ADGM Landlord Guide — Registration, Management and Eviction Under the 2024 Regulations

The ADGM Real Property Regulations 2024 created a dedicated Short-Term Residential Lease (STRL) regime for property within the ADGM Area on Al Maryah Island. (s.182) If you own or manage residential property inside that boundary, every aspect of your letting relationship — from the day you collect a reservation deposit to the day you return the keys — is governed by these rules. This guide sets out, in plain terms, what the RPR 2024 requires you to do, what it forbids you from doing, and what happens when you get it wrong.

1. The STRL regime — what it covers and where it applies

The Short-Term Residential Lease regime established by section 182 of the RPR 2024 applies exclusively to residential leases of property physically situated within the ADGM Area — the demarcated zone on Al Maryah Island, Abu Dhabi. Commercial leases within the ADGM Area, and residential leases of property located outside it (even if both parties are ADGM-registered entities), fall under different provisions of the RPR 2024 or outside its scope entirely.

The regime imports English common law principles through the ADGM's application of English law, supplemented by the specific STRL provisions. This means that landlords familiar with DIFC residential leasing will find many parallels, but the ADGM rules differ in material respects — particularly on deposit mechanics, notice periods and the eviction process.

2. Your right to let — are you entitled to grant this lease?

Before you sign anything, confirm your entitlement. The RPR 2024 limits who may grant a residential lease within the ADGM Area:

• Registered freehold owners: you must hold a registered freehold interest in the property confirmed on the ADGM Land Register.
• Holders of a superior lease: if you hold a long leasehold interest, check whether your superior lease expressly permits subletting. A clause that is silent on subletting does not permit it under ADGM law.
• Property managers: any person acting as property manager on your behalf must hold a valid Power of Attorney lodged with the ADGM Registrar. (s.133) An informal arrangement or an email authorisation is not sufficient.

3. Registration — the 30-day duty that most landlords underestimate

Registration is not optional and it is not administrative housekeeping. An unregistered lease is unenforceable. The RPR 2024 creates two distinct registration obligations:

New leases

Section 43(1) requires registration of a new lease within 30 days of the date of execution. The clock runs from the date the lease is signed, not the commencement date.

Renewals

Section 43(2) applies the same 30-day window to each renewal. If the original lease expires and is renewed on agreed terms, you have 30 days from the renewal date to register. A renewal that is not registered is treated as a new lease at renewal rates — which, if the gap exceeds 90 days, will attract higher registration fees.

Approved form and fees

Registration must be in the approved form and accompanied by the applicable fees. (s.44) For leases of 25 years or less — which covers all standard residential lettings — the fee structure under section 44(3) consists of:

• A one-time service fee (payable on each registration, including renewals); plus
• Annual authority fees paid via the utility provider for the property.

The precise fee schedule is published by the ADGM Registration Authority and updated periodically. Always check the current schedule before submitting.

Late registration

Missing the 30-day window triggers late filing fees under section 148. These are not nominal — they accumulate on a per-day or per-period basis. More significantly, a lease that remains unregistered cannot be produced as evidence in enforcement proceedings before the ADGM Courts without explaining the failure to register.

4. Deposits and payments — what the law says the landlord can and cannot do

The RPR 2024 imposes precise rules on every category of pre-lease and lease payment. Landlords who depart from these rules — even informally and even with the tenant's apparent agreement — face liability for the excess amount plus interest.

Security deposit — maximum and trust character

You may collect a security deposit of no more than 5% of the annual rent. (s.53) If annual rent is AED 200,000, the maximum security deposit is AED 10,000. Demanding more than 5% is unlawful regardless of whether the tenant agrees to pay it.

Critically, the security deposit is held on trust for the tenant. It does not become your money upon receipt. You may not commingle it with your own funds, spend it, or treat it as income. The obligation is to hold and return it (less any lawful deductions) at the end of the tenancy.

Permitted deductions from the security deposit

You may deduct from the security deposit only for:

• Unpaid rent at the end of the tenancy;
• Breach of the lease by the tenant;
• Damage to the property beyond fair wear and tear; and
• Repairs that are the tenant's responsibility under the lease.

Fair wear and tear is not defined in the RPR 2024, but ADGM Courts applying English common law will treat it as the ordinary deterioration from reasonable use over the lease term. Scuffs, minor marks, and faded paintwork from normal occupation are fair wear and tear. A broken window or a stained carpet caused by the tenant are not.

The 21-day itemised notice requirement

Section 53(1)(c) requires that, if you intend to make any deduction from the security deposit, you must serve an itemised written notice on the tenant within 21 days of the end of the tenancy, supported by evidence (invoices, photographs, condition reports). The notice must specify each item claimed and the amount. Any sum not included in that notice, or for which evidence is not provided, cannot be deducted. The balance must be returned within the same period.

Reservation deposit — what you can and cannot collect

Before a lease is signed, you may collect a reservation deposit of no more than 5% of the annual rent from one prospective tenant per property. (ss.55(5), 55(6)) You may not take reservation deposits from multiple applicants simultaneously — one per property is the rule.

The reservation deposit must either be:

• Set off against the first rent instalment when the lease is signed; or
• Returned to the prospective tenant in full if no lease is agreed.

There is no basis in the RPR 2024 to forfeit the reservation deposit as "admin fees" or to retain it if you (rather than the prospective tenant) decide not to proceed.

Rent receipts — mandatory

Section 55(4) requires you to issue a rent receipt for every payment received. This applies regardless of the payment method — bank transfer, cheque, or cash. You must keep records of all receipts for a minimum of one year after the end of the tenancy. Failure to issue receipts is a compliance breach and can undermine your position in a rent dispute.

Payment schedule — must be in the lease

The lease must state the rent amount, the payment method, and the frequency of payments. You cannot impose a different payment schedule during the lease (for example, switching from quarterly to monthly) without a formal variation registered under section 46(1).

5. Lease form requirements — clarity, condition and cost

Section 52 sets out specific requirements for the lease document itself:

• Clear and concise language: the lease must be written in plain English (or Arabic where applicable) that a reasonable person can understand. (s.52(1))
• Condition report: a condition report must be prepared at handover and countersigned by both parties. (s.52(1)(b)) This is the single most important document in any future deposit dispute — it fixes the agreed state of the property at the start of the tenancy. Skipping it leaves you without a baseline.
• Cost of drafting: section 52(2) places the cost of drafting the lease on the landlord. You cannot recover drafting costs from the tenant or make them a condition of signing.

6. Repair and maintenance — who is responsible for what

Section 56 of the RPR 2024 sets out a clear allocation of repair and maintenance obligations. Understanding this allocation is essential: disputes over repairs are among the most common — and most expensive — landlord-tenant disagreements in the ADGM.

Landlord's obligations

You are responsible for maintaining and repairing:

• The structure and fabric of the building;
• The façade, external walls, roof and foundations;
• All external doors and windows;
• Air conditioning systems and ventilation;
• Utility connections serving the property (water, electricity, drainage);
• All mechanical, electrical and plumbing (MEP) systems within the property.

The overriding obligation is to keep the property safe and fit for residential use throughout the term. If the property becomes unsafe or unfit for habitation through disrepair, the tenant has remedies including the right to terminate.

Tenant's obligations

The tenant must keep the property clean and in good order, and must not cause damage beyond fair wear and tear. The tenant is responsible for minor day-to-day upkeep that falls within that standard.

Tenant self-help repairs — the two-tier rule

Section 56(2) establishes a practical self-help mechanism for urgent repairs:

• Up to AED 5,000: the tenant may carry out the repair themselves (or instruct a contractor) and bill you for the cost, without needing your prior consent. You must reimburse.
• Above AED 5,000: the tenant needs your written consent before proceeding. Without that consent, costs may not be recoverable.

This rule is designed to prevent landlords from ignoring repair requests and leaving tenants in unacceptable conditions. If you are unresponsive to repair notices, you create the conditions for a unilateral repair and a bill you cannot contest.

Utility cutoff — never an option

Section 59(4) expressly prohibits you from cutting or disconnecting utilities to the property. This prohibition is absolute — it applies even if the tenant owes rent, even if the tenant has breached the lease, and even during an eviction process. Cutting utilities is not a pressure tactic; it is a breach of the RPR 2024 that converts your enforcement position into a counterclaim by the tenant for damages, injunctive relief, and potentially punitive remedies.

7. Access to the property — prior written notice required

Section 57 restricts your right to enter the property during the lease term. You may only enter:

• To carry out repairs or maintenance;
• During the final 30 days of the lease, for the purpose of showing the property to prospective tenants; or
• For the purpose of a sale or valuation.

In all cases, prior written notice must be given to the tenant — except in genuine emergencies (for example, a burst pipe or fire risk). What constitutes a reasonable notice period is not defined in s.57, but ADGM Courts applying English common law will typically regard 24-48 hours as reasonable for non-emergency access.

Entering the property without notice or outside the permitted purposes constitutes a breach of quiet enjoyment, entitling the tenant to damages.

8. Rent increase rules — strict compliance is not optional

This is the area where landlords most frequently lose in court. The RPR 2024 contains two separate regimes for rent increases: one for the existing term, and one for renewal.

During the lease term

Section 55(2) prohibits any rent increase during the term of a lease unless the lease itself expressly states the amount of the increase and the timing at which it will take effect. A clause that says "rent may be reviewed annually" is not sufficient — the increase mechanism must be certain and explicit. In the absence of such a clause, you cannot raise the rent until the lease expires.

On renewal

Section 61 caps any rent increase on renewal at 5% and requires that written notice of the proposed increase be given to the tenant at least 90 days before the expiry of the current term. An increase notified with less than 90 days' notice, or in excess of 5%, is unenforceable — the tenant may refuse to pay the excess and the court will not order it.

Common landlord mistakes that lose in court

• Sending a rent review letter mid-term without an express contractual basis;
• Notifying a renewal increase less than 90 days before expiry and expecting it to take effect;
• Proposing an increase above 5% on renewal and negotiating from there — if the tenant does not agree, you cannot impose it;
• Treating the renewal as a new letting and attempting to set market rent — if the same tenant is staying, s.61 applies.

9. Renewal — registration obligations and de-registration if not renewed

Under section 60, renewal of a residential lease requires mutual agreement. There is no automatic right of renewal for either party. If both parties agree to renew:

• The renewal must be registered within 90 days of the expiry of the previous term. (s.60) Registration after 90 days treats the arrangement as a new lease, which attracts higher fees and requires fresh compliance with all STRL requirements.
• If the lease is not renewed and you do not apply to de-register the property within 90 days of expiry, the property may be marked as vacant on the Register — which affects your ability to collect the annual authority fees through the utility provider.

If you decide not to renew and the tenant will be vacating, you must apply to de-register the lease within 90 days of the end of the term. This is an active obligation — the Register does not update automatically.

10. Selling the property while a lease is in place

Section 64 addresses the position of a landlord who wishes to sell the property with a sitting tenant. The key points are:

• You do not need the tenant's consent to sell the property. The lease does not give the tenant a right of pre-emption or a right to block a sale.
• The new landlord (purchaser) is automatically bound by the existing lease — they take the property subject to all the tenant's rights and your obligations under the RPR 2024.
• You must notify the tenant in writing of the new landlord's name and contact details promptly upon completion.
• The security deposit is deemed transferred to the new landlord on completion. You cannot retain the deposit as part of the sale proceeds. If you do, you remain liable to the tenant for the deposit amount.
• All your liabilities as landlord up to the date of sale are assumed by the purchaser from that date — though you may retain liability for any breach committed before completion.

11. Appointing a property manager — what changes and what does not

Section 65 of the RPR 2024 is a trap for landlords who believe that appointing a professional property manager transfers responsibility. It does not. The appointment of a property manager:

• Does not relieve you of any obligation as landlord under the RPR 2024;
• Does not break the liability chain — if the manager breaches the deposit rules, the notice rules, or the repair obligations, you are liable;
• Means the tenant is entitled to treat any act or omission of the property manager as an act or omission of the landlord, unless you have notified the tenant in writing that the manager does not have authority for a specific matter.

The practical implication: vet your property manager carefully, ensure they understand ADGM STRL requirements, and do not assume that placing a manager between you and the tenant creates any legal insulation.

Remind yourself: the manager's Power of Attorney must be lodged with the ADGM Registrar under section 133. A PoA that has not been lodged means the manager has no formal authority to act on your behalf in relation to registered instruments.

12. Eviction — the correct process and what you must never do

Eviction under the STRL regime is a process-driven area where departing from the rules has severe consequences. The RPR 2024 distinguishes between termination without court order and termination requiring court order.

Termination without a court order — limited circumstances

Section 62 permits termination without court proceedings in four situations only:

1. Mutual surrender: the landlord and tenant agree in writing to end the lease early. The surrender must be registered under section 49. Verbal agreement is insufficient.
2. Exercise of a break option: if the lease contains a valid break clause that has been properly exercised by either party in accordance with its terms.
3. Property destroyed or rendered uninhabitable: if the property is substantially destroyed and cannot be used, the lease terminates by operation of law — but you must refund any unearned rent paid in advance.
4. Tenant terminates on landlord breach: if you have materially breached your obligations (for example, by failing to carry out structural repairs after notice) the tenant has the right to terminate and claim damages.

Termination requiring a court order — the three routes

Section 63 requires you to obtain a court order for eviction in the following circumstances:

Notice drafting requirements

Eviction notices must comply with strict formal requirements under the RPR 2024 service provisions:

• The notice must be in writing and state the breach with specificity — a general "you are in breach" is not sufficient;
• The remedy period must be stated clearly;
• The notice must be sent to the address specified in the lease. (s.159) Sending to a different address, even one you know the tenant uses, creates a service risk;
• A notice served after 5pm or on a non-business day is treated as served on the next business day. (s.160) This extends the notice period accordingly and means your remedy window runs from that next business day, not the day of actual delivery.

Relief from forfeiture

Even after a court order is obtained, section 50 of the RPR 2024 preserves the tenant's right to apply for relief from forfeiture. The court has discretion to grant relief — typically conditional on payment of all arrears and costs — and this can delay recovery of possession. This is not unusual in common law systems and should be factored into your timeline expectations.

What you must never do

13. Variation of the lease — the 7-day registration window

Any agreed variation of a registered lease — whether to the rent amount, the term, the permitted use, or any other material term — must be registered with the ADGM Land Registry within 7 days of the date the variation is agreed. (s.46(1)) An unregistered variation is unenforceable against a third party (including a purchaser of the property) and may be unenforceable between the parties in certain circumstances.

The 7-day window is very short. If you agree a rent reduction mid-term to retain a good tenant, register the variation immediately — do not leave it to the end of the month.

14. Goods left behind by the tenant

Section 51 addresses the situation where a tenant vacates and leaves personal property behind. You are not entitled to simply dispose of abandoned goods or treat them as your own. You must:

• Allow a period of 30 days from the date of termination or expiry of the lease to elapse;
• Take reasonable steps to notify the tenant that goods remain at the property;
• After 30 days, you may arrange for disposal — but disposal in this context means proper removal and, where goods have value, appropriate steps to account for that value. Selling the goods and pocketing the proceeds creates a separate liability.

15. Landlord red lines — what will lose in court

The following is a consolidated reference of the conduct that the ADGM Courts have consistently found against landlords. These are not grey areas:

16. Key deadlines cheat sheet

17. Registration fees — what landlords pay

The RPR 2024 and the ADGM Registration Authority's published fee schedule set out the following cost structure for residential lease registration. Note that fees are revised periodically; always verify the current schedule with the ADGM RA before submitting:

• New lease registration (≤25 years): one-time service fee per lease + annual authority fees via the utility provider. (s.44(3))
• Renewal registration: same fee structure as a new lease. Renewals registered within 30 days attract the standard rate; late registration attracts the standard rate plus late fees under s.148.
• Variation registration: service fee for lodging the variation document.
• Surrender registration: service fee for lodging the surrender instrument.
• Late filing fees (s.148): accruing from the day after the registration deadline, at a rate specified in the fee schedule. The practical lesson is that the cost of late registration almost always exceeds the cost of timely registration.

The landlord bears the cost of registration under the RPR 2024. You may not pass the registration fee to the tenant as a condition of signing.

18. Practical onboarding checklist for new ADGM landlords

Use this checklist when taking on a new residential letting within the ADGM Area. Tick each item before handing over keys.

1. Confirm your title
   • Obtain a current title search from the ADGM Land Registry
   • Confirm the property is within the ADGM Area
   • Check your superior lease (if applicable) expressly permits subletting
2. Property manager appointment (if using one)
   • Execute a written PoA in favour of the manager
   • Lodge the PoA with the ADGM Registrar under s.133
   • Brief the manager on STRL requirements
3. Pre-lease
   • Take reservation deposit: no more than 5% of annual rent; one applicant only
   • Issue a written receipt for the reservation deposit
   • Prepare the lease in the approved form: clear language, payment schedule, break rights if any, mid-term increase clause if intended
   • Include landlord's contact details and the address for service of notices
4. Lease execution and handover
   • Execute the lease — both parties sign
   • Complete a detailed condition report at handover; countersign with tenant
   • Photograph every room and each surface — date-stamp photographs
   • Collect security deposit: no more than 5% of annual rent; issue receipt
   • Set off reservation deposit against first rent instalment
5. Registration (within 30 days of execution)
   • Submit registration form in the approved format
   • Pay applicable registration fee and annual authority fees
   • Obtain confirmation of registration from the ADGM Land Registry
6. During the term
   • Issue rent receipts for every payment
   • Keep records of all receipts for at least one year post-tenancy
   • Respond to repair requests promptly — sub-AED 5,000 repairs may be done by tenant and billed to you without consent
   • Give prior written notice before any access
   • Never cut utilities regardless of non-payment
7. Approaching expiry (90 days before end of term)
   • Serve written rent increase notice if renewal increase intended (max 5%)
   • Negotiate renewal terms with tenant
   • Diarise the 30-day renewal registration deadline from the renewal date
8. End of tenancy
   • Conduct exit condition inspection with tenant; countersign exit report
   • Photograph property on exit; compare with handover photographs
   • Within 21 days: return deposit in full OR serve itemised deduction notice with evidence
   • If not renewing: apply to de-register lease within 90 days of expiry
   • If tenant leaves goods: notify tenant; wait 30 days before disposal

Frequently asked questions

This article is for general information only and does not constitute legal advice. The ADGM Real Property Regulations 2024 and ADGM Registration Authority fee schedules are subject to amendment. For advice specific to your property or tenancy, please contact us. Last updated: 18 May 2026.

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