Short answer: the requirement to have paid 50% of the property value, or AED 1 million in cash, does not appear in the Golden Visa provisions at all. Article 8 of the Annex to Cabinet Resolution No. 65 of 2022 requires property with a combined value of at least AED 2 million and expressly permits it to be financed by a loan from a local bank. The condition the market repeated for three years is absent from the text — though it does exist elsewhere in the same regulation, governing a different permit.
| Element | What the regulation says | What the market repeated |
|---|---|---|
| Property value | At least AED 2 million combined | At least AED 2 million |
| Mortgage | Expressly permitted, loan from an approved local bank | 50% paid down, or AED 1 million |
| Off-plan | Separate route, purchase from approved local companies | Treated as excluded or discretionary |
| Portfolio | "One or more Real Estate", combined value counts | Often described as not permitted |
| Permit term | 10 years, renewable (Annex, Article 1) | 10 years, sometimes stated as 5 |
What does the regulation actually say?
The governing instrument is Cabinet Resolution No. 65 of 2022, issued as the Executive Regulations of Federal Decree-Law No. 29 of 2021 on the entry and residence of foreigners. It came into force on 3 October 2022 and repealed the earlier Cabinet Resolution No. 8 of 2021 on Golden Residence. The full text, including the Annex, is publicly available on the UAE's official legislation portal.
The rules for real estate investors sit in Article 8 of the Annex, under the heading "Second". It provides two routes.
Route one — completed property. The investor owns one or more properties with a combined value of not less than AED 2,000,000, wholly owned by the investor. Immediately after that condition, the text adds a qualification: "It may be a loan" — the property may be mortgaged, provided the loan comes from one of the local banks determined by the competent local authority.
Route two — off-plan. Purchase of units bought off the plan with a combined value of not less than AED 2 million, provided the purchase is made from local companies approved by the competent local authority.
Both routes additionally require comprehensive health insurance for the investor and family members.
The part that rewards careful reading: the financing clause is not a third, alternative basis for eligibility. It is a qualification inside the value condition. Taking out a loan achieves nothing by itself. What qualifies is property worth at least AED 2 million; the regulation simply does not object to that property being financed with debt.
Nowhere in this section is there a threshold for capital already repaid. Neither 50% nor AED 1 million.
How do we know this is not a drafting gap?
Because the same article does impose a financing prohibition — on a different category.
The section headed "First" covers investors in public investments: a deposit in a fund or national bank, company capital, or a partnership share, each from AED 2 million. Point 6 of that section states that the invested capital must be wholly owned by the investor and "not a loan", and that evidence must be provided to prove it.
Placed side by side, the two sections leave little room for interpretation:
| Category in Article 8 of the Annex | Debt financing |
|---|---|
| "First" — public investments | Expressly excluded, proof required |
| "Second" — real estate | Expressly permitted, condition: local bank |
This is not an oversight. It is a distinction drawn deliberately, a few paragraphs apart.
By the same logic, "wholly owned by the Investor" cannot mean "fully paid for", because the sentence immediately following permits a mortgage. It describes the extent of ownership — the property must belong to the applicant in full rather than as a fractional share.
Where did the AED 1 million figure come from?
The most plausible explanation sits in the same regulation, some twenty articles earlier.
Article 52 governs the residence permit for retired foreigners. It requires property worth at least AED 1 million, or a deposit of the same amount, or fixed annual income of at least AED 240,000. And it contains a clause that has no equivalent in the Golden Visa provisions: where the property is mortgaged, the mortgaged title deed is accepted provided the amount paid to release the mortgage is not less than AED 1 million.
So the million-dirham threshold does exist in UAE law, and it does attach to mortgaged property. It simply belongs to the retirement category rather than the investor one.
| Category | Basis | Treatment of a mortgage |
|---|---|---|
| Golden Visa — real estate investor | Annex, Article 8, "Second" | Loan permitted, no repayment threshold |
| Golden Visa — public investments | Annex, Article 8, "First" | Loan excluded |
| Residence permit for retired foreigners | Article 52 | At least AED 1 million paid to release the mortgage |
| Residence permit for property owners | Article 53 | No mortgage clause; requires monthly income from AED 10,000 |
We cannot prove that this conflation is what produced the market practice — it remains a hypothesis. But it is the only place in the regulation where AED 1 million and a mortgage appear together, and a more likely source is hard to construct.
What happened in February 2026?
Here the ground becomes softer, because this is where verifiable legal text runs out.
Market material consistently describes a federal circular dated 20 February 2026 said to have removed the 50% / AED 1 million requirement and made valuation the sole qualifying criterion. The accounts agree on both date and substance — but all of them are secondary. We were unable to locate the document itself in publicly accessible sources.
At the same time, the official government portal and parts of the procedural material still carry the earlier wording, including phrasing that suggests property free of encumbrance. That gap between layers is itself worth knowing about.
The cautious conclusion is this: the law did not change. Article 8 of the Annex has read the same way since October 2022. If something happened in February 2026, it happened at the level of administrative practice rather than legislation. Which also means practice can move again, in either direction, without anything being amended.
This is the same mechanism we describe in the Dubai tax residency trap: the rule says one thing, the authority does another, and the risk sits with the facts rather than the paperwork.
The practical consequence: confirm the currently required documents directly with the land department or a licensed intermediary before committing to a purchase. Do not base a transaction on anyone's description of the circular — including ours.
What does the process look like?
What follows reflects procedural and market material rather than the text of the regulation, and is more likely to shift.
| Element | Notes |
|---|---|
| Valuation | Eligibility rests on a valuation confirmed by the competent authority, not on the contract price alone |
| Bank NOC | For mortgaged property, confirmation that the lender does not object is normally required; documentary requirements were revised during 2026 |
| Foreign financing | The regulation refers to a local bank determined by the competent authority, so a loan from a bank outside the UAE does not meet the condition |
| Freehold zones | The property must sit in an area where foreign ownership is permitted |
Off-plan and mortgages — a distinction worth internalising. A developer payment plan (20/80 and similar) is not a bank loan. For off-plan property a bank is constrained by Central Bank rules: Circular No. 31/2013 as amended caps the loan-to-value ratio for off-plan at 50%, regardless of buyer category or value. For completed property, by comparison, an expatriate's first purchase is capped at 80% up to AED 5 million and 70% above it.
A 20% payment on an off-plan unit is therefore a developer schedule, not a mortgage offer.
Joint ownership and portfolios
The regulation requires the property to be wholly owned by the applicant. Each person applying in their own right must therefore demonstrate ownership worth at least AED 2 million.
The practice of allowing spouses to combine values on production of an attested marriage certificate is an authority procedure rather than a provision of the regulation. Worth remembering, because procedures change faster than legal texts.
A portfolio of several properties, by contrast, sits squarely within the wording: the provision refers to one or more properties and to combined value.
The two-year investor permit
For investment below the Golden Visa threshold, a shorter property investor permit remains available through the land department's dedicated service.
In April 2026 updated criteria appeared in the material of the DLD-affiliated service centre — without any formal announcement. Under those criteria the previous AED 750,000 minimum was removed for sole owners of a completed unit, while co-owners each need a registered share of at least AED 400,000.
The way that change was introduced — a revised service card rather than a public statement — illustrates precisely why status should be verified with the authority directly.
What the Golden Visa does not do
It is a residence permit. It does not by itself establish tax residency, which is determined under Cabinet Decision No. 85 of 2022, with the certificate issued by the Federal Tax Authority. We set out the distinction in tax residency versus immigration residency, and the comparison with the business route in Golden Visa versus business visa.
Nor does it change your position in the country you are leaving. Buying property in Dubai neutralises neither exit tax and CFC exposure nor the question of when zero per cent tax actually works.
Legal instruments and sources
- Cabinet Resolution No. 65 of 2022 — Executive Regulations of Federal Decree-Law No. 29 of 2021 on the entry and residence of foreigners. Real estate investor Golden Visa: Annex Article 8, section "Second"; permit term: Annex Article 1; retired foreigners: Article 52; property owners: Article 53. In force from 3 October 2022; repealed Cabinet Resolution No. 8 of 2021.
- CBUAE Circular No. 31/2013 (Regulations regarding Mortgage Loans) — loan-to-value limits; off-plan capped at 50% regardless of buyer category. Amended by Board Resolutions No. 96/2019 and No. 31/2/2020, status "In-Force".
- TRC service card — Federal Tax Authority — the authority issuing tax residency certificates; criteria under Cabinet Decision No. 85 of 2022 and Ministerial Decision No. 247 of 2023.
- Federal circular dated 20 February 2026 — text not publicly available. Market accounts are consistent but secondary and unverified at source. We flag this rather than cite it as established fact.
In short: Cabinet Resolution No. 65 of 2022 has permitted a mortgage-financed property Golden Visa since October 2022. The 50% and AED 1 million conditions are not in that provision — the million-dirham threshold belongs to the retirement permit under Article 52. Whatever happened in February 2026 concerned practice, not law. And practice can move again without a single amendment.
Frequently Asked Questions
Do I need to have paid 50% of the property before applying?
The regulation contains no such requirement. Article 8 of the Annex requires property with a combined value of at least AED 2 million and permits it to be financed by a loan from an approved local bank.
Where does the AED 1 million figure come from?
From Article 52 of the same regulation, which governs the residence permit for retired foreigners and requires at least AED 1 million paid to release a mortgage. A different category entirely.
Does simply taking out a mortgage qualify me?
No. Property worth at least AED 2 million qualifies. The financing clause is a qualification within that condition, not a separate route.
Can several properties be combined?
Yes. The provision refers to one or more properties and to combined value.
Does off-plan property qualify?
Yes, through a separate route requiring purchase from approved local companies. Note that Central Bank rules cap off-plan mortgage financing at 50% loan-to-value.
How long is the permit valid?
Ten years, renewable, under Article 1 of the Annex. References to five years most likely survive from the repealed Cabinet Resolution No. 8 of 2021.
Does it make me a UAE tax resident?
No. Two separate statuses, granted by different authorities under different instruments.
Last updated: 12 August 2026
This article is for educational purposes only and should not be treated as legal or tax advice. Every situation requires individual analysis.