3.3 Brokerage Offices: Classification, Registration Requirements and Record-Keeping
Key Takeaways
RERA Circular 13 of 9 August 2015 introduced office classification in Gold, Silver, Bronze and General categories, published to the public from 1 January 2016.
RERA Circular 26 of 31 December 2015 limited the classification to offices licensed for real estate buying and selling brokerage.
Article 15 of Bylaw No. 85 of 2006 requires a broker to keep a register of all transactions and the related documents.
Brokers must keep transaction and customer records for at least five years under the UAE anti-money-laundering rules.
A broker marketing an off-plan project must deposit sale proceeds into the project escrow account and may not deduct commission first (EC Resolution No. 6 of 2010, Article 12).
3.3 Brokerage Offices: Classification, Registration Requirements and Record-Keeping
The "Business of a Broker" module covers the office side of the profession: how an office is set up and registered, how RERA ranks offices, and what records the office must keep. These questions are usually factual, so learn the dates and the scope of each rule.
1. Setting up and registering an office
An office needs a trade licence with a real estate brokerage activity from the Department of Economy and Tourism (or a free zone authority), registration in DLD's Trakheesi system, and practice cards for every broker. DLD's licensing service states that a practice card must be applied for immediately after the real estate licence is approved, and that no person may practise the licensed activity until registered and holding the card for that activity.
Article 6 of Bylaw No. 85 of 2006 lists what a registration application contains:
- A valid trade licence from the competent licensing entity.
- A certificate of membership of the Dubai Chamber of Commerce and Industry.
- Passport copies of the owners (sole establishment) or partners (company).
- The title deed or tenancy contract of the office premises.
- Certificates of good conduct for the owner and the managing director(s).
- Proof that no director or manager has been declared bankrupt or convicted of a crime affecting honour or trustworthiness.
- Certificates of completion of accredited real estate training.
- A certificate of passing the real estate brokerage test prepared by DLD.
DLD's FAQ also notes that the broker's residency must be on the same licence as the office, and that offices are registered automatically when the licence is issued.
2. Office classification: Gold, Silver, Bronze and General
| Circular | Date | Content |
|---|---|---|
| Circular 13 | 9 August 2015 | RERA applies a system classifying brokerage offices as Gold, Silver, Bronze and General, "based on particular criteria", launched to the public from 1 January 2016; offices must update their internal-systems data through the "Offices Classifications" link in Trakheesi |
| Circular 26 | 31 December 2015 | The classification applies only to brokerage firms with the real estate buying and selling brokerage activity |
DLD's FAQ confirms the four classes. The circulars do not publish the scoring criteria, so do not rely on unofficial lists of weightings. The legal hook is Article 44 of the Bylaw, which allows the Committee to classify real estate brokers by specialty.
Note
Leasing-only offices are outside the classification scheme because Circular 26 limits it to buying-and-selling brokerages.
3. The office's duties toward clients and DLD
| Duty | Source |
|---|---|
| Keep a private register of every transaction, keep the documents, and give the parties true copies on request | Bylaw Article 15 |
| Keep the plan or model used for an off-plan sale until the deal concludes | Bylaw Article 15 |
| Provide brokerage information and statistics requested by DLD | Bylaw Article 16 |
| Hold money, securities or items received from a party as a trustee and deliver them as agreed | Bylaw Article 21 |
| Show the broker's name and registration number on correspondence and reports | Bylaw Article 12 |
| Keep customer, transaction and report records for at least five years | UAE AML rules (Federal Decree-Law No. 10 of 2025; Cabinet Resolution No. 134 of 2025; Ministry of Economy circular for brokers) |
Because practice cards and permits are issued through the office's account, violations by agents are recorded against both the broker and the office. DLD's FAQ describes a black-points system that applies to offices and brokers alike.
4. Marketing a developer's off-plan project
Executive Council Resolution No. 6 of 2010 (the implementing bylaw of Law No. 13 of 2008) sets three conditions before an office may market a developer's project (Article 10):
- The project is registered with DLD.
- The developer signs an agreement with a licensed broker in accordance with Bylaw No. 85 of 2006.
- The marketing agreement is registered with DLD.
Article 12 then protects buyers' money: the broker must deposit the sale proceeds into the project escrow account, may not deposit them into its own account, and may not deduct its commission before depositing. Any agreement to the contrary is void. Article 11 also makes any off-plan sale by a developer or broker before the project is approved and registered null and void.
5. Unlicensed intermediaries
An office may not share fees with, or rely on, people who are not licensed and registered: Article 3 of the Bylaw bars anyone from brokerage without a licence and registration, and Article 16 of Law No. 8 of 2007 makes it an offence for a developer to deal with a broker who is not on DLD's register. Offices should check every co-broker's ORN and BRN before signing Form I.
A brokerage licensed only for real estate leasing brokerage asks why it has no Gold, Silver, Bronze or General classification. What is the reason?
Leasing offices are automatically classified as General
RERA Circular 26 of 2015 applies the classification only to brokerage firms with the real estate buying and selling activity
Classification is granted only to offices with more than 50 brokers
Leasing offices must apply to the Department of Economy and Tourism for classification
A developer appoints a brokerage to sell off-plan units. A buyer hands the broker a cheque for the first instalment. The broker proposes to bank it in the brokerage account, deduct its commission and pass on the balance. What does Executive Council Resolution No. 6 of 2010 require?
This is permitted if the developer agrees in writing
This is permitted for the first instalment only
The broker must deposit the sale proceeds into the project escrow account and may not deduct its commission first; any contrary agreement is void
The broker must give the cheque to DLD, which pays the developer
During an inspection, a brokerage cannot produce customer identification files and contracts for sales it closed three years ago because it discards records after title transfer. Which rule has it breached?
No rule: record-keeping ends when the title deed is issued
Only a DET licensing rule on paper storage
The rule that records are kept only if a buyer files a dispute
The obligation to keep transaction records (Bylaw Article 15) and the AML requirement to keep customer and transaction records for at least five years
Sections you finish are checked off in the contents.