How Dubai's holiday home permit works

Dubai separates the business from the building. Decree No. (41) of 2013 Regulating the Activity of Leasing out Holiday Homes, issued on 24 November 2013, makes it unlawful under Article 3(a) for any natural or legal person to conduct the activity without a licence from the tourism regulator. The activity is defined in Article 1 as engaging, regularly and on an ongoing basis, in leasing out furnished units, or renting them in order to sublet them to guests. The implementing bylaw, Administrative Resolution No. (1) of 2020, then adds a second document. A permit is issued for each individual unit, confirming that the regulator accepts that flat or villa as a holiday home. One licence can sit above many permits.

Both instruments still name the Department of Tourism and Commerce Marketing. Later Dubai legislation, including Executive Council Resolution No. (68) of 2025 on support for hotel establishments, calls the same regulator the Department of Economy and Tourism. The English versions published on the Dubai legislation portal each carry a footnote stating that the Arabic text prevails in case of conflict. That footnote earns its keep here. The fee schedules and the Decree do not use the same word for one category.

The licence, and the approval that comes before it

Nothing starts with the licence. Article 2 of the 2020 bylaw requires an initial approval first, applied for through the electronic portal and supported by passport and Emirates Identity Card copies for the owner, partners and managing director, a valid commercial licence, and certificates of good conduct. The applicant then has three months, renewable once for the same period, to complete the licensing procedures. Miss that window and the initial approval is deemed revoked.

The licence itself runs for one year under Article 7 of the Decree, renewable for the same period. The regulator may approve a term of more than one year and up to four, and Article 4(b) of the bylaw makes that conditional on paying the licensing fees for the whole term up front. A licence revoked for any reason can be applied for again, but only after one year has passed from the date of revocation.

Which units the regulator will permit

Article 8 of the bylaw is the gate. The unit has to sit in an area where the activity is authorised by the regulator in coordination with the other competent entities, and it must fall into one of four described categories.

• An apartment in a building designated for conducting the activity
• An apartment in a residential building
• A house or villa located within a real property compound
• An independent villa

Two further requirements in the same article are worth reading before anything is bought for this purpose. The applicant must prove a right to dispose of the unit, and the sale and purchase agreement must not include any explicit provision that precludes using the unit as a holiday home. That clause exists in some agreements. It is cheaper to find it at the offer stage than after handover.

Deluxe, standard, and a translation mismatch

Article 9(a) of the Decree and Article 15(a) of the bylaw both split holiday homes into two categories, deluxe and standard, against criteria set out in the Guide that the regulator publishes. A classification certificate is issued for each home, and the regulator may upgrade or downgrade it. The Tourism Dirham schedule uses different English. Schedule 1 to Executive Council Resolution No. (2) of 2014 lists a "Luxury Holiday Home" and a "Standard Holiday Home". It is the same two-tier split described with a different word in the English translation. Worth confirming against the Arabic if a classification argument ever turns on it.

The Tourism Dirham, per occupied room per night

Holiday homes are treated as hotel establishments for this fee. Article 1 of Executive Council Resolution No. (2) of 2014 says so expressly, and Article 3, as replaced by Executive Council Resolution No. (10) of 2014 of 27 March 2014, charges the guest for each night of occupancy of a room for a maximum of thirty consecutive nights. The rate follows the classification category.

Collection is the operator's job, not the guest's. Article 4 requires the proceeds to be paid before the sixteenth day of the month following collection, the fee to be shown in the invoice issued to the guest, and the accounting books recording it to be kept for at least five years. The fines for getting this wrong are proportionate rather than fixed. Late payment costs ten per cent of the unpaid fee and failure to collect costs ten per cent of the uncollected fee, with a floor of AED 1,000 in each case. Manipulating the accounting data carries AED 15,000. A repeated violation within one year doubles the fine, capped at AED 50,000, and the regulator may close the establishment for up to three months or permanently.

What the published fee schedule says

Executive Council Resolution No. (49) of 2014, issued on 7 December 2014, sets the fees and the fines for this activity. Fees and fines collected under it go to the Public Treasury of the Government of Dubai.

Treat those as the figures the resolution prescribes rather than the figures a live application will quote. Fee schedules in Dubai are amended by further Executive Council resolutions, and the amount shown on the application at the point of payment is the one that binds. Check it there before budgeting a portfolio.

The no-objection question

People expect the bylaw to name a landlord's or owners' association no-objection certificate. It does not. Article 3(1)(b) requires the licence application to be supported by copies of the required approvals obtained from the concerned entities in the Emirate, and Article 16 leaves the document list, the technical standards and the classification criteria to the Guide, which the regulator publishes on its own website. The one no-objection certificate the bylaw does describe is a different animal: Article 13 covers trade name approval, and records that the name may not include the word "Dubai" or the classification category.

Article 17 points the other way, and is often overlooked. Real property developers, owners of jointly owned real property, and real property management and leasing firms must enable licensees to conduct the activity in accordance with the terms of their licences and permits. So a building's position is not the last word on whether a permitted unit may operate, although in practice the approvals demanded at application stage are whatever the Guide lists on the day.

Operating without one

Article 11(a) of the Decree sets the outer range at not less than AED 200 and not more than AED 20,000, with the specific amounts fixed by Schedule 2 to the 2014 fees resolution. A repeated violation within one year of the previous one doubles the fine, subject to a ceiling of AED 100,000.

Money is not the only consequence. Alongside a fine, the regulator may issue a warning, suspend the activity for up to six months, or revoke the licence. Article 11 of the bylaw lists eight grounds for closing a holiday home, among them failure to renew within the time limits, the home ceasing to meet the permit requirements or classification criteria, and enforcement of a court judgment against the property. A closed home can be applied for again, and Article 12 requires that application to come at least fifteen days after the closure date. A grievance against a decision goes to the Director General within thirty days of notification, and is determined within thirty days. That decision is final.

The running obligations that get missed

Article 14 of the bylaw requires the approved trade name and the permit number to appear in all print and digital advertisements, which includes the listing itself. It also requires comprehensive insurance from an insurer licensed in the Emirate, valid for the whole licence term, a lease contract given to each guest, emergency and guest service numbers available twenty-four hours a day and seven days a week, compliance with the maximum occupancy written into the permit, and guest records kept for at least three years. Article 8 of the Decree adds a notice board in each home showing the licensee's information in Arabic and English together with the classification category, and prohibits charging guests extra for electricity and water.

Before a listing goes live, two things on the permit itself decide whether the advertisement is compliant: the permit number that has to appear in it, and the maximum occupancy it states. Read both off the document rather than off the floor plan.