10.1 Law No. 6 of 2019: Jointly Owned Property and the Three Management Categories
Key Takeaways
Law No. 6 of 2019 repealed Law No. 27 of 2007 and transferred the rights and obligations of former owners associations to management entities (Articles 49 and 51).
The law applies to all master projects and jointly owned property in Dubai, including special development zones and free zones (Article 3).
Category 1 major projects are managed by the developer and have an owners committee selected by RERA from resident owners (Article 18).
Category 2 hotel projects are managed by a hotel project management company, and an owners committee is formed only if that company wishes.
Category 3 projects are managed by a specialised management company selected and contracted by RERA, with an owners committee appointed by RERA.
10.1 Law No. 6 of 2019: Jointly Owned Property and the Three Management Categories
Most Dubai apartments and many villas sit in jointly owned property (JOP): buildings or communities where owners hold individual units plus a share of common areas. Law No. 6 of 2019 Concerning Ownership of Jointly Owned Real Property in the Emirate of Dubai, issued on 4 September 2019 and in force 60 days after publication, is the law the course's JOP module is built on.
1. What changed from Law No. 27 of 2007
| Point | Law No. 27 of 2007 | Law No. 6 of 2019 |
|---|---|---|
| Owner body | Owners associations | Owners committees appointed or selected by RERA, with defined advisory duties |
| Who manages | Associations, often in practice the developer | Developer, hotel project management company or a management company selected by RERA, depending on category |
| Transition | Rights and obligations of owners associations transferred to management entities (Article 49); all parties had six months to comply (Article 48) | |
| Repeal | Law No. 27 of 2007 repealed; its implementing rules continue only where consistent (Article 51) |
2. Scope and key definitions
- Scope (Article 3): all master projects and jointly owned property in the Emirate, including special development zones and free zones.
- Jointly Owned Real Property: a building with its common parts and the land under it, or land subdivided into units or plots for individual ownership.
- Common Parts: parts shown on the site plan for common use by owners and occupants.
- Designated Common Parts: parts, connections or facilities designated for the exclusive use of certain owners.
- Common Facilities: areas on a master plan (gardens, streets, pools, playgrounds, public car parks, beaches and similar) owned by the developer for common use across a master project.
- Service Charges (paid by owners for managing, operating, maintaining and repairing the jointly owned property) vs. Usage Charges (paid to the master developer for common facilities in the master project).
- Management Entity: the body in charge of management, which may be the developer, a management company or a hotel project management company.
3. Registers and documents
- DLD keeps a Jointly Owned Real Property Register listing developers' plots, units and owners, owners committee members, building management regulations, plans, management entities and their contracts, and the area of common parts (Article 4).
- The plans, master community declaration, statute and building management regulation form part of the title deed of jointly owned property (Article 6). The developer files them with DLD within 60 days of the completion certificate (extendable by up to 30 days).
- Every occupant must comply with these documents to the extent they apply.
4. The three management categories (Article 18)
| Category 1: Major Projects | Category 2: Hotel Projects | Category 3: Other projects | |
|---|---|---|---|
| Which projects | Designated under criteria set by the DLD Director General | Projects licensed as hotel establishments (hotels, hotel villas, hotel apartments, hotel rooms) | All other jointly owned property |
| Who manages common parts | The developer (it may outsource to a management company under an agreement approved by RERA) | A hotel project management company to which the developer must outsource | A specialised management company selected and contracted by RERA |
| Owners committee | Yes, members selected by RERA from owners residing in the property | Only if the hotel management company wishes; the committee may not take part in managing the project | Yes, members appointed by RERA |
| Building management regulation | Issued by the developer and approved by RERA before units are sold (Article 20) | Issued by the developer and approved by RERA | Issued by RERA if none exists |
Two further rules complete the picture:
- Mixed projects (Article 18(b)): where a property combines Category 2 and Category 3 parts, the common parts are managed by the hotel project management company and there is a single owners committee.
- No developer (Article 18(d)): if a Category 1 or 2 project has no developer, RERA appoints a management company.
5. Master communities and common facilities
Separate from the building categories, Article 19 makes the master developer responsible for the common facilities of a master project (roads, parks, lakes and similar), which it must outsource to a management company under an agreement approved in advance by RERA. The master developer collects usage charges for them (Article 26). An apartment owner in a master community may therefore pay service charges for the building and usage charges for the master community.
6. Why brokers need this
- Before listing, identify the category and the management entity, because they determine who issues service-charge statements and NOCs.
- Explain to buyers that service and usage charges must be approved by RERA (Article 27) and that unpaid charges block a sale (Article 32).
- For hotel apartments, warn buyers that owners have little say in management: the committee, if any, cannot participate in managing a Category 2 project.
A developer completes a conventional 250-unit residential tower in Jumeirah Village Circle that is not a designated major project or a hotel project. Its in-house team starts issuing service invoices on company letterhead. Under Article 18 of Law No. 6 of 2019, how should the common parts be managed?
The developer manages it as a Category 1 project without RERA involvement
It is a Category 3 project, managed by a specialised management company selected and contracted by RERA
A hotel operator licensed by DET must manage it
The developer may self-manage for five years during the defects period
What happened to the rights and obligations of owners associations formed under Law No. 27 of 2007 when Law No. 6 of 2019 came into force?
They became corporate companies with expanded borrowing powers
They were transferred to the original developers for 15 years
They were transferred to management entities, and Law No. 27 of 2007 was repealed
They were transferred to the Rent Disputes Settlement Centre
An investor owns studios in a branded hotel-apartment project managed by a hotel project management company and demands that an owners committee be formed to run housekeeping and pool contracts. What does Law No. 6 of 2019 provide?
A committee must be formed on demand by any owner holding 1% of the area
A committee is formed only if the hotel project management company wishes, and even then it may not participate in managing the project or its common parts
Owners committees run all three categories
The committee elects the hotel general manager every two years
In a Category 1 major project, who manages the common parts and how is the owners committee formed?
A management company chosen by the owners at a general meeting, with an elected board
The hotel project management company, with no committee
The RDC, with a committee of judges
The developer manages them (and may outsource with RERA approval), and the owners committee is selected by RERA from owners residing in the property
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