How tokenised property ownership works in Dubai and who may offer it

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Kooky

Builder of Shaka, the payment router that pays every agent their commission on closing date.

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Owning a share of a Dubai flat for a few thousand dirhams is no longer only an idea in a conference talk. Since March 2025 the Dubai Land Department (DLD), the body that keeps the emirate's property register, has been running a Real Estate Tokenisation Project in which a title deed is split into digital tokens and sold in small parts. A first property sold out in a day, and a resale market for the tokens opened in February 2026.

The subject attracts a great deal of marketing, and the two authorities in charge have twice published warnings about firms that claim a role they do not have. So the useful questions are plain ones. What exactly has been built, what does a buyer hold, who was allowed to buy, and who is allowed to sell? This guide answers them from the pages of the Dubai Land Department, the Virtual Assets Regulatory Authority (VARA) and the Government of Dubai Media Office, and it says just as clearly where those pages stop.

Dubai Land Department releases of 25 May 2025, 29 May 2025 and 9 February 2026. The token count is approximate, as the department gives it.

What the Land Department means by tokenisation

The Dubai Land Department gave its own definition when it launched the pilot on 19 March 2025. Tokenisation, in its words, converts real estate assets into digital tokens recorded on blockchain technology. Each asset is divided into shares, and the size of a share can fit an investor's budget and strategy. The result is partial, or fractional, ownership: several people co-own one property, each through the tokens they hold.

The same release sets tokenisation beside crowdfunding. Crowdfunding, it says, lets people put small amounts into property through digital platforms. Tokenisation is presented as a more structured model for real estate investment. The department does not go further than that comparison on the page, and it does not describe one as replacing the other.

What makes Dubai's version unusual is where it starts. The project is run by the registry itself. According to the Dubai Land Department, it is the first real estate registration body in the Middle East to apply tokenisation to property title deeds. The token is therefore not a private product sitting next to the register and pointing at it from outside. It is an experiment carried out by the authority that issues title deeds in the first place.

The department placed the pilot under its Real Estate Innovation Initiative, known as REES, and named two partners at launch: VARA, which regulates virtual assets in Dubai, and Dubai Future Foundation, through the Real Estate Sandbox. A sandbox is a controlled space where a new activity is tested under supervision before any wider rule is written, and the word describes the whole project well. Each stage so far has been called a pilot or a phase.

At the launch the Director General of the department at the time, Eng. Marwan Ahmed Bin Ghalita, described tokenisation as "a revolutionary tool driving fundamental change in the real estate sector". The release also carried a projection: a tokenisation market worth AED 60 billion by 2033, equal to 7 per cent of Dubai's total real estate transactions. That is a forecast made by the department in March 2025, not a measurement, and no later page read for this guide updates it.

From pilot to resale: the dates

The project has moved in short, announced stages. Each line below comes from a dated page of the Dubai Land Department, VARA or the Government of Dubai Media Office.

Two things stand out in that sequence. The first is speed: 67 days passed between the launch of the pilot and the opening of the first project, and resale followed eleven months after the launch. The second is that the regulator's warnings arrived inside the same calendar, one of them the day before resale opened. The project and the caution around it have been published together from the start.

What the first project showed

The Dubai Land Department opened the first tokenised project on 25 May 2025 and described it as the first of its kind in the Middle East and North Africa. Four days later, on 29 May 2025, it reported the result: the project had sold out within one day of launch.

The figures in that second release are the only official picture of who buys property tokens in Dubai. According to the department, 224 investors took part, from 44 nationalities. About 70 per cent of them were investing in Dubai property for the first time, and the average individual investment was AED 10,714. The waitlist for the initiative, it added, had passed 6,000 requests.

Some simple arithmetic helps to read those numbers, with the caution that it is arithmetic and not data published by the department. As a worked example, 224 investors at an average of AED 10,714 gives AED 2,399,936, or roughly AED 2.4 million. That is the order of size of a single home, not of a tower. Seventy per cent of 224 is about 157 people who had not invested in Dubai property before. And the average ticket of AED 10,714 is about 5.4 times the AED 2,000 minimum, so the average buyer put in well above the smallest amount allowed, although an average says nothing about how the amounts were spread. The department itself published neither the value of the property nor the price of one token on the pages read, so the first of those results is an inference from its average, nothing more.

The same care applies to the long-range projection. If AED 60 billion is 7 per cent of Dubai's real estate transactions in 2033, the total behind it is about AED 857 billion (60 divided by 0.07). The department states the two figures, not the total. Set against the worked example above, the first project is a very small first step towards a very large stated ambition.

Who could buy, and how they paid

The release of 25 May 2025 is the page that sets the terms of the pilot, and it is specific on three of them.

Who. The pilot was available exclusively to holders of a UAE ID. The department said that an opening to global users was planned for later. No page read for this guide announces that this opening has happened, so the general rule on record is the one of May 2025.

How much. The minimum investment started from AED 2,000. For comparison with the usual route into Dubai property, a buyer of a whole home pays the full price, alone or with a mortgage. Here the entry amount is fixed by the platform's minimum, and the investor holds a share.

In what. Transactions were in UAE dirhams only. Cryptocurrencies were not used during the pilot phase, according to the department. The point is easy to miss: the token is a digital asset recorded on a blockchain, but the money that buys it in the pilot is ordinary currency, and the department named Zand Digital Bank as the banking partner for the pilot phase.

The department also described what was on offer. Investors bought tokenised shares in ready properties in Dubai, meaning homes that are already built, not off-plan units still under construction. The release says investors can generate returns, without setting out how any return is calculated or paid. It adds that the platform shows the pricing, the risk factors, the technical specifications and the minimum investment for each property.

One later sentence matters for developers. In its release of 29 May 2025 the department said it was working to let real estate developers list their projects on the platform. No date was attached, and the pages read give no further detail on how a developer's listing would work.

The certificate and the property register

To see why a certificate matters, start with the ordinary rule. Dubai's Law No. 7 of 2006 on real property registration says, in Article 9 as replaced by Law No. (7) of 2019, that dispositions of rights in real property are not deemed effective unless they are recorded in the Property Register. In Dubai a property right exists through registration at the Land Department. A private contract alone does not create it.

That is the gap any tokenised scheme has to bridge. A token on a blockchain is one record; the Property Register is another. If the two are not connected by the authority that keeps the register, the token says something the register does not.

The Dubai Land Department's answer, announced on 29 May 2025, is the Property Token Ownership Certificate, which it calls the first of its kind in the world. The department says it developed the certificate with VARA, the Central Bank of the UAE and Dubai Future Foundation. The release announces it together with the sale of the first project.

The institutional link behind it was signed a few weeks earlier. According to the Government of Dubai Media Office, the department and VARA signed a collaboration agreement on 6 April 2025, described as the first agreement of its kind to link a property registry with property tokenisation, through a governance system. It was signed by Majid Al Marri, Executive Director of the Real Estate Registration Sector at the department, and Matthew White, Chief Executive Officer of VARA. Among its stated aims are protecting investors' rights, keeping regulations up to date, widening access for small investors and supporting pilot projects that assess and manage risk.

What the release on the certificate does not do is list what the document records, or define in legal terms the right a token holder has. That limit is taken up at the end of this guide, because it is the most important one.

Who may offer it: the licence rule

On this question the sources are at their clearest. VARA's alert of 19 February 2026 cites Dubai Law No. 4 of 2022 and Cabinet Resolution No. 111 of 2022 and states the rule in one line: no person may carry out virtual asset activities in or from Dubai without the required licence or approval from VARA.

The alert then applies that rule to property. Anyone offering, marketing or facilitating tokenised real estate products in or from Dubai must hold the appropriate VARA licence or approval, and the approval of any other relevant competent authority. Three verbs are used, and they reach wide. A firm does not need to issue a token to fall under the rule: marketing one, or helping a sale along, is enough.

Taking part in the Land Department's project is a separate and narrower matter. VARA's earlier alert, issued on 23 April 2025 in coordination with the department, says that only entities explicitly approved by both the Dubai Land Department and VARA may take part in the pilot, and that official confirmation of participation comes solely from one or both of them. A VARA licence and a place in the pilot are therefore two different things, and the alerts treat a claim to either as something that can be checked.

What the VARA rulebook says about issuing

Offering a token and creating one are different activities in VARA's rules. The second is covered by the Virtual Asset Issuance Rulebook, and the part that concerns the most regulated kind of issue is Section D of its Part I, on Category 1 VA Issuance.

Rule I.D.1 says that no entity in the Emirate may carry out Category 1 VA Issuance unless it is authorised and licensed by VARA for that issuance. Rule I.D.2 makes Category 1 issuance a VA Activity in its own right, which brings a group of other rulebooks with it: the Company Rulebook, the Compliance and Risk Management Rulebook, the Technology and Information Rulebook and the Market Conduct Rulebook. Under Rule I.D.3 those rules apply together, and where two of them overlap the higher standard has to be met at all times.

The section names two kinds of virtual asset. One is the fiat-referenced virtual asset. The other is the asset-referenced virtual asset, known as an ARVA. Rule I.D.6 says that an entity issuing an ARVA must comply at all times with the ARVA Rules set out in Annex 2 of the rulebook. This guide does not describe the content of that annex, which was not among the pages read, and no official page read says in so many words which category Dubai's property tokens fall into. What the public record does show is that one of the two firms the Land Department names in its project holds a licence for Category 1 VA Issuance, as the next section sets out.

The section also shows that a licence can be lost. Rule I.D.7 lists the grounds on which VARA may revoke a Category 1 licence. They include failing to issue the virtual asset within six months of approval, false or misleading statements, including in the whitepaper, failure to meet licence conditions, breach of any regulation, rule or directive, and insolvency or a decision to stop operating. Rule I.D.8 requires the entity to tell VARA immediately when one of those situations arises. For a reader of the Public Register, the practical meaning is that a licence is a status at a given date, and the word next to it can change.

Reading VARA's Public Register

VARA publishes the firms it has licensed in a Public Register, and both alerts send consumers to it. Each entry gives the name of the entity, a licence number, the date of issue, the activities the licence covers and its status.

Two entries are relevant to the firms the Dubai Land Department names in its own releases. As seen on the register on 9 October 2026, Prypco FZE holds licence VL/25/05/001, issued on 24 May 2025, for Broker-Dealer Services, with the status Active. Ctrl Alt Solutions DMCC holds licence VL/25/05/002, issued on the same day, for Broker-Dealer Services and Category 1 VA Issuance, also Active. Both licences are dated the day before the department announced the first project.

The table below sets each body and firm beside the role an official page gives it. It reports roles as the sources state them and is not a ranking or an endorsement of any of them.

A register entry answers one question only: whether a named entity holds a VARA licence for named activities on the day it is read. It does not say that the entity takes part in the Land Department's project. On that second point, the April 2025 alert is explicit that confirmation comes from the department or from VARA.

What the two alerts warn against

VARA has published two Consumer and Marketplace Alerts about this project, and they describe the same behaviour ten months apart.

The first, on 23 April 2025, came five weeks after the pilot opened. According to VARA, some entities were claiming or implying that they took part in the pilot phase when they did not. The alert adds that marketing real estate tokenisation services tied to assets located in Dubai without a licence or other authorisation, especially where the material targets customers based in Dubai, may breach VARA's regulations, including its Marketing Regulations. It names the tools available to the regulator: public alerts, financial penalties and market prohibitions. It also names the risk to the public: unlicensed platforms lack the consumer protection, market integrity and risk management safeguards of the regulated pilot.

The second, on 19 February 2026, says VARA had learned of entities referring to the pilot in promotions, informal communications or marketing claims without the necessary approvals, or implying participation beyond what had been formally authorised. Neither alert names a firm.

For agents and brokers the alerts carry a direct message, since "marketing" and "facilitating" are words that describe a good part of their daily work. An agency that advertises a tokenised property product in or from Dubai is inside the rule VARA states, whoever issued the token. Whether a given activity needs a licence or an approval depends on the facts of the case and is a question for the regulator.

For consumers, VARA sets out what it expects in three points.

Phase II and the resale market

A fractional share is of limited use to its holder if it cannot be sold on. That is what the second phase addresses. On 9 February 2026 the Dubai Land Department announced Phase II of the project, opening resale in the secondary market from 20 February 2026. According to the department, about 7.8 million real estate tokens became available for resale, within what it calls a controlled pilot framework.

The stated aims of the phase are those of a test. The department lists assessing market efficiency, testing operational readiness, strengthening transparency and governance, protecting investors' rights and ensuring the integrity of transactions. It describes its approach as gradual and coordinated with the relevant regulators, and it ties the phase to the Dubai Real Estate Sector Strategy 2033 and the Dubai Urban Plan 2040.

VARA's alert of 19 February 2026 gives the regulator's reading of the same moment. Phase 1, it says, is complete, and it validated the core technology, the regulatory framework and the operational feasibility of tokenising real estate in Dubai. Phase 2 is a controlled testing and evaluation phase under close regulatory oversight, coordinated between the department and VARA. It assesses additional functions, secondary-market mechanisms among them, and it will determine the scope, the sequencing and the conditions of any future expansion.

That last phrase deserves attention. Neither authority has announced that tokenised property is open to any firm that wishes to offer it. The department says only that it is studying wider participation and the onboarding of additional platforms, subject to evaluation and regulatory approvals, and it names none. VARA says further updates will follow as the evaluation progresses.

The release on Phase II does not explain the mechanics of a resale. It does not say where tokens trade, how a price is set, who may buy from an existing holder or what a resale costs. Nor does it give the value of the 7.8 million tokens or the number of properties behind them.

What the official pages do not say

A guide built on official sources has to be honest about their edges. The pages of the Dubai Land Department and VARA read for this article establish the framework, the dates, the participants and the licence rule. They leave open several questions that a buyer or an adviser would naturally ask.

None of these gaps means the answers do not exist. The department says the platform displays pricing, risk factors and technical specifications for each property, so a good part of the detail sits in the documents shown to an investor at the time of purchase. What the gaps do mean is that the general public record does not yet carry them, and that a statement about fees, yields or the legal standing of a token cannot be attributed to the Land Department or to VARA on the strength of the pages cited here.

One more distinction avoids a common confusion. Buying a property token in the pilot was done in dirhams. Paying for an ordinary property with virtual assets is a different subject with its own federal rule: under the Ministry of Economy's Circular No. 05/2022 on Real Estate Activity Reports, a property deal paid wholly or partly in virtual assets, or with funds converted from virtual assets, triggers a mandatory report by the broker. Tokenised ownership and payment in virtual assets are two separate topics, with separate rules.

In Dubai the token did not arrive from outside the registry. The registry is testing it, one phase at a time, and it has not finished.

Kooky, from Shaka

Kooky edits Agents Estate and builds Shaka, the payment router he made for real estate professionals. One payment comes in, and every agent, agency and party in the deal receives their signed share on closing date.

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