explanation, or missing escrow certificates on DLD’s system should trigger immediate investigation.
- Aggressive resale discounting. Deep discounting of unsold inventory well below prevailing market prices can indicate cash flow pressure rather than marketing strategy.
- Requests to amend the SPA. Developers approaching buyers mid-project with “routine” amendments extending timelines, restructuring payment plans, or waiving specific clauses deserve careful review, not a quick signature.
- Public market distress signals. For developers with listed bonds or sukuk, yield spreads widening sharply versus comparable benchmarks are objective indicators of financial stress that appear before operational problems become visible.
- Regulatory actions. Fines issued by DLD or RERA, licence suspensions, and Article 17 deregistration notices under Law No. 8 of 2007 are serious markers.
If you are seeing two or more of these signs, your position deserves a formal legal review.
Why the Escrow Account Is Your Single Most Important Protection
Under Article 9(1) of Dubai Law No. 8 of 2007, an escrow account is opened in the name of the project and is dedicated exclusively to the construction of that Real Estate Development project. No attachment may be imposed on the payments deposited in this account for the benefit of the creditors of the Developer.
Read that provision twice. It means creditors chasing the developer cannot seize your escrow payments to satisfy the developer’s debts to them. Your money, while it remains in the escrow account, is legally separate from the developer’s bankruptcy estate.
Article 9(2) reinforces this by requiring a separate escrow account for every project. Commingling is prohibited. If a developer has ten projects, there must be ten escrow accounts. For the full escrow mechanics, see our escrow law guide.
The protection has limits every buyer should understand clearly.
- Already-released funds are gone. Ring-fencing applies only to funds still in the account. Money released for completed construction milestones is out of the pool. A 70% drawn-down escrow is 70% gone.
- The 5% retention is locked for one year. Article 14 of Law No. 8 of 2007 holds 5% in escrow for one year after unit registration to cover defects. Not available for refund until that year has passed.
- Pre-2008 purchases may have no escrow protection. Several long-running Dubai cases involve units sold before the escrow law was fully enforced.
- Only legitimately deposited payments are protected. If a developer misdirected your payments to a general business account, those funds sit outside the protected perimeter. Every instalment should go to the project escrow account, never to the developer’s general account.
What happens to the escrow when a developer fails
Article 15 of Law No. 8 of 2007 sets out the trigger. When a developer cannot complete a project, the escrow agent must, after consultation with DLD, take the required measures to preserve the rights of depositors, and ensure that the Real Estate Development project is completed, or depositors are refunded their payments.
In practice, RERA freezes the escrow account, stops all further withdrawals, and investigates the developer’s financial condition. Two outcomes are possible. Either a replacement developer is appointed to complete the project, or the project is formally cancelled and the escrow funds are returned to buyers.
How the 2024 Bankruptcy Law Treats Off-Plan Buyers
Federal Decree-Law No. 51 of 2023 took effect on 1 May 2024 and replaced Federal Decree-Law No. 9 of 2016. All cases pending under the old law transferred automatically to the new Bankruptcy Court without fees. The Executive Regulation (Cabinet Resolution No. 94 of 2024) was published in September 2024 and applies retroactively.
The law introduces three distinct procedures. Each has different consequences for buyers.
Preventive Settlement
The developer remains in control of its business under court supervision. A three-month automatic moratorium blocks creditor claims, extendable to six months (the extension requires a court order). The developer must propose a settlement that at least two-thirds of ordinary creditors (by value) approve, representing more than 50% of total unsecured debts.
What this means for you: you cannot enforce your SPA, file for refund, or execute against the developer’s assets for up to six months. Use that window for RERA and Settlement Centre action, not for SPA-based litigation.
Restructuring
A court-appointed trustee supervises management. The moratorium has no fixed time limit and continues until a plan is ratified or the proceedings terminate. A critical feature is the “cram-down” power: the Bankruptcy Court can ratify a restructuring plan even if creditors reject it, provided creditors are not worse off than they would be in liquidation.
What this means for you: the moratorium has no fixed end. Plan for a multi-year timeline if the matter stays here. Your best route to recovery usually remains the escrow/RERA track, not negotiating the restructuring plan.
Bankruptcy and Liquidation
The trustee assumes full control of the developer, replacing the board, chairman, and CEO. A liquidation plan must be prepared within 30 days of the first creditors’ meeting, extendable to three months. Assets are sold and proceeds distributed according to the statutory priority order.
File your claim within 30 days of the trustee’s published invitation or you forfeit it entirely. This is the single hardest deadline buyers face in formal bankruptcy proceedings. It is not negotiable, and it runs independently of anything happening on the RERA track.
Where You Rank Under Article 179
Article 179 of FDL 51/2023 sets the distribution waterfall for claims against the developer’s general bankruptcy estate. The order is broadly:
- Secured creditors are paid up to the value of their security (typically banks with registered mortgages over the developer’s assets).
- Privileged debts are paid in a specific order: judicial fees, alimony, government taxes, employee wages (with a separate absolute priority under Article 146 for wages accrued before proceedings), expert fees, and post-commencement beneficial contract costs.
- Ordinary unsecured creditors share whatever remains.
The Article 179 waterfall only governs claims pursued against the developer’s general estate. Funds sitting inside a properly maintained escrow account are not part of that estate.
An off-plan buyer whose escrow is intact is not competing with the developer’s bank creditors for those funds. Unsecured creditor status bites only where the escrow is depleted, the project was non-compliant, or the claim is for amounts beyond what escrow can cover (such as consequential damages).
A common misconception is that Oqood registration elevates you to secured creditor status in a formal bankruptcy. It does not. Oqood creates an in-personam (contractual) interest recorded at DLD. It protects you against the developer reselling your unit and gives you legal standing. But it is not a registered mortgage or charge of the type Article 179 recognises as secured. Full title with registered security only exists after handover.
The RERA Project Cancellation Process
When a developer cannot complete, RERA has statutory power to cancel the project. The cancellation triggers a defined refund mechanism that, critically, operates inside the escrow system and largely independently of the federal bankruptcy process.
Grounds for cancellation
Article 23 of Executive Council Resolution No. 6 of 2010 lists nine grounds on which RERA can cancel a project. The most common in insolvency situations are: failure to commence construction within six months of approvals, escrow violations under Article 16 of Law No. 8 of 2007, gross negligence in construction, the developer expressing an intention not to perform, and the developer lacking serious intent to complete.
The cancellation timeline
Articles 24 to 27 of the same Resolution set the procedure. RERA conducts a technical assessment, issues a cancellation resolution, and notifies the developer. The developer has 7 working days to appeal, and RERA must decide the appeal within a further 7 working days. Once cancellation is final, RERA appoints an auditor (at the developer’s cost) to review the escrow account. Available escrow funds are distributed to buyers within 14 days of cancellation under Article 25(4). If a shortfall exists, the developer has 60 days under Article 26 (extendable at RERA’s discretion) to pay the difference. If the developer cannot reimburse, Article 27 provides for referral to the Special Tribunal.
Article 11(b) of Law No. 19 of 2020 is unambiguous: when RERA cancels a project, the developer must refund all amounts received from buyers, with no retention. This is a public order rule. Any SPA clause that tries to contradict it is void. For the full Article 11 analysis, see our Article 11 reference guide; for the three full-refund scenarios, see our off-plan refund guide.
The rule delivers when the escrow account is intact. It breaks down when the escrow has been depleted and the developer has no other resources. The law gives you a full claim. It does not guarantee the developer has the money to meet it.
The Special Tribunal Under Decree No. 33 of 2020
Dubai’s Special Tribunal for Unfinished and Cancelled Real Property Projects was formed under Decree No. 21 of 2013 and is currently governed by Decree No. 33 of 2020, which expressly superseded and expanded the earlier decree under Article 16(a). The Tribunal is headquartered at DLD, and applications are exempt from judicial fees.
Expanded jurisdiction
Decree 33/2020 broadened the Tribunal’s reach beyond cancelled projects to include unfinished projects, addressing a gap in the original framework. Article 6 covers: claims arising from cancelled and unfinished projects, disputes over replacement developer assignments, developer grievances against RERA cancellation decisions, determination of rights when projects transfer between developers, project liquidation, and associated execution proceedings.
Article 10 establishes exclusive jurisdiction, prohibiting all courts in Dubai (including the DIFC Courts) from hearing matters within the Tribunal’s scope. Article 11 confirms that decisions are final, conclusive, and not subject to ordinary appeal. For forum analysis in non-cancelled cases, see our Dubai Courts vs DIAC guide.
Powers and procedure
Under Article 7, the Tribunal can issue interim and preliminary orders, propose mediation and conciliation, form sub-committees, appoint auditors at the developer’s expense, and direct escrow agents on refund distribution. Under Article 9, RERA must submit detailed reports on each project.
Practical significance for buyers
For a buyer in a cancelled or stalled Dubai project, the Tribunal is often the most effective forum. The process is fee-free, the decisions are final, and the Tribunal can direct escrow agents directly. This matters because the ordinary civil courts, while available in theory, are slower, more expensive, and less specialised.
What You Can Do Right Now
The legal options depend on where your developer sits on the distress spectrum. Before proceeding, one clarification.
RVS (Real Estate Violations Service) handles regulatory and licensing violations: unlicensed marketing, escrow non-compliance, breach of developer obligations under RERA regulations. RVS expressly excludes contractual disputes, refund claims, compensation claims, and applications to revoke or terminate contracts.
Real Estate Dispute Settlement Centre handles contested contractual relief (refund, rescission, compensation, enforcement of SPA terms) through mandatory conciliation, and if unresolved, to Dubai Courts Real Estate Circuit or arbitration depending on the SPA’s dispute resolution clause.
In most developer-distress situations, both pathways run in parallel. Use RVS to flag regulatory breaches and trigger RERA scrutiny. Use the Settlement Centre to pursue your contractual refund. They are complementary, not alternatives. For the full regulatory-filing strategy, see our RERA complaint guide.
If the developer is still operating but delayed
Actions to take this week
- File a regulatory complaint through RVS for any escrow or licensing violations you can evidence. This puts the developer under RERA scrutiny and creates a formal record.
- Request a formal status report on the escrow account. You are entitled to confirmation that your payments are sitting where they should be.
- Review your SPA for termination triggers. Under Article 272 of the UAE Civil Code, a party may seek rescission (fasakh) where the other party fails to perform a material obligation, after serving notice. Before serving any termination notice, a professional SPA review is essential. The wrong termination notice can forfeit rights rather than preserve them. For pre-signing and clause-level analysis, see our SPA clauses guide.
- Initiate conciliation at the Real Estate Dispute Settlement Centre for refund or compensation claims. If conciliation fails, the matter proceeds to Dubai Courts Real Estate Circuit or arbitration.
If RERA has already flagged the project
Actions to take this week
- Petition RERA to exercise its cancellation powers under Article 23 of Resolution No. 6 of 2010. A formal cancellation triggers the Article 11(b) refund mechanism and the Article 25(4) and Article 26 distribution timetable.
- Gather documentation for potential Tribunal filing. If RERA cancels and a shortfall exists, you will need a complete evidence pack quickly. This includes every payment receipt, bank transfer confirmation, escrow deposit record, SPA, Oqood certificate, and correspondence.
- Monitor DLD and Dubai Courts notices for project status changes.
If the developer is already in formal bankruptcy
Actions to take this week
- File your claim within the 30-day window after the trustee’s published invitation. Missing this deadline can forfeit your claim entirely. Prepare documentation to prove the amount owed, the basis of the claim, and any security or priority arguments.
- Monitor the escrow account’s status separately from the bankruptcy proceedings. The two tracks operate in parallel, and your best recovery usually comes from the escrow and tribunal route, not the bankruptcy estate.
- Consider coordinated action with other buyers. While the UAE does not have a formal class action mechanism, multiple buyers filing aligned complaints and claims create regulatory pressure and efficient legal coordination.
Abu Dhabi: A Parallel but Distinct Framework
If your project is in Abu Dhabi, the framework differs in important ways. Law No. 3 of 2015 Concerning the Real Estate Sector governs escrow accounts, off-plan sales, and buyer protection. The Abu Dhabi Real Estate Centre (ADREC), established in 2023 under the Department of Municipalities and Transport, is the primary regulator.
Abu Dhabi’s escrow framework contains statutory language on buyer priority within the escrow pool. If a developer fails, the escrow bank must safeguard depositors and ensure completion, failing which buyers and financiers are granted priority to escrow funds after trustee expenses.
Abu Dhabi does not have an equivalent to Dubai’s Special Tribunal. Disputes over cancelled Abu Dhabi projects must go through the ordinary Abu Dhabi courts and ADREC’s administrative processes. This typically means longer timelines and more procedural complexity than Dubai’s fee-exempt Tribunal route.
Abu Dhabi’s framework continues to be updated through DMT and ADREC decisions, and specific provisions applicable to your project should be verified against current ADREC guidance before action.
What Remains Uncertain
A small number of areas in this framework remain legally underdeveloped, and honesty requires flagging them.
- Federal Bankruptcy Court vs Special Tribunal jurisdictional boundary. The interaction when a developer enters formal bankruptcy while its projects are simultaneously before the Tribunal is not clearly addressed in published guidance. Jurisdictional questions can arise, and the practical answer tends to be worked out case by case.
- Treatment of off-plan SPAs as executory contracts. Whether a trustee can disclaim or reject your SPA in a formal bankruptcy, and what the consequences would be if they did, has not been conclusively tested in UAE jurisprudence under FDL 51/2023.
- Treatment of non-compliant payments. Where a buyer paid outside the project escrow (into the developer’s general account), the treatment of those payments in a formal bankruptcy is unsettled: whether they are recoverable from the general estate as void receipts or rank as ordinary unsecured claims depends on the facts and practitioner practice varies.
- New Civil Code impact post-1 June 2026. Federal Decree-Law No. 25 of 2025 may affect compensation and termination claims filed after that date. The practical impact on real estate disputes will emerge over the coming years.
These gaps are not reasons to delay action. They are reasons to get specific legal advice rather than relying on general guidance.
Practical Takeaways
Five principles to internalise
- Verify your escrow account status regularly through the escrow agent, not through the developer. Article 12 of Law 8/2007 gives you the right to your own records.
- If you see two or more warning signs, commission a formal legal review now, not after the developer publicly collapses. Early action is worth more than a strong judgment on a depleted escrow.
- If RERA has flagged the project, start building the evidence pack immediately. Payment receipts, bank confirmations, escrow statements, SPA, Oqood certificate, and correspondence. If cancellation follows, the Tribunal process moves quickly.
- If formal bankruptcy is filed, the 30-day creditor claim deadline is not negotiable. Missing it can forfeit your claim against the general estate entirely.
- Monitor the escrow track and the bankruptcy track in parallel. They do not substitute for each other, and your best recovery usually comes from the escrow and Tribunal route, not the bankruptcy estate.
The worst position you can be in is paralysis: knowing something is wrong, feeling overwhelmed by the legal complexity, and doing nothing while the situation deteriorates. Escrow funds have time limits. Claim windows have deadlines. The 30-day bankruptcy filing window is not negotiable.
Send us the SPA, the escrow account details, the Oqood certificate, and any correspondence with the developer, RERA, or DLD. Within 48 hours you will get a written view on:
- Where your project sits on the distress spectrum
- What deadlines are running against you right now
- What action you should take this week to preserve your position
We do not take every matter. Where your position is straightforward, we will tell you that. Where it is complex, we will set out the options and timelines honestly. Contact us through offplandisputes.ae.
This article reflects UAE law as at April 2026, including Federal Decree-Law No. 51 of 2023 (effective 1 May 2024), Cabinet Resolution No. 94 of 2024, and the Dubai real estate framework as amended through 2020. Federal Decree-Law No. 25 of 2025 (new Civil Transactions Law) enters into force on 1 June 2026 and may affect compensation claims filed after that date. Statutory citations have been cross-checked against the official bilingual texts on the Supreme Legislation Committee’s Dubai Legislation Portal. Practitioner commentary cited (Al Tamimi & Company) should be verified against the underlying publications before being relied on in pleadings. Specific facts change outcomes. In case of any conflict between the English translation and the original Arabic text, the Arabic prevails.
This article is for general information only. It does not constitute legal advice and does not create a lawyer-client relationship. UAE law and Dubai real estate regulations are fact-sensitive, and outcomes in any specific matter depend on the precise terms of the SPA, the state of the project, the applicable regulatory decisions, and the timing of events. Readers should obtain advice from a UAE-qualified legal consultant on the facts of their particular case before acting on anything in this guide.