Part time and freelance: what is allowed

Can you sell property in Dubai alongside another job?

Only by becoming a registered broker at a licensed brokerage, and the published rules say nothing about doing that part time. Bylaw No. (85) of 2006, which regulates the brokers register, states that no person may conduct the brokerage activity in Dubai unless licensed by a competent entity and registered on the register. The Land Department's FAQ puts it more plainly: no individual is entitled to practise real estate brokerage before applying for a licence through RERA.

So the real question is not whether you can sell a flat for a friend on the side. It is whether you can hold a broker card while holding another job. The DLD's card service page states that a card's validity is linked to the validity of the brokerage's trade licence, and its FAQ asks for the broker's residency to be on the same licence. What that means when you change firms is covered in the broker card piece in this guide.

Nothing on the DLD pages we checked addresses a broker who also works somewhere else, either to permit it or to forbid it. The department's list for adding a broker to a firm includes residency on the same licence, which raises an obvious question for anyone whose visa is held by another employer. The published guidance does not answer that question. It is why the rest of this page names who to ask rather than offering a workaround.

What are MOHRE's part-time and freelance permits?

Work permits come from the Ministry of Human Resources and Emiratisation, and the UAE government portal lists thirteen types. Two of them are what people usually mean when they ask about property as a second income. They are described here as MOHRE describes them, and nothing more.

The part-time work permit is applied for by the employer, through its authorised signatory, not by the worker. MOHRE's service page lists the conditions as an employee aged 18 or older who holds a valid residence visa, an occupation compatible with the establishment's activities, and, for a specialised profession or any other that requires a licence, meeting the requirements set by the law that governs it. The permit runs for one year, and the page states that once it is obtained an employee may work for more than one employer.

The freelance work permit, as the portal describes it, is for individuals working independently, including foreign nationals on self-sponsored residence visas, with no employer sponsoring them and no active employment contract. The freelancer earns by providing services and is not treated as an employee of the people they serve.

Neither permit is a broker card. A work permit concerns the right to work; brokerage in Dubai also needs the licence and registration the Land Department administers, and MOHRE's own condition on licensed professions points the same way. Whether a brokerage can register a broker it employs under a part-time permit is not addressed on any DLD or MOHRE page we checked. Ask both before you sign anything.

Is there a freelance broker licence in Dubai?

Not one we could find. No DLD service we checked issues a broker card to an individual outside a licensed real estate business, which is why this guide answers the independence question the same way everywhere: going independent means establishing your own licensed firm. That comparison has its own piece in the section on choosing a brokerage.

The Land Department does license real estate businesses, through its Real Estate Licensing Application service, with mainland applications submitted through the Department of Economy and Tourism and free zone licences needing an NOC. Its FAQ says an office is registered automatically when its licence is issued. That is a business with a registered office, not a personal permit to broker.

Who may hold such a licence is a point on which the FAQ gives answers that are hard to reconcile. One answer says individuals can obtain a real estate broker licence only if they are Emirati or GCC citizens. Another says an expatriate can own a brokerage licence provided there is a citizen services agent. The department does not explain how the two fit, and the right place to resolve it is the DLD and the Department of Economy and Tourism, not an article.

UAE nationals have a separate route. The Dubai Real Estate Brokers Programme, which the DLD states is only for UAE nationals, asks applicants whether they want a National Broker Licence or to join a real estate company as a broker. Its page says registration for the current phase is closed.

What is the difference between referring a client and practising?

The bylaw defines brokerage by what is done, not by job title. In its words, it is a service under an agreement in which a broker undertakes to a client "to find another party to conclude a contract with, and to represent that client in the contract negotiations, in return for a fee". That activity is the one Article 3 reserves for licensed, registered brokers.

The published texts do not say where an introduction ends and brokerage begins. Passing a friend's name to a licensed agent is not described anywhere in them, and nor is a thank-you payment for doing so. Ask RERA how the definition applies to any payment you are offered for an introduction, before it is paid rather than after.

The fee rules point the same way. Article 33 says a broker is entitled to fees only from the party who engages him. Article 31 says that where more than one broker acts for one party and a contract is concluded, they share the fee as if they were one broker, divided by the terms of the contract between them. Both rules are written about brokers. Neither describes a payment to somebody who is not one.

1. 01

   Finding the other party

   Locating a buyer, seller, landlord or tenant for a client. The first element of the bylaw's definition.

2. 02

   Representing the client in negotiations

   Acting for one side while terms are agreed. The second element.

3. 03

   In return for a fee

   Payment for the service. The third element, and the one that usually turns a favour into a question worth asking RERA.

Why are sub-agent arrangements risky?

"Sub-agent" is a word agents use, not one the regulator uses: no DLD text we found mentions it. As the term is usually meant, it describes somebody who sources clients or listings and is paid a share by a licensed agent or firm, without a broker card of their own. The regulator does not address the label. It addresses the activity, and what it says is short.

The four points below are what the published texts say. Whether a registered broker who pays an unregistered person falls within the penalties in Article 39 is not something they spell out. That is a reason to ask before rather than after, not a reason to assume it is fine. And because the department's FAQ says a broker found not to be licensed by RERA may lose the right to claim commission, the person in the weakest position if a payment is disputed is the one without the card.

1. 01

   Brokerage needs a licence and registration

   Bylaw No. (85) of 2006, Article 3. Working under somebody else's card is not the same as holding one.

2. 02

   Unlicensed brokerage carries a fine

   Executive Council Resolution No. (25) of 2009 lists AED 50,000 for conducting brokerage in Dubai without a licence from RERA, doubled for a repeat within one year, up to AED 1,000,000.

3. 03

   Commission can be lost

   The DLD's FAQ says a broker may lose the right to claim a commission if found not to be licensed by RERA.

4. 04

   Registered brokers face sanctions too

   Article 39 of the bylaw allows the Permanent Brokerage Committee to impose a notice, a warning, suspension for up to six months or blacklisting on a broker who breaches it or the resolutions issued under it.

What should you ask before agreeing to a part-time arrangement?

If a brokerage offers you a role that sits alongside another job, the published rules give you the questions even where they do not give you the answers. Put these to the firm, get the replies in writing, and then confirm the parts that depend on regulation with RERA and MOHRE yourself.

An offer to work deals under somebody else's card, with no card of your own, is the arrangement described in the section above, however it is presented. Whatever the firm says about how common it is, the bylaw and the fines schedule are the texts to read it against, and RERA is the body to ask.

1. 01

   Will you register me and issue a broker card in my name?

   On your licence, through Trakheesi, before I deal with any client.

2. 02

   Where will my residency sit?

   And has RERA confirmed that it works with the card, given that the DLD's list mentions residency on the same licence.

3. 03

   Which MOHRE permit will I be employed under?

   And has the firm confirmed it fits a licensed profession, which MOHRE's part-time conditions refer to directly.

4. 04

   Under whose card is each of my deals registered, and how is commission paid?

   In writing, in the contract, not in the conversation.