In a new Dubai strata office tower, the developer is liable for defective mechanical or electrical installations for one year after handover. The chillers, lifts and power systems they serve are built to run for far longer. In 2022 Savills described the "first life" of a UAE office building as generally 12 to 20 years, and notes that major systems such as chillers become less efficient with age.
That gap is easy to overlook while a market is tight and buildings fill quickly. It is harder to ignore once a tower is a decade old and its plant needs replacing. Someone then has to pay, someone has to decide, and someone has to answer if the work is neglected.
Who that someone is depends heavily on how the building is owned. For one type of building, Dubai's law is explicit. For another, it is silent. And on whether operating quality already separates strong buildings from weak ones, the public evidence does not yet exist.
A short warranty on long-lived equipment
Law No. 6 of 2019 governs what Dubai calls jointly owned real property. In plain terms, these are strata buildings (our Dive on strata versus single ownership covers the ownership split and the owners committee): towers in which floors or units are sold to different owners, who share the common parts such as structure, lifts, plant and lobbies. The law covers commercial units as well as homes, according to its definitions and scope in Articles 2 and 3 (Dubai Legislation Portal, English translation; the Arabic text prevails).
Within strata buildings, Article 40 sets the developer's liability after handover on two clocks:
- Structural defects: ten years from the completion certificate.
- Defective installations, meaning mechanical, electrical, sanitary and similar systems: one year from handover.
Both clocks cover defects. The statute does not say they extend to ordinary wear or end-of-life replacement, and we read them as not doing so. On that reading, the cost of keeping a tower functioning through its second and third decades falls outside both clocks.
Article 40(c) leaves any other rights or warranties owners hold under other legislation untouched; we have not assessed them.
Two other laws touch the same ground. Dubai's Law No. 3 of 2026 on the quality and safety of buildings applies to existing buildings as well as new ones. According to its text, it requires periodic maintenance of buildings under 20 years old and a quality and safety certificate after 20 years, and in jointly owned buildings the management entity performs those duties. In the text we read it sets no warranty period and does not say how costs are shared. The federal Civil Transactions Law, in force since 1 June 2026, is reported by law firms to keep the ten-year joint liability of contractors and engineers for structural defects.
The incentive logic follows, though we stress it is logic and not a finding. A developer is paid when units are sold. The running costs arrive afterwards, and they are met by others.
Where the bill lands
Running costs are recovered through service charges. Under Article 25, each owner pays a share according to the area of their unit, and the developer pays for any units it has not sold. Article 27 bars the collection of charges without approval from RERA, the Real Estate Regulatory Agency, and requires the budget to be approved by an audit firm that RERA recognises.
Then there is the reserve. According to the law's text, Article 30 requires a cash reserve for emergencies or the replacement of equipment in the common parts. It must sit in an account separate from the service charge account, and it cannot be used outside a critical emergency without RERA approval. If it proves too small, the management entity may, per the translated text, ask owners to cover the cost with RERA's prior approval.
What the statute does not do, in the text we read, is set a floor: it contains no required percentage of the budget and no number of years of cover. We did not check Director General resolutions or a building's own declaration. Some commentary cites a ten per cent or ten-year requirement. We could not find either in the law, and readers should treat those claims as unverified.
The structure, as the statute is written, is therefore clear, and so is its soft spot. Owners fund the building through charges and a reserve whose size the statute does not set. Whether that reserve matches the eventual replacement bill is a question for each building, not for the statute.
How many towers are approaching that moment
Cushman & Wakefield estimated in May 2025 that about 15 to 20 per cent of Dubai's office stock is nearing the age at which building systems begin to date. The stock arrived in two waves, one in the early 2000s and one after 2012. Retrofit in Dubai, it noted, is "more a matter of economics and demand" than regulation, and it lists valuation gaps, regulatory complexity and fragmented ownership among the challenges to repositioning.
That analysis offered no rent, vacancy or operating metrics for those buildings. It describes a population of ageing towers, not their performance.
What the numbers say, and what they do not
JLL's Q2 2026 figures do not show a penalty for lower-grade space, though grade is not age. Savills' Q3 2026 report points the other way for the future, expecting prime, well-connected and ESG-compliant buildings to outperform while secondary assets "may face longer leasing periods". JLL's data, reported by Khaleej Times on 30 August 2026, show Dubai-wide office vacancy at 6.1 per cent. Grade A stood at 4.2 per cent (a figure we found only in the Khaleej Times report) and Grade C at 10.9 per cent. Grade B vacancy fell to 8 per cent from 10.9 per cent a year earlier.
Rents tell a similar story. JLL reports Grade B rents up 31.5 per cent year on year (the base comes from Khaleej Times; JLL's release does not state it), ahead of Grade A at 26.2 per cent and prime at 13.6 per cent. With prime space scarce, demand appears to be cascading down the quality ladder.
Cushman & Wakefield's Q2 2026 MarketBeat, published on 24 June 2026, reads the market differently. It puts average rents at AED 205 per sq ft, down 2 per cent on the quarter, the first fall in nearly five years. Cushman & Wakefield says the rental softening was concentrated in Grade B stock, which makes up nearly 70 per cent of inventory, while Grade A, single-owned and institutional assets stayed resilient. Separately, it notes that city-wide occupancy eased marginally as more strata office stock returned to the market. It ties the softer leasing to occupiers' caution after the regional conflict and calls the moderation "healthy".
The two brokers measure different things over different periods, and neither page we read says whether rents are asking or achieved. We have not tried to reconcile them, and readers should not net them off. Both also leave "grade" undefined, and grade is a quality classification, not an age.
That is the central limit of this story. We found no data on rents or vacancy by building age, no survey or index of office service charges, and no dataset of reserve balances against replacement liabilities. The service-charge figures we came across relate to residential communities and cannot be carried over to offices.
The other side of the argument
The thesis that owners are left to carry a developer's legacy meets several fair objections.
1. The market is rewarding older and lower-grade space today.
JLL's figures on Grade B rents and vacancy contradict a simple "old building loses" story. It may be that a tight market simply hides operating differences that later become visible.
2. The regulator holds real tools.
RERA can notify a management entity to repair common parts (Article 35). Unpaid charges carry a lien on the unit; after a 30-day written notice approved by RERA, the claim is enforceable before the execution judge, who may order a public auction of the unit (Article 32). According to the law's text (Article 44), fines of up to AED 1 million, doubled to a maximum of AED 2 million for a repeat within a year, apply to violations specified by a resolution of the Executive Council Chairman. We have not checked which violations that resolution lists. Structural liability runs for a decade.
3. Single-owner buildings fall outside the statute's logic.
A tower held by one owner has no separate unit owners to charge, so the statute's charge-approval, reserve and owners-committee provisions have nothing to attach to. The statute does not address single-owner buildings in terms; this is our reading. Its operating costs are the owner's own. Cushman & Wakefield already treats this group as the resilient one.
4. Developers do bear some running cost.
Article 25 makes them pay charges on units they have not sold, so the shift of cost to others is gradual rather than immediate.
We also found nothing comparing operating standards between large and small developers, and no published building-level scores. It would be wrong to say large developers keep standards high, or that they do not.
What it means for the market
The more useful test may come later than today's market. Savills' Q3 2026 report expects limited new supply in 2026 and development activity increasing from 2028 onwards, and Cushman & Wakefield also expects deliveries to accelerate from that year. Those are pipeline forecasts, not completed stock. If they hold, tenants will have more choice, and operating quality may start to count for more.
That is a plausible forward test, not an observed result. It would matter first to the people who hold strata office units, and to those who lend against them or plan to buy.
Questions worth asking of any jointly owned office building include:
- How old is the main plant, and when is replacement due?
- What is in the reserve account, set against that replacement bill?
- How was the service-charge budget approved, and by whom?
- How much of the building is still unsold, and who pays for those units?
Occupiers have a stake too. Charges and plant condition feed through to running costs and service continuity, though we have no office data to size either.
A question the law cannot answer
Dubai's strata law is precise about how long a developer answers for a tower's structure and how long for its systems. It is silent on whether the money will be there when the systems wear out.
Until reserve balances and office service charges are published, that can be tested only one building at a time. The supply wave after 2028 may be the first moment when the difference shows up in the numbers.
Sources
- Law No. (3) of 2026 Concerning the Quality and Safety of Buildings, Dubai Legislation Portal (English translation)
- Federal Decree-Law No. 25 of 2025, Civil Transactions Law, Lexis Middle East
- Savills, Refurbishment of commercial real estate assets, 22 April 2022
- Law No. (6) of 2019, Dubai Legislation Portal (English translation)
- Cushman & Wakefield, Dubai Office MarketBeat Q2 2026, 24 June 2026
- Cushman & Wakefield, Rethinking value in a maturing market, 19 May 2025
- JLL Q2 2026 data via Khaleej Times, 30 August 2026
- Savills, Dubai office research, Q3 2026, 15 October 2026
This analysis was inspired by themes explored at RealTimes' Dubai Office Summit 2026, where senior market participants examined the changing dynamics of Dubai's office sector. The discussion was held under a non-attribution editorial approach.
