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RERA escrow rules for off-plan developers in Dubai

30 June 20266 min read

Selling off-plan in Dubai comes with a clear deal: you can take buyer money before a building exists, but only if that money is ring-fenced and spent strictly on the project. The rules that enforce this sit under Dubai's escrow law for real estate development and are overseen by the Real Estate Regulatory Agency (RERA), part of the Dubai Land Department (DLD). Here are the ones that shape day-to-day operations.

1. Every project needs its own escrow account

Each off-plan project must have a dedicated escrow, or trust, account held with an approved account trustee. All payments from buyers go into that account. You do not get to mix project money with company money or with another project's funds. This is the foundation everything else rests on.

2. All buyer payments flow through escrow

Money collected from purchasers must land in the escrow account, not in a general operating account. Collecting payments outside escrow, even temporarily, is one of the fastest ways to create a gap that an audit will catch later.

3. Withdrawals are tied to construction progress

You cannot draw funds simply because they are in the account. Releases are linked to certified construction progress, typically supported by a consultant or engineer's certification. The principle is that the money leaves the account at roughly the pace the building goes up, which keeps buyer funds protected if work slows down.

4. Only eligible costs come out

Withdrawals must be for permitted, project-related costs. Construction and directly related project expenses generally qualify. General marketing, corporate overhead, and unrelated spending generally do not. Every withdrawal needs to be defensible as an eligible cost with supporting documentation.

5. A retention is held back

A portion of the funds, commonly around 5%, is retained and released only after the relevant completion and handover milestones, covering the defect-liability period. Releasing the retention early is a common and avoidable finding.

6. Funds stay segregated

Each project's escrow balance must be traceable and separate. If an auditor cannot cleanly tell one project's money from another's, that alone is a problem, even if the totals happen to work out.

7. You report and get audited

Escrow activity is subject to reporting and an independent audit. The audit confirms that inflows, outflows, progress linkage, retention, segregation, and documentation all held up over the year. Penalties for breaches can be significant.

What this means in practice

None of these rules are complicated on their own. The difficulty is keeping all of them true at once, across every transaction, for an entire year, usually on spreadsheets. That is where gaps creep in unnoticed.

Plinth is built around exactly these rules. It reconciles inflows, flags withdrawals that are not eligible or not yet justified by progress, watches the retention, and keeps each project segregated, so you are compliant continuously rather than hoping it all adds up at audit time.

This article is general information, not legal or financial advice. Confirm the specifics for your project with your auditor and the relevant authorities.

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Plinth keeps your off-plan escrow account reconciled and audit-ready all year, then exports your audit pack in one click.

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