Subletting a room in Dubai without an official permit is now prohibited under the new shared housing law, but as landlords, shared housing operators and tenants begin to adjust, plenty of questions remain unanswered.
The law brings shared accommodation under a system regulated by permits, occupancy limits, safety standards and tenancy rights, and is intended to reduce overcrowding, prevent illegal partitions and limit informal rentals for safer living conditions.
It is a necessary intervention given the scale of unofficial shared accommodation in Dubai, said Taimur Khan, head of research for the Middle East and Africa at JLL, a real estate and investment management company. "This is a welcome regulatory change due to safety issues and the unregulated operations of informal bed-space and shared-room accommodations,” he said.
He expects the property market to respond before the September 2027 deadline, partly because the penalties for non-compliance are steep. Although owners and businesses have time to comply, Dubai Municipality has already started inspections in identified problem areas.
“We will start to see changes pretty quickly, with landlords applying for permits, as there are heavy penalties for non-compliance,” Mr Khan said.
Law does not apply to all apartments
One key question is how authorities will determine the permitted number of occupants for each property.
Ahmed Elnaggar, founder of Elnaggar & Partners, a legal firm, said the law identifies six types of property that may be approved for shared accommodation: residential apartments, stand-alone houses, residential complexes, mixed-use buildings, adjoining houses and multistorey buildings.
However, the law does not yet specify occupancy limits for studios and one- or two-bedroom apartments.
“We will therefore need to wait for the further decisions and technical requirements to understand how these limits will work in practice,” said Mr Elnaggar.
“The actual number of people allowed will depend on the property, its size, its location, its technical capacity and the conditions mentioned in its permit,” he said.
Mr Khan noted that unauthorised partitioning is not clustered in one part of Dubai; it is scattered throughout the city. He said enforcement would likely target specific buildings rather than specific neighbourhoods. The focus would be “on the asset, not the location”.
Conventional renting
Landlords relying on informal shared accommodation may need to choose between investing in compliance and reverting to conventional renting. “It is likely they might not rent it the same way and instead target families and conventional tenants,” Mr Khan said.
Mr Elnaggar stressed that shared accommodation itself remains legal under the new system. The issue is whether a property can safely hold the proposed number of people.
Dubai Municipality will assess not only the unit but also the surrounding area, reviewing population density, infrastructure, sewerage capacity and the neighbourhood's urban planning.
Before approval, properties must meet standards for fire safety, sanitation, the environment, security and the electricity network.
Inspectors will have judicial powers to enter shared housing units, review documents, prepare violation reports and call the police if needed. However, inspections must follow approved procedures and respect the privacy of occupants.
What does it mean for tenants?
The law gives tenants protection that did not necessarily exist in the informal market.
Leases must be registered in the Shared Housing Register and a copy provided for tenants, along with a guide explaining their rights, obligations, permitted uses and emergency contacts.
The law also provides protection if disputes arise between an owner and an operator. An occupant can retain the right to remain in the property under the lease while the dispute is being considered.
How can tenants tell if property is legal?
For tenants, verification will become particularly important.
The landlord or operator must display a visible sign at the front of the property that identifies the permit holder in Arabic and English and states the approved category of shared housing. Advertisements must also carry the authorised establishment's trade name and permit number.
But Mr Elnaggar said it is not yet clear whether tenants will have access to an online system to independently verify the property.
Until that is clarified, prospective occupants should ask for a copy of the shared-housing permit; confirmation of the approved category and maximum permitted occupancy; the operator's trade licence and authorisation, where applicable; confirmation that the lease will be registered in the Shared Housing Register; and a copy of the registered lease.
What if a property loses its permit?
If an operator gets suspended or a permit is cancelled, that doesn't mean tenants have to pack up immediately. The authority sets a time frame for lawful occupants to stay and relocate, and any formal evacuation for non-compliance requires a decision from the Execution Judge.
Tenants can also challenge an eviction within seven days, which pauses it, and may be able to claim compensation through the Rental Disputes Centre for prepaid rent or other losses.
For Mr Elnaggar, the guiding principle is that penalties should land on whoever caused the violation, not on the tenant caught in the middle. “A good faith occupant should not suddenly lose all legal and contractual protection simply because the owner or operator did not comply with the permit requirements.”
