Is permission required to operate a property-listing platform in the UAE?

No, you cannot launch this platform under the activity of "software company" only. Doing so will expose your company to hefty financial penalties (which could reach hundreds of thousands of dirhams) and the immediate shutdown of the platform.

Launching a real estate platform in a developed legislative environment like the UAE requires legal precision that goes beyond mere programming; it involves complex real estate compliance and avoiding legal liability for false advertisements.

As your legal advisor, I am pleased to offer the following services to ensure a safe and legal launch for your platform:

• Modifying the legal structure: I will guide you in amending your business license, adding the required digital real estate activities, and obtaining approvals from (DLD/RERA) or the Department of Municipalities and Transport.
• Drafting the platform's "Terms and Conditions": Drafting legal agreements that protect your platform from liability in case intermediaries enter incorrect data, while ensuring compliance with the new 2025 real estate advertising laws.
• Data protection file management: Preparing a comprehensive privacy policy that complies with the UAE Personal Data Protection Law, to ensure the legality of collecting and processing ORN and BRN numbers.
• Representation before regulatory authorities: I will take on your behalf the correspondence with the relevant authorities to obtain operating permits and connect the platform to government systems to verify real estate permits.

Investing in the correct legal foundation now will save you substantial amounts in regulatory fines later. I am pleased to start immediately reviewing your technical business model and ensuring its compliance with the law.

At the London Center for Legal Consultancy, we are committed to the highest standards of professionalism in providing legal advice, and we strive to offer the best solutions.

A brokerage license from RERA is required if the platform engages in any of the following:

• Taking a commission from the buyer/lessee
• Negotiating prices
• Communicating with clients on behalf of agents
• Managing, selling, or renting properties
• Acting as a broker, directly or indirectly

We need to study the case and see the appropriate trade license to acquire for each activity. It can't be under the software license only, as there are other trading activities.

Hello,

In Dubai and other Emirates, publicly listing properties requires a RERA-approved real estate portal license; operating solely under a software company without this license is not permitted.

We can also assist you in obtaining the necessary licenses to operate your platform legally.

Please feel free to contact us if you require any further assistance.

ISN Legal Consultancy

Greetings,

Thank you for your inquiry regarding the launch of your property-listing platform.

In the UAE, operating a platform that publishes real estate listings generally requires regulatory compliance beyond a standard software license. While collecting ORN, BRN, and Permit IDs is essential, it does not by itself exempt the platform from regulatory oversight.

Depending on the exact business model (advertising only vs. brokerage-related activities), you may need:

• Approval or coordination with the Dubai Land Department (DLD) and RERA,
• A correctly structured trade license activity that covers real estate advertising portals,
• Compliance with regulations related to online property advertising and data publication.

Launching without the proper approvals may expose the company to penalties or platform suspension.

To assess whether you can proceed under your existing software license or if additional approvals are required, we recommend a legal review of your platform structure before launch.

You may book a consultation through the website or appoint our office to handle the full regulatory and licensing process on your behalf, depending on your needs.

We will be pleased to assist you further.

Be advised that launching a property-listing platform in the UAE requires compliance with real estate regulations, even if it is operated under your software company.

Platforms that list properties for sale or rent are considered real estate intermediary activities and may be regulated by authorities such as the Dubai Land Department (DLD) / RERA. While collecting ORN, BRN, and Permit IDs is standard, you must verify these documents and comply with UAE data protection laws.

You cannot operate the platform freely without a DED-approved real estate listing license or written confirmation from the relevant authority that your platform is exempt. To ensure full compliance, obtain the necessary approvals, verify all agents and properties, and include clear disclaimers in your terms of use.

For more details and direct guidance, please share your WhatsApp number so we can review your case and assist you.

Greetings from Dr. Khalifa Bin Huwaiden Advocates & Legal Consultants.

Launching such a platform may require legal review and obtaining the relevant approvals. If you wish, we can proceed by obtaining a Power of Attorney from you to conduct a full legal assessment and coordinate with the relevant authorities to ensure the platform is launched in compliance with the law.

OUR LEGAL TEAM is ready to provide online legal assistance whenever you need it.

Thank you for reaching out and for sharing the details of your situation with us.

You cannot launch a real estate platform in the United Arab Emirates without ensuring compliance with all applicable regulatory and legal requirements. Having your company licensed in the commercial registry alone is not sufficient if the platform lists properties or handles data of real estate brokers.

It is essential to ensure that your company’s activity is properly registered in accordance with real estate activities or operating real estate listing platforms, that all listings on the platform come from licensed brokers or companies with the required official numbers (ORN / BRN / BLN), and to obtain all necessary permits for online real estate advertising from the competent authorities in the respective Emirate (such as the Land Department, RERA, ADREC/DARI), depending on the platform’s scope and location.

We are ready to provide full legal support to assist you in completing all procedures and understanding the detailed requirements for each Emirate, ensuring you receive the correct legal advisory before launching the platform.

Greetings,

Reference to your inquiry regarding the launch of an electronic platform for listing real estate properties, where agents and real estate agencies will be able to post their properties and collect the ORN, BRN, and Permit ID for each property, we hereby inform you of the following in accordance with the laws and regulations applicable in the United Arab Emirates:

Launching the platform under a software company only

The platform can be launched if it operates solely as a technical service provider for licensed brokers, without publishing real estate advertisements directly to the public. In this case, the platform may operate under the existing company license without the need for additional real estate licensing, provided that each broker or real estate agency participating on the platform is duly licensed in accordance with the applicable regulations.

Publishing real estate listings directly to the public

If the platform publishes properties directly to the public and facilitates the connection between sellers and buyers or tenants, this activity falls within the scope of regulated real estate activities under UAE law. Accordingly, the following are required:

• Obtaining an electronic license / real estate portal license from the Department of Economic Development (DED) or the competent authority in the relevant Emirate.
• Complying with the requirement to obtain a Permit ID for each property listing in accordance with applicable regulations in Dubai (DLD/RERA) or Abu Dhabi (ADREC/Madhmoun).
• Ensuring that all brokers or real estate agencies listed on the platform hold valid and active licenses.

Legal Recommendations

• Define the nature of the platform: whether it will be a technical service only or a public-facing real estate portal.
• Review all participating brokers and ensure the validity of their licenses.

Conclusion

The platform may operate under the existing company license if its role is limited to providing technical services to licensed brokers. However, if the platform publishes properties directly to the public, UAE law requires obtaining the necessary licenses and complying with all regulatory requirements applicable to the real estate market.

If you need any assistance, feel free to contact us.

There is more than one legal route to launch a property-listing platform in Dubai, andd the correct path depends on how the platform is positioned and used in practice. We previously handled a partially similar case where a tech company launched a listings portal under a software licence, but the activity was later classified as real estate advertising, and we secured a favorable outcome for our client by restructuring the model and aligning it with the required compliance framework.

If your platform publicly displays property listings, generates leads, or markets real estate to the public, it is not treated as software only. In such cases, the platform itself is seen as enabling real estate marketing, even if you collect ORN, BRN, and Permit ID from agencies. The silent risk is that relying solely on collecting these numbers does not protect the platform owner from liability if any listing is found non-compliant. The expected position from the authorities is that the platform must have its own compliant structure governing verification, display, and removal of listings.

If, however, the platform is structured strictly as a closed SaaS system used internally by licensed agencies, with no public advertising, no lead generation, and no promotional exposure, it may operate under a software licence. This boundary must be clearly reflected in the platform design, terms of use, onboarding process, and commercial positioning. Our office focuses on defining this boundary precisely to avoid reclassification risk.

The accurate answer requires reviewing your full business model, including whether listings are public, how leads are generated, how permits are verified, and how the platform is marketed. RASHID ALKAITOOB ADVOCATES & LEGAL CONSULTANTS, based in Dubai for 12 years, has handled similar platform structures and can identify the most suitable compliance route for your project. We provide a free 20-minute listening session for an initial file assessment, not a legal consultation, depending on complexity. Our consultants speak Arabic, English, Russian, Hindi, and Chinese.

This response is provided by Rashid Al Kaitoob Advocates & Legal Consultants based solely on the information you’ve provided and does not constitute a final legal opinion. A binding legal assessment can only be given after reviewing the full documents of the case.

You can launch the platform under your software company without additional approval as long as you:

• Do not act as a broker.
• Only allow licensed agencies/agents to list properties.
• Verify their licenses and include proper legal disclaimers.

Dear Questioner,

Thank you for reaching out regarding your proposed property-listing platform.

Any platform that facilitates the advertisement and listing of real estate properties must comply with the regulations set by the relevant authorities, including the Real Estate Regulatory Agency (RERA) in Dubai and other emirate-specific real estate regulatory bodies. Since your platform will collect and display ORN (Owner Registration Number), BRN (Broker Registration Number), and Permit ID for each property, it falls within the scope of regulated real estate activities.

While your company can operate as a software company, the collection and public display of real estate listings may require prior approval or licensing from the relevant authorities. Launching without such approvals could expose your company to penalties or enforcement action.

The usual process involves:

• Submitting an application to RERA or the respective regulatory authority in the relevant emirate.
• Demonstrating compliance with listing, data, and licensing requirements.
• Obtaining an official permit to operate the platform legally.

We understand that navigating these approvals can be complex and time-consuming. If you wish, our firm can assist you with the entire process, from preparing the necessary documentation to obtaining the required permissions, allowing you to launch your platform without regulatory concerns.

Please let me know how you would like to proceed.

Kind regards,

Mohammad Salah, Legal Consultant