Proposed Amendments to DIFC Real Property Law and Enacted Changes to Operating Regulations

The Riffle

The Dubai International Financial Centre (DIFC) Authority has proposed a series of amendments to its Real Property Law and accompanying regulations — aiming to enhance clarity, fairness, and flexibility in the Centre’s real estate framework.

Simultaneously, the DIFC Authority has enacted changes to its Operating Regulations, empowering it to collect a 7% sales fee from hotels and alcohol-serving establishments within the Centre — a role previously managed by the Dubai Municipality.

Key Highlights from the Proposed Real Property Law Amendments

Released under Consultation Paper No. 3 of 2025, the proposed amendments seek to refine the DIFC Real Property Law No. 10 of 2018 to better reflect the needs of property owners, contractors, and tenants.

Notable proposed changes include:

• Ten-Year Decennial Liability for Contractors

  Contractors would be statutorily liable for construction defects for up to ten years — mirroring Article 880 of the UAE Civil Code. This bridges a current gap where such liability within the DIFC is only contractual.

• Discretionary Powers for the Registrar of Real Property (RoRP)

  The Registrar would gain authority to waive certain penalties or conditions where the strict application of the law could lead to unfair or unjust outcomes.

• Extended Deadlines for Registration and Fee Payments

  • Lease registration period to increase from 30 to 45 days.

  • Payment window for Freehold Transfer Fees on Off-Plan Sales to extend from 30 to 60 days, aligning with recent amendments to the Real Property Law.

• Revised Penalty for Unregistered Leases

  The penalty for failure to register a lease would be reduced from USD 1,000 to USD 100, ensuring proportionality for minor administrative delays.

• Removal of Obsolete Fees

  The $545 fee for lapsing a Caveat which no longer applies under current law, would be removed from the regulations entirely.

Enacted Changes to DIFC Operating Regulations

Effective October 28, 2025, the DIFC Authority has implemented amendments to its Operating Regulations granting it the power to collect a 7% sales fee from:

• Hotels

• Establishments serving alcohol within the Centre

This change, mandated by a Dubai Supreme Fiscal Committee Resolution, transfers the fee collection responsibility from the Dubai Municipality to the DIFC Authority, consolidating fiscal administration within the Centre.

Consultation Process and Timeline

The consultation on the proposed Real Property Law amendments remains open until November 28, 2025.

Stakeholders — including property owners, tenants, developers, and legal advisors — are invited to share their feedback on [email protected]

After the consultation period, DIFC will review all submissions and make any necessary revisions before formal enactment. The final laws and regulations will be published on the DIFC website upon approval.

Summary

The proposed amendments to the DIFC Real Property Law and the newly enacted fee collection framework highlight the Centre’s continued efforts to modernize its legal ecosystem.

By strengthening developer protections, introducing procedural flexibility, and aligning fiscal powers within the DIFC framework, the Authority reinforces its role as a leading, transparent, and responsive global business hub.

Read the full briefing document Presented by 10 leaves here -