Electronic signatures and UAE Pass in UAE property dealings: the rules

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Kooky

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

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A tenancy contract approved on a phone, a sale agreement signed inside a government app, a registration certificate that arrives by email: each rests on the same question, which is what an electronic signature is worth in law. In the United Arab Emirates the answer sits in one federal text, Federal Decree-Law 46 of 2021 on Electronic Transactions and Trust Services, and in the Cabinet resolution that carries it out.

This guide reads that law for people who deal in property. It sets out the three kinds of electronic signature the Decree-Law defines, what the text covers and what it does not exclude, the rule that nobody can be made to deal electronically, and the duties of the person who signs and of the person who relies on a signature. It then turns to UAE Pass, the national digital identity, and to what the service pages of the Dubai Land Department actually say about it for sales and for tenancy registration in Dubai. Where the pages are silent, the guide says so.

Federal Decree-Law 46 of 2021, Articles 1 and 54, and Cabinet Resolution 28 of 2023, Article 15(12).

One federal law, in force since January 2022

The Decree-Law was issued on 20 September 2021. Under its Article 54 it was published in the Official Gazette and took effect on 2 January 2022. Article 53 repealed the text that governed the subject until then, Federal Law 1 of 2006 on Electronic Commerce and Transactions, while keeping earlier decisions in force where they are consistent with the new law. Article 50 gave everyone subject to the law a period of no more than one year from its entry into force to regularise their position, a period the Cabinet may extend.

The authority in charge is named in Article 1: the Telecommunications and Digital Government Regulatory Authority, known as the TDRA. The UAE Government portal adds that the Federal Authority for Identity, Citizenship, Customs and Port Security issues the controls for trust services provided to the government sector.

The detail is in Cabinet Resolution 28 of 2023, the Executive Regulations of the Decree-Law, issued on 31 March 2023. Its Article 37 brings it into force 90 days after its publication in the Official Gazette; the text does not print the publication date.

Three kinds of electronic signature

Article 1 of the Decree-Law defines an electronic signature broadly: a signature made of letters, numbers, symbols, voice, a fingerprint or a processing system in electronic form. The person who creates one is the signatory. Above that general definition the law builds two stronger tiers.

The middle tier is called the advanced electronic signature in the English text published on the UAE Government portal. The English text of the Executive Regulations uses the word "reliable" for the same tier, a difference of translation the reader will meet in practice. Article 19 of the Decree-Law lists what it must do. It must be completely and exclusively associated with the signatory and under the signatory's control. It must identify the signatory. It must be linked to the signed data so that any later change can be detected. It must be created with technical and security techniques, and it must meet any further requirement of the Executive Regulations, which in turn refer to the specifications set by the TDRA.

The top tier is the qualified electronic signature, defined as an advanced signature created by a qualified signature device. Article 20 adds that it must rest on a valid qualified authentication certificate, that its validation data must match what is given to the relying party, and that the signatory's identity data must be properly disclosed.

The three tiers read as a ladder of proof: the first cannot be shut out of evidence because of its form, the second has legal effect once its conditions are shown, and only the third is put on the same footing as ink on paper.

Property dealings: the exclusion list that is not there

The question a property reader asks first is whether the law applies to a sale or a lease at all. Article 2(1) of the Decree-Law applies it to the persons who rely on electronic transactions and trust services, and to the transactions, documents and procedures themselves. Article 1 defines an electronic transaction as any transaction, including contracts, agreements and other such transactions or services.

The English text published on the UAE Government portal contains no list of excluded transactions. It does not mention real estate, title deeds, sales of immovable property, long leases or personal status as carved out. The law on notaries public appears in it once, in the preamble, among the statutes the Decree-Law refers to, and not as an exclusion. The Executive Regulations are the same: Cabinet Resolution 28 of 2023 lists no transaction or document as included or excluded.

What the text has instead is a power. Under Article 2(2), the Cabinet may add, delete or exclude any transaction, document, service or procedure, and may exclude any entity from all or part of the law. Whether a given kind of property document is outside the law therefore depends on Cabinet decisions taken under that article, and not on the Decree-Law itself. No such decision was found among the primary pages read for this guide, which is recorded as an open point at the end.

One caution follows. The Decree-Law lets the body in charge add conditions: Article 9, on originals, expressly reserves any further condition set by the government entity that oversees the document.

Nobody is compelled to deal electronically

The Decree-Law is permissive, not mandatory, for private parties. Articles 5 and 28 state that no one must be compelled to use an electronic document without consent. The same provisions add that consent may be inferred from any conduct that indicates it.

Government bodies are treated differently. Under Article 28, government entities must accept electronic signatures, electronic seals, digital IDs and electronic documents in their electronic services, in line with the standards set by the TDRA. The same article allows them to accept deposits, issue licences and collect fees electronically.

Writing, originals and contracts formed on a screen

On legal force, Article 5(1) says that an electronic document is not without legal force and effect merely because it is in electronic form. An electronic document, in the Article 1 definition, is an electronic record, an electronic message such as an email, or an informational statement.

On writing, Article 7 treats a requirement of writing as met when the information is saved in a way that allows it to be used and referred to later.

On originals, Article 9 sets three conditions: reliable assurance that the document has kept its integrity since it was created in final form, the ability to display it where it has to be shown, and any additional condition set by the government entity that oversees it.

On keeping records, Article 6 requires the document to be kept in its original format, or in one that represents it accurately, to remain accessible, and to keep the information that shows where it came from, where it went and the date and time. Information created automatically only to send or receive the document is left out of that duty.

On forming a contract, Article 10 allows offer and acceptance to be expressed electronically, and says a contract does not lose its validity merely because it was made through electronic documents. Article 11 extends this to contracts concluded between automated systems. Two further provisions deal with proof of who sent what. Under Article 12(3), a recipient may treat a document as coming from its originator where an approved verification procedure was properly applied. Under Article 13(5), receipt is presumed where an acknowledgement has been received.

UAE Pass: the national digital identity

The Decree-Law defines a digital ID as a special electronic identification tool that allows a person to access and carry out transactions and services. According to the UAE Government portal, the TDRA regulates electronic transactions and trust services, licenses providers and publishes the list of them.

UAE Pass is the national tool. The UAE Government portal, on a page updated on 30 December 2024, describes it as the first national digital identity and signature solution. The portal says it was launched at GITEX 2018 as a collaboration between Digital Dubai, the TDRA and the Department of Government Enablement, and that it works in all emirates.

The portal describes four functions:

• Sign-in. A single sign-in for the services that accept it.
• Signature. A user can upload a document and sign it.
• Verification. A signed document can be verified.
• Digital vault. A vault holds digital versions of official documents. The portal says the vault runs on blockchain technology.

On registration, the portal says facial recognition creates a verified account in less than 5 minutes without a visit to a government service centre, where registration previously took 20 minutes and required a visit. It lists the Electronic Transactions and Trust Services Law among the protections that apply.

The page does not state who is eligible to register, does not mention a fee, and does not say which of the three legal tiers a UAE Pass signature belongs to.

Where Dubai Land Department pages name UAE Pass

The Dubai Land Department publishes a page for each of its services, with the documents required, the steps and the fees. Four of those pages were read for this guide on the version of the department's site last updated on 7 October 2026. They do not treat identity the same way.

The sale page is the clear case. The department offers the service to individuals who hold a UAE ID, with the residency status given as citizen and resident. Its list of required documents holds a single entry, UAE PASS. Its cancellation terms allow a request to be cancelled before the contract is signed "via the Digital ID", and cancel it automatically after 7 days if it has not been signed. The output is an electronic title deed and the service time is given as instant. The page limits the service to subdivided units (apartments, offices and townhouses) in freehold areas, free of any restriction or mortgage, and its terms refer to an escrow account.

The Dubai REST page describes the app as a smart real estate platform. It lists registering, renewing and cancelling leases among its services, and a real estate wallet for sales, purchases, leases and mortgages. It does not mention UAE Pass or electronic signature.

Registering a tenancy in Ejari: what the page asks for

Ejari is the Dubai Land Department's system for registering tenancy contracts in the Emirate of Dubai. The department's page for registering or renewing a contract gives three channels: the department's website through the Ejari system, the Dubai REST app, and the Real Estate Services Trustee Centres.

The service terms set a condition for the mobile apps: the tenant and the landlord must both be individuals and the owner's data must be up to date.

The online route runs in five steps on the department's page.

Two points stand out against the sale service. First, the document asked for in the app is a copy of the Unified Tenancy Contract. The page does not describe the parties signing electronically inside the service, and it names neither UAE Pass nor a digital signature. Second, the request is reviewed by an employee before the certificate is issued, where the sale page gives its service time as instant.

At a trustee centre the page asks for the original Unified Tenancy Contract, the applicant's Emirates ID and, for a representative, the official power of attorney. A power of attorney issued in Dubai can be entered by its number; one issued in another emirate must be attached. The page gives the service time there as 25 minutes.

The fees differ by channel. A worked example, using only the figures on the department's page: through the app or the website, the first line is AED 100, two further lines are AED 10 each and the service partner fee is AED 55, plus value added tax of AED 2.75 on the partner fee. The sum is 100 + 10 + 10 + 55 + 2.75, which is the AED 177.75 the page gives as the total. At a trustee centre the first three lines are the same and the partner fee is AED 95 plus VAT, with a stated total of AED 220. The four listed lines add up to AED 215, and the page does not state the VAT amount. If VAT bore the same proportion to the partner fee as on the app, where AED 2.75 on AED 55 is 5%, it would be AED 4.75 and the sum would be AED 219.75; the page says AED 220, and the two are shown here as the page gives them. On the stated totals, the trustee channel costs AED 42.25 more than the app.

Cancellation follows the same pattern. The department's page covers a contract that has expired on a property that has been vacated. It is free of charge through the app or the system, and costs a service partner fee of AED 40 plus VAT at a trustee centre. Online, the applicant submits the request and receives an email if it is approved. The page does not mention UAE Pass.

Duties of signers, relying parties and providers

The Decree-Law gives duties both to the person who signs and to the person who acts on the signature.

The signatory, under Article 30, must exercise due diligence, notify the licensed provider if the signature data is compromised, keep the data in the certificate accurate, report changes and use only valid certificates. The holder of a digital ID has a parallel list in Article 31: due diligence, notice to the relevant parties of any doubt about security, and accurate data.

The relying party is defined in Article 1 as a person who relies on electronic trust services. Article 29 makes that person responsible for failing to check the validity of a certificate or of a digital ID. It lists what a relying party must take into account: the level of security of the signature, the identity of the signatory and the certificate behind it, whether the certificate has been revoked, and any prior dealings between the parties.

The Executive Regulations support that check from the provider's side: licensed providers must tell relying parties the security and trust levels of the digital identity used (Article 15(9)), and must keep information on the validity of certificates free for at least 15 years after a certificate expires (Article 25(2)). A revocation must be published within 24 hours, a revoked certificate cannot be reactivated, and temporary suspension of certificates is prohibited.

Behind every certificate stands a licensed provider. Article 15 forbids anyone from providing trust services without a licence from the TDRA, and qualified trust services require qualified status as well. Article 17 lists the trust services and, separately, the qualified trust services, which include the qualified electronic time stamp and the qualified electronic delivery service. The TDRA prepares and publishes the UAE Trust List.

The Executive Regulations set the bar for a licence. An applicant must produce a report from an accredited auditor confirming financial resources of AED 5,000,000. A licence runs for two years, and renewal must be requested at least 3 months before it expires. Licensed providers must keep their records for at least 15 years, and the identification proofs behind authentication certificates for at least 10 years after the certificate expires.

Two provisions reach beyond the providers. Article 37 of the Decree-Law recognises qualified trust services from outside the UAE where they are on a comparable level to those under the law. And Article 29 of the Executive Regulations requires government authorities that archive electronically signed documents to preserve the signature against change and deletion; if an authorised change is made to the document, the signature must be recreated on the new version.

Penalties for forged or misused signatures

The Decree-Law carries its own criminal provisions, in Articles 39 to 45. Several are aimed at providers; the ones below can reach any person who signs or submits a document.

Under Article 39(3), a person who knowingly uses a counterfeit electronic document faces the same penalty as the forger. Article 46 provides for the confiscation of the tools and devices used, without prejudice to third parties acting in good faith.

What the sources leave open

Several questions a reader may reasonably ask are not answered by the pages read for this guide.

No page read says which tier of signature a UAE Pass signature is. The UAE Government portal calls UAE Pass a digital identity and signature solution and lists the Decree-Law among the laws behind it, but it does not use the words advanced or qualified. The weight of a given signature under Article 18 turns on that classification.

No Cabinet decision under Article 2(2) was found. The Decree-Law and its Executive Regulations list no excluded transactions, yet the Cabinet holds the power to exclude any transaction or document, and a decision of that kind would change the answer for the document it names.

The tenancy pages of the Dubai Land Department do not say how a user of Ejari or Dubai REST is identified, or whether the parties sign within the service. The eligibility rules for a UAE Pass account are not on the portal page, which matters for a party who holds no UAE ID: the department's sale service through Dubai Now is offered only to individuals who do.

The federal law does not take property off the list of things that can be done electronically. What each service asks for is set page by page, and only one of the four pages read names UAE Pass.

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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