Which Company Types Can Hold Dubai Freehold Title

Article 4 of Law No. 7 of 2006 Concerning Real Property Registration in the Emirate of Dubai provides that the right to own real property in the Emirate is restricted to UAE nationals, nationals of the Gulf Cooperation Council member states, companies fully owned by these, and public joint stock companies. It then provides that, subject to the approval of the Ruler, non-UAE nationals may in certain areas determined by the Ruler be granted freehold ownership of real property without time restriction, or usufruct or leasehold for a period not exceeding 99 years.

Two things follow immediately. Companies were contemplated from the start, but the general entitlement runs to companies fully owned by UAE or GCC nationals and to public joint stock companies. Everyone else, including every foreign-owned company, is inside the second paragraph, which is a grant in designated areas rather than a general right.

Regulation No. 3 of 2006 Determining Areas for Ownership by Non-UAE Nationals sets out where the grant applies, and it does so plot by plot against maps issued by the Land Department. The areas named in it include Umm Hurair 2, Al Barsha South 2 and 3, Emirates Hills 1 to 3, Jebel Ali, Al Jaddaf, The World Islands, Ras al Khor, Al Rowyah, Sheikh Zayed Road, Sofouh 1 and 2, Al Quoz 3 and the Al Quoz industrial areas, Mirdif, Dubai Marina, Palm Jebel Ali, Palm Jumeirah, Nad al Sheba and Warsan 1.

That is the original instrument and it has been amended since. The operative point for a buyer is not the historical list but the mechanism: eligibility attaches to the plot, and the Land Department holds the maps. Ask about the plot, not about the neighbourhood's reputation.

The Land Department is the only entity authorised to register real property rights and long-term leases, and transactions that create, transfer, amend or extinguish those rights are not valid unless recorded in the Property Register, which has absolute evidentiary value against all parties. So the practical question is never 'may this company own property' in the abstract. It is 'will the Land Department register this company as the owner of this plot'. A trade licence records what the company may do commercially. It does not answer that question.

Each agreement is between the Land Department and the authority that keeps a company register. The ADGM text refers to the Land Department's own framework, legal controls and registration procedures, so the agreement does not replace its checks. The Masdar City memorandum of 24 July 2025 commits both sides to develop eligibility criteria and the registration procedure. Read it as a framework in preparation.

Jebel Ali Free Zone publishes, among its registration letters, a 'NOC to own property for Land Department', available across its company types including offshore companies, requested through the Dubai Trade portal and quoted at AED 200 plus a small electronic fee. Which of the free zone versus mainland structures you choose changes which registry would issue that letter.

The letter is issued by the registry that holds the company, for use at the Land Department. It is one input, not a guarantee, because the Land Department applies its own framework and procedures. Prepare the company's constitutional documents and evidence of who owns and controls it, and expect further requests on the day.

Registries differ in how far their arrangement has progressed. The ADGM item is a memorandum of understanding, and the Masdar City item sets out work still to be done. Routes are added over time.