Adgm Registration Authority Publishes Consultation Paper On Enhanced Strata Regulations

Key dates

2026-10-01

ADGM published Consultation Paper No. 4 of 2026 proposing the Strata Regulations 2026.

2026-10-22 Deadline

Public consultation closes; comments should be submitted through the ADGM Registration Authority Consultation Portal by this date.

Suggested considerations

• Compliance and legal teams may wish to review the proposed Strata Regulations 2026 and Model Articles against existing strata governance, management agreements, building management statements and developer rights.
• Developers may wish to assess the proposed single Registrar approval process, required disclosure statement and strata management statement, staged-development arrangements, bank-guarantee exposure and six-month handover obligations.
• Existing strata developments may wish to map the likely automatic establishment of an Association when the Regulations commence, including legal-entity, contracting, banking, governance and record-keeping implications.
• Property-management businesses may wish to assess whether they hold, or can obtain, the required ADGM licence to act as an Association Manager and whether their service model supports competitive quotations and Registrar-approved budgets.
• Associations and developers may wish to model general-fund and reserve-fund requirements, including the three-year minimum reserve-fund study cycle, annual reserve forecast and restrictions on reserve-fund expenditure.
• Relevant stakeholders may wish to review defect-reporting, remediation, structural-integrity and Registrar-notification processes and identify evidence, escalation and document-retention controls.
• Developers, owners and advisers may wish to submit comments through the ADGM Registration Authority Consultation Portal by 22 October 2026; comments sent only to the consultation email address may not be considered.
• Firms should avoid treating the proposals as operative requirements because ADGM states that stakeholders should not act on them until the Regulations are enacted and published.

What changed

The proposed regime would replace the existing two-step strata-plan approval process with a single process administered by the Registrar. Developers would submit a proposed strata plan, disclosure statement and strata management statement; the Registrar could approve, condition, defer, request amendments to, or reject the application, and could defer registration until construction completion and required folios or subdivisions were established. The framework would expressly support staged strata developments, including phased incorporation of additional strata lots and common areas. Owners’ associations would be established automatically by operation of law: for existing strata developments when the Regulations enter into force and for new developments when the strata plan is registered.

Who is affected

• ADGM strata developers
• Owners of residential, commercial and retail strata lots in ADGM
• ADGM-licensed real estate and property-management entities acting as Association Managers
• Boards and owners’ associations of existing ADGM strata developments
• Purchasers, sellers and investors in ADGM strata developments
• Professional advisers handling ADGM real estate, development, conveyancing or property-management matters

Related regulations

• ADGM Strata Title Regulations 2015
• ADGM Companies Regulations 2015
• ADGM Commercial Licensing Regulations
• ADGM real property registration framework