Freehold vs Leasehold in Dubai: Who Can Own Commercial Property, and Where

Freehold is permanent, unlimited title to the property, registered in the owner's name with no expiry; leasehold and usufruct are time-limited rights to use someone else's property, capped at 99 years. Both are real property rights and both are registered at Dubai Land Department, but they are not the same asset.

The practical consequences for a commercial investor sit in three places. First, exit: a freehold title is sold as an asset in its own right, while a leasehold interest is sold with a shrinking term, and the discount steepens as the tail shortens. Second, finance: lenders assess a diminishing term differently from perpetual title, so the security position and the loan-to-value you are offered can differ. Third, control: what you may alter, sublet or change the use of is set by the lease or usufruct instrument rather than by ownership alone.

DLD also registers musataha, which is distinct again — the right to build on land belonging to someone else. Its service card describes musataha as running for up to 50 years, against up to 99 years for usufruct or long-term lease. For an occupier planning a purpose-built facility on land it will not own, that 50-year ceiling is the number that shapes the business case.

Where a purchase forms part of a wider Dubai strategy, the Legal, Tax and Ownership hub for commercial property investors maps how ownership, registration, tax and residency fit together.

Article 4 of Law No. 7 of 2006 restricts the right to own real property in the Emirate to UAE nationals, nationals of GCC member states, companies fully owned by them, and public joint stock companies. Non-UAE nationals may, subject to the Ruler's approval and only in certain areas determined by the Ruler, be granted freehold ownership without time restriction, or usufruct or leasehold for a period not exceeding 99 years.

Read the bottom row carefully, because it is the point most commonly got wrong. A long lease is not a fallback that a non-GCC buyer can use anywhere in Dubai. Under Article 4, the 99-year usufruct or leasehold right is granted in the same way as freehold — by Ruler designation, over particular areas. DLD's own Property Status Enquiry reflects this: where a plot is flagged NonFreehold, the stated position is that "Purchase is allowed for GCC Nationalities", full stop.

The UAE Government Portal states the same framework plainly: "In Dubai, foreign ownership is permitted in areas designated as freehold", and foreigners who do not live in the UAE, as well as expatriate residents, "may acquire freehold ownership rights over property without restriction, usufruct rights, or leasehold rights for up to 99 years" (u.ae, accessed Aug 2026).

The other emirates run their own regimes, with their own instruments and their own investment zones. Do not assume Dubai's rules travel — take advice specific to the emirate you are buying in.

The reliable answer is not a published list — it is a per-plot check at DLD, because designation attaches to numbered plots shown on maps issued by the Department, not to a neighbourhood name on a marketing brochure.

Article 3 of Regulation No. 3 of 2006, as originally issued on 7 June 2006 and published in English on the Dubai Legislation Reference Portal, names 23 areas and, against each, the specific plot numbers over which non-UAE nationals may take freehold, usufruct or leasehold up to 99 years: Umm Hurair 2, Al Barsha South 2, Al Barsha South 3, Emirates Hills 1, Emirates Hills 2, Emirates Hills 3, Jebel Ali, Al Jaddaf, The World Islands, Ras al Khor, Al Rowyah, Sheikh Zayed Road, Sofouh 1, Sofouh 2, Al-Qouz 3, Al-Qouz Industrial Area 2, Al-Qouz Industrial Area 3, Mirdif, Dubai Marina, Palm Jebel Ali, Palm Jumairah, Nad al-Sheba and Warsan 1. Article 4 of the same Regulation adds plot 224 in Nad al-Sheba for usufruct or leasehold only — a useful reminder that designation can grant one right and withhold another on the same map.

Within that original schedule, the entries commercial buyers tend to focus on are Jebel Ali, Ras al Khor, Al-Qouz Industrial Areas 2 and 3, Sheikh Zayed Road and Umm Hurair 2. The Regulation designates areas and plot numbers; it does not classify those plots by use. Treat any office, retail or logistics label attached to an area name as market shorthand, and confirm the approved use of the specific plot rather than inferring it from where the plot sits.

How the 2006 schedule has been extended since

The 2006 text is the starting point, not the current position. The Ruler has added land to the designated areas repeatedly by separate resolution, each dated, each plot-specific, and each granting its own combination of rights. These are the amending instruments retrievable in English from the Dubai Legislation Reference Portal at the time of writing:

Two of those matter disproportionately if you are buying commercial stock. Resolution No. 25 of 2021 opened four plots — in Jebel Ali Industrial Third, Ras Al Khor Industrial Third and Al Warsan First — but granted usufruct and lease rights only, and expressly not freehold. The Resolution identifies those plots by number and area name and attaches no use classification to them, so establish the permitted use of the specific plot before you underwrite it. What the instrument does settle is the interest on offer: on those four plots a non-GCC buyer can register a term of years rather than perpetual title, and your exit pricing and your lender conversations both need to reflect that. Resolution No. 18 of 2019 and Resolution No. 6 of 2022, by contrast, granted full freehold on plots in Trade Centre Second, Zaabeel Second and Zabeel First.

That table is what the official portal publishes in English; it is not certified as complete, and it is not presented here as the definitive amendment history. Legal commentary refers to further amending instruments issued between 2010 and 2012 that the portal does not publish in English, and the Government of Dubai's own 2014 compilation of real estate legislation cites the instrument as "Regulation No. (3) of 2006 ... and its amendments" without enumerating them. Read the table as proof that the schedule moves, not as the schedule itself.

For the same reason, this guide does not publish a current total count of freehold areas. The counts circulating in the market are far higher than 23, no primary source publishes a consolidated official register of designations, and a number you cannot trace is worth nothing when the actual question is whether one specific plot qualifies. Check the plot. For context on how the freehold footprint has become a market story in its own right, see our article on Dubai's freehold move and what it opens up for investors.

The Sheikh Zayed Road and Al Jaddaf conversion route

There is also a route that converts existing ownership rather than designating new land, and it sits on one of Dubai's main commercial corridors. On 19 January 2025 Dubai Land Department announced that private property owners in the Sheikh Zayed Road area "from the Trade Centre Roundabout to the Water Canal" and in Al Jaddaf can convert their ownership status to freehold to all nationalities. DLD put the eligible stock at 457 plots — 128 along Sheikh Zayed Road and 329 in Al Jaddaf — and set a conversion fee of 30% of the property's valuation, based on gross floor area. Owners confirm eligibility through the Dubai REST app, then apply to DLD for land assessment and valuation; a map and a freehold title deed are issued once the fee is paid.

Two practical readings for a buyer. First, conversion is something the owner applies and pays for, not an automatic change of status, so a plot inside those boundaries is not freehold until it has actually been converted — the per-plot check remains the answer. Second, where a seller has not converted, that 30% fee is a live negotiating item whose size depends on a DLD valuation you will not have seen. Ask for the valuation, not just the headline percentage, and sense-check the underlying figure against the commercial property valuation tool before you price the deal around it.

It shows whether the plot may be bought by all nationalities or only by GCC nationals, and it surfaces the encumbrances and disputes that would otherwise only emerge late in a deal. You can search by title deed number, property number, Makani number, municipality number, or by selecting the plot on a map.

Alongside the Freehold or NonFreehold flag, the enquiry returns:

• Property blocking — including the blocking authority, the blocking date and the stated reason.
• Dubai Municipality violations — violation date, type and status.
• Active rental dispute cases — case number, case type and activation date.
• Restrained information — case number, case type and registration date.
• A title deed explanation, and the underlying land record details.

An active rental dispute on a tenanted office floor, or a live municipality violation on a warehouse, changes what you are buying and what you should pay for it. Run the enquiry before you sign anything, not after. DLD also operates a separate free Verify Title Deed service, which validates a deed number, year, property type and owner name against the register and returns a digitally validated result. For a practical walkthrough of these and the other portals you will use, see Dubai REST, DubaiNow, Ejari and DET: how to use Dubai's property government portals.

DLD's Property Sale Registration service card sets the transfer fee at 2% of the sale value payable by the seller and 2% payable by the buyer, with a set of fixed additional fees on top. The service is open to all residency statuses and accepts a valid passport for non-resident foreign buyers in place of an Emirates ID.

Two practitioner points. DLD's card allocates only the 2% and 2% shares between the parties; it says nothing about who bears the fixed additional fees, so make that allocation explicit in the sale contract rather than assuming. And the "+ VAT" on the trustee fee, and any VAT arising on the sale itself, are a separate question with their own rules — see UAE corporate tax and VAT on commercial property and our article on the VAT rules when buying commercial property in Dubai.

To sanity-check the all-in cash requirement before you make an offer, run the numbers through the Dubai buying-costs calculator.

The deed is issued by DLD out of the Property Register itself. Article 22 of Law No. 7 of 2006 provides that the Department issues title deeds based on the data recorded in the register, and Article 24(1) gives those deeds absolute evidentiary value in verifying real property rights. On a sale registration, DLD lists the issued documents as an Electronic Title Deed, an Electronic Map and Fee Balances — and under Article 8, electronically recorded documents carry the same evidentiary value as originals, so an e-deed is not a lesser instrument.

Reissue is where the published picture is genuinely thin, and it is worth saying so plainly rather than quoting you figures that may not apply. DLD's standalone "Issue Title Deed" service card lists fees of AED 250 for the certificate, AED 120 for the map, AED 10 knowledge and AED 10 innovation, with a five-minute service time — but it states eligibility as "Emirati Citizen", and lists a copy of the owner's Emirates ID among the required documents. That restriction reads as deliberate rather than as a blank field: DLD populates the same eligibility line with "All" on the Property Sale Registration card, and with "all property owners are eligible to apply for this service" on the Title Deed Modification card. The narrower wording on the reissue card is doing work.

No separate DLD service card covering a lost or damaged title deed appears in DLD's published service catalogue. The cost figures circulating for that process come from law-firm and agency pages rather than from DLD, so none is repeated here. If you are a non-UAE national or a corporate owner and you need a replacement deed, ask DLD's customer happiness centre or a registration trustee office for the applicable procedure and fee in writing before you budget for it — do not assume the AED 250 and AED 120 lines above transfer to you.

Two things do help in the meantime. The free Verify Title Deed service will confirm your registered position from the deed number, certificate year, property type and owner name alone, which is usually what a bank or a counterparty is actually asking for. And Title Deed Modification is a separate service that DLD does open to all property owners, explicitly accepting a valid passport for non-resident owners: it issues a title deed certificate at AED 250 plus AED 10 knowledge and AED 10 innovation in a stated 25 minutes. It is scoped to correcting ownership data — a name, a nationality, a passport number, a date of birth or a place of birth — and not to replacing a lost deed, so it is not a substitute. It does, though, show that DLD's title deed services are not uniformly restricted to UAE nationals, which is the right thing to point out when you ask.

Yes, but the company has to be registered with DLD before the transfer can be processed. Both the Property Sale Registration and the mortgaged-sale service cards carry the same condition: an unregistered entity must first apply for a company registration procedure.

That single line has real timetable consequences. Corporate constitutional documents, evidence of the authorised signatory, powers of attorney and any required attestations or legalisations all have to be in order before the trustee will transact, and for an offshore or overseas holding company that assembly work routinely takes longer than the rest of the purchase. Start it when you go under offer, not when you are ready to complete.

Note also the distinction inside Article 4 itself: companies fully owned by UAE or GCC nationals, and public joint stock companies, sit on the unrestricted side of the line. Any other corporate buyer is treated like any other non-UAE national and is confined to designated plots. If you are still choosing between a mainland and a free zone structure, the trade-offs are set out in mainland versus free zone licensing in Dubai. If you are buying inside a free zone, establish at the outset which registry your title will sit in and which authority issues the deed, because that determines the process, the fees and the dispute route.

There is one, it is statutory, and it is narrow enough that most buyers reading this will not qualify for it. Decree No. 22 of 2022 Approving the Grant of Privileges to Real Estate Investment Funds in the Emirate of Dubai provides at Article 8 that a fund registered on the Register may acquire ownership rights over real property within the areas for ownership by non-UAE nationals — and may also acquire "freehold ownership rights, without time restriction, or usufruct and lease rights for up to ninety-nine (99) years" in real property existing outside those areas, where the property has been designated by the committee formed under Article 9.

Article 9 creates that committee — the Real Estate Investment Funds Committee — and sets a threshold it must verify before designating anything: that "the market value of the Real Property to be owned is not less than fifty million dirhams (AED 50,000,000.0)". The Decree lists further conditions alongside it, covering the investment return the property generates against DLD's criteria, compliance with the rules applying to granted property, and any other requirements DLD prescribes. The committee's chairman, members and terms of reference are set by a separate resolution of the Chairman of the Executive Council.

Read that for what it is before treating it as a way round the designated-area rules. It is a privilege attaching to a registered fund, conditional on a property-by-property designation by a committee, with an AED 50 million floor on market value. It is not a mechanism for an individual, or for an ordinary company, to buy a building outside a designated area — and Article 26 of Law No. 7 of 2006 continues to void arrangements aimed at circumventing the ownership restrictions regardless of how they are dressed up. If a fund structure is genuinely on the table for you, take UAE-licensed advice on registration and on the Committee's process before you commit to a target asset.

Then, as a non-GCC buyer — setting aside the registered-fund route above, which almost certainly does not apply to you — you cannot acquire a registrable interest in it, and the honest answer is to occupy rather than own. The route is an ordinary commercial tenancy, registered on Ejari, governed by Dubai's landlord and tenant regime rather than by the property register.

That is a genuine commercial option, not a consolation prize. Many of Dubai's best-located mainland offices, showrooms and industrial units are held long-term on tenancies, and the rent-review and renewal protections are substantive. What matters is going in with your eyes open on rent increases, notice periods and deposits — covered in Dubai commercial landlord–tenant law — and on the registration mechanics set out in RERA, Ejari and Oqood explained.

What you must not do is engineer around the restriction. Article 26 of Law No. 7 of 2006 states that any agreement or disposition in breach of the law is null and void, and so is any agreement or disposition "made with the intention of circumventing" its provisions — and that invalidity may be invoked by any interested party, by DLD, by the Public Prosecution, or by the court of its own initiative. A nominee holding arrangement is not a clever structure; it is an unenforceable one.

Not for the ownership framework itself. Offices, retail units, showrooms, warehouses and industrial premises follow exactly the same designated-area rules as apartments and villas, because eligibility is a function of the plot, not the use class. What varies is everything downstream of ownership.

Permitted use is the one to check hardest. A title deed that lets you own a unit does not guarantee that the unit's zoning, building classification and landlord rules will support the activity your trade licence names — and a mismatch discovered after completion is expensive to unwind. Confirm the approved use before you sign; how business activity selection dictates your licence, approvals and premises explains how tightly the two are coupled in Dubai. Article 24(2) of Law No. 7 of 2006 is helpful here: any conditions, undertakings or restrictions concerning real property rights must be stated in the record of the real property unit, so the register itself is a place to look for them.

Off-plan purchases are recorded on DLD's Interim Property Register, known as Oqood, until the unit is completed and a title deed can be issued. That mechanism, the escrow protections that sit around it, and the registration steps at handover are covered in full in RERA, Ejari and Oqood: registering Dubai commercial leases and off-plan purchases.

Two things carry over from this guide. The designated-area test applies to an off-plan unit exactly as it applies to a completed one, so run the plot check before you pay a booking fee. And the eventual title deed will be issued out of the Property Register under Article 22 — meaning the same registration fees and the same trustee process arrive later rather than never.

If the purchase is also meant to support a residency application, check the qualifying conditions before you structure the deal rather than after — see the UAE Golden Visa through commercial property investment. Where the premises also has to carry a licensed activity, run the ownership checks alongside the premises due diligence checklist for licensing, because a plot that clears the ownership test can still fail the licensing one. For the end-to-end buying sequence from a foreign investor's perspective, our article on how to buy property in Dubai as a foreign investor sets out the order of events.