Can I Combine Several Properties, and What About Off-Plan or Mortgaged?

This is the rare point on which the federal and emirate surfaces agree, in their own words and without qualification.

No authority publishes a cap on the number of properties that may be counted. That is an absence rather than a permission, but it is a consistent absence across every surface.

Nor does any authority publish a restriction by property type on the golden route. GDRFA states that mortgaged property is acceptable “and includes all types of properties”. Assertions that commercial property, or land, or a particular category is excluded from the golden route are not sourced to anything published, making it crucial to understand what is UAE trade licence requirements.

The properties do have to sit in the applicant's name. Both the Dubai Land Department formulations above say so explicitly — wholly owned by the investor, under the name of the applicant, which is similar to the requirements for licensing an entity to trade onshore.

This is where families most often assume a rule that exists on a different product. Three routes, three different treatments of a shared holding.

On the golden route, GDRFA is explicit and it is the strict one: “If the ownership is in the form of a share in a joint property, the value of the share must not be less than AED 2 million.” The share itself has to clear the full threshold, similar to the requirements when deciding on where the licence should be based.

On the retiree route, the Dubai Land Department publishes the opposite accommodation: “A husband and wife can share one property (providing a certified copy of the marriage contract).”

On the two-year investor route, the department sets a much lower bar for a co-owner: “A co-owner of the property is allowed to apply for the issuance of a license and residence visas for property investors, provided that their share value is not less than AED 400,000.”

The consequence is worth stating plainly, because it disappoints a lot of couples. No authority publishes any rule permitting two spouses to combine individually sub-threshold holdings to reach AED 2 million on the golden route, and the one explicit golden-route rule on joint shares reads against it. How a family actually gets onto one file is a structuring question, not a rule you can look up.

ICP's guide requires ownership of properties “valued at ≥ AED 2 million (without loans)”, and its service card restates that as a term: “The property must be fully owned by the investor.” Taken at face value that excludes mortgaged property outright.

Both Dubai surfaces say the opposite in terms. The Dubai Land Department's investor service states: “In the event that a mortgaged property, a bank letter indicating 2 million AED paid amount as a proof to be provided”, and among its service terms, “The property may be mortgaged, and a no-objection bank letter to be submitted indicating that the bank does not object to issuing a residence permit on the property, indicating the paid amount and the balance.” GDRFA states simply that “mortgaged property is acceptable”, and on its property-owner page that “if at least 2 million Dirhams of the value of the property are paid, the owner is entitled to obtain golden residency.”

What the operational surfaces test, then, is an absolute amount paid in, evidenced by a bank letter — not unencumbered title. Those two positions can be reconciled by reading “without loans” as meaning that the qualifying AED 2 million must not itself be borrowed, but no authority publishes that reading and we are not going to assert it as though one did.

Two related figures circulate and neither is published. There is no minimum down-payment percentage anywhere on these pages — every published test is an absolute dirham amount paid, never a proportion. And no authority publishes a list of approved or specific mortgage banks; GDRFA's property-owner page refers to “a loan from a local bank in the country” without naming any.

The retiree route shows the same structure with a lock-up added, which is worth knowing because clients hear it and apply it to the wrong route: where that property is mortgaged, the Dubai Land Department requires a bank letter indicating that “the deposit cannot be released within 3 years”.

We looked for this specifically, on every surface, and it is not there. ICP's golden residency guide and its real-estate service card do not mention off-plan. The UAE government portal's golden visa hub does not mention it. GDRFA's golden residence permit for investors does not mention it. The Dubai Land Department's golden visa investor service does not mention it.

The department's FAQ page does use the phrase off-plan nine times — and every one of them is about developer escrow accounts under Law No. 8 of 2007, or about initial registration, meaning “registering real estate sales contracts and other legal actions off-plan before transferring them to the real estate registry”. None of them is about residency.

The widely-repeated claim that off-plan purchases from approved developers count toward the AED 2 million traces back to a UAE government portal page that no longer exists. Three legacy portal URLs still carried in search results returned 404 when we checked them, and the surviving investor-visa page is a stub containing no reference to AED 2 million, off-plan, mortgages or loans. The portal currently publishes nothing about the property route beyond a single summary table row.

So the position is not that off-plan is excluded. It is that no authority has published a pathway, and that the citation everybody passes around points at a dead page. There is one adjacent published signal worth noting: ICP's property-owner renewal documents ask for a municipality certificate confirming “completion of construction, full ownership, and suitability of the property for residence” — which is a different route, but it is a reminder that completion appears as a condition where the authorities do address it.

Anyone holding or considering a provisionally registered unit needs the position established on their specific facts before they commit money to it. That is not a hedge; it is the only responsible thing to say about a question the authorities have left blank.

Aggregation being permitted does not tell you which properties to put forward, whose name they should sit in, or how a joint share ought to be structured given that the golden rule and the retiree rule point in opposite directions.

A mortgage being acceptable to the Dubai surfaces does not tell you what a bank's no-objection letter needs to say, how the mortgage sits with the lien registered for the term, or what accepting that combination means for a client who may want to refinance. Those are the parts that decide a file, and they are worked out on the facts with an adviser.