Al Reem Island's inclusion in the ADGM Area from 1 January 2025 was one of the most significant jurisdictional shifts in Abu Dhabi real property law. Every Reem Island property owner, lender, and tenant now operates under the ADGM Real Property Regulations 2024 — not Abu Dhabi Law 19/2005. The transition created specific rules, risks, and obligations that remain live in 2026.
1. The 1 January 2025 transition
Before 1 January 2025, Al Reem Island was governed by: Abu Dhabi Law No. 19 of 2005 (real property ownership), the Tawtheeq registration system (lease registration), and ADREC (Abu Dhabi Real Estate Centre) oversight. From 1 January 2025, the ADGM Real Property Regulations 2024 replaced this regime for all real property on Reem Island. Al Maryah Island was already within the ADGM Area; Reem joined it from this date.
2. Primary application deadline — now lapsed
Section 27(1) required existing Reem Island property interests (ownership, mortgages, leases, covenants) to be filed for registration on the ADGM Register by 30 June 2025. As of May 2026, this deadline has passed. Owners who did not register by 30 June 2025 are now in late-filing status. Consequences:
- Late filing fees under section 148 — cumulative with the standard registration fee
- Priority risk — any interest registered in the gap period may outrank the late-registered interest under section 16
- Unregistered interests do not have indefeasibility protection (section 22)
- Unregistered interests may not bind third-party purchasers who registered without notice
If you have a Reem Island property interest not yet registered on the ADGM Register, the correct action is to register immediately — accepting the late fees rather than compounding the delay. Every additional day of non-registration is another day of priority exposure.
3. Granted-land restrictions — section 174
Section 174 is unique to Reem Island and reflects its history as government-granted land. The Abu Dhabi government originally gifted parcels on Reem Island to developers and individuals. Section 174 gives the ADGM Registrar power to attach restrictive covenants to such granted land on the folio, limiting the owner's ability to:
- Lease the property (restrictions on who can be a tenant, or prohibition on leasing)
- Mortgage the property (restrictions on encumbrancing)
- Dispose of the property by sale or gift
These restrictions are noted on the folio — they are not separately published or notified to the owner. Any buyer or lender dealing with Reem Island property must search the specific folio for section 174 covenants before transacting. Assuming free dealing rights without a folio search is a fundamental due diligence failure.
4. Dual register risk — Tawtheeq vs ADGM Register
Section 3(2) acknowledges the practical reality that some Reem Island properties were registered under the Abu Dhabi Tawtheeq system before 1 January 2025, and conflicts between those records and the ADGM Register may exist. Common scenarios:
| Conflict type | Risk | Resolution |
|---|---|---|
| Tawtheeq shows mortgage, ADGM folio does not | Mortgage may be unenforceable in ADGM Courts without ADGM registration | Register mortgage on ADGM Register immediately |
| Tawtheeq shows lease, ADGM folio does not | Tenant's rights not protected by ADGM indefeasibility (s.22) | Register lease on ADGM Register |
| Ownership conflict between registers | Competing title claims | Registrar adjudicates under s.3(2) or applies to Courts |
| Different parties shown as owner | Potential fraud or error | Court proceedings to resolve; caveat to protect pending resolution |
Owners with pre-2025 Reem assets should audit their position: obtain both a Tawtheeq extract and an ADGM folio search, compare them, and resolve any conflict through registration or Court proceedings.
5. Pre-2025 Reem mortgages — different enforcement rules
Section 72(3)(b) creates a specific transitional rule for mortgages registered on Reem Island before 1 January 2025. Unlike mortgages registered elsewhere in ADGM — which can proceed to enforcement after the standard 30-day cure notice — pre-2025 Reem mortgages must obtain a Court enforcement order before any enforcement action can proceed, even after the 30-day notice lapses without cure.
This rule reflects that these mortgages were created under the prior Abu Dhabi law regime and were subject to a different enforcement process. Lenders holding pre-2025 Reem security must factor Court timelines into their enforcement planning — typically adding 3-6 months to the enforcement process compared with new-regime ADGM mortgages.
6. The 6-month correction window
Section 176 provides a correction window of 6 months from the date of first ADGM registration, during which administrative errors in Reem Island registrations can be corrected without penalty. For properties first registered in January 2025, this window closed around July 2025. For any Reem Island property that has recently been registered for the first time on the ADGM Register, the 6-month clock is still running.
Use this window to identify and correct: incorrect folio details, missing co-owners, wrong property descriptions, and any errors in transferred encumbrances. Corrections after the window require a full amendment application.
7. New Reem transactions from 2025 onwards
All transactions on Al Reem Island from 1 January 2025 are fully within the RPR 2024 regime. Standard rules apply:
- Freehold title — only freehold permitted inside ADGM Area (s.1(a))
- Priority by registration order (s.16) — register promptly
- Indefeasible title on registration (s.22)
- Residential leases — STRL rules apply (s.182) including 5% deposit cap, 5% rent increase cap, 30-day registration
- Mortgage enforcement — standard 30-day cure notice, no Court order required for new mortgages
- Caveats available (s.117) for protecting unregistered interests
- Check for granted-land restrictions (s.174) on every Reem folio before transacting
8. Reem Island owner action checklist (May 2026)
- Verify whether your interest is registered on the ADGM Register — request folio search (s.153)
- If not yet registered: file immediately — late fees apply but delay compounds risk
- Cross-check ADGM folio against any Tawtheeq records — identify and resolve conflicts
- Search folio for granted-land covenants under section 174
- If you hold a pre-2025 mortgage on Reem: factor Court enforcement requirement into any default planning
- If recently first-registered: check correction window under s.176 is still open — fix any errors now
- Register any unregistered leases, mortgages, or dealings with late fees
- Verify lease terms comply with RPR 2024 STRL rules — update if not
This article is for general information only and does not constitute legal advice. For advice on a specific ADGM real property matter, please contact us. Last updated: 19 May 2026.