RERA Escrow Account Audit Dubai: The Complete 2025–2026 Guide

In Dubai’s real estate sector, financial transparency is not just a best practice—it is a legal mandate. For real estate developers operating in the Dubai real estate market, the project escrow account (also known as a trust account or escrow trust) is the heartbeat of project viability.

A RERA escrow account audit is a specialized trust account audit designed to ensure that funds from off-plan buyers and financing are handled according to RERA (Real Estate Regulatory Agency) laws. This audit ensures compliance with RERA regulations, safeguarding investors' rights and maintaining the integrity of the UAE real estate industry.

What is a project escrow account in Dubai?

A project trust account is a dedicated bank account opened for a specific development. Under RERA regulations, these are escrow trust accounts where all proceeds from off-plan sales must be deposited.

Key pillars of RERA guidelines include:

• Separate Accounts: A developer must have a distinct rera trust account for every project.

• Restricted Usage: Funds cannot be mixed with a corporate current account; they are for project construction only.

• Regulatory Supervision: The RERA trust account department monitors these accounts via approved RERA auditors.

Who is involved in the escrow ecosystem?

Maintaining a cordial relationship with the RERA and the Dubai Land Department (DLD) is essential for all stakeholders:

1. DLD & RERA Oversight: DLD provides the guidelines prescribed by RERA, explaining who must open accounts and how milestones work.

2. Account Trustee: A bank or financial institution licensed by the Central Bank of the UAE and approved by RERA to manage the account.

3. The Developer: The project owner responsible for routing funds and ensuring they comply with RERA regulations.

4. RERA Approved Auditors: Audit firms like Young & Right that are registered with RERA to prepare the annual audit report.

5. Service Providers: Contractors and consultants who are the primary eligible payees.

What is a RERA escrow account audit in Dubai?

In practice, a RERA escrow account audit (Dubai) is an independent review of whether a project’s escrow account is being managed according to:

• the escrow law principles (project-only use, separate account per project, controlled releases, retention), 

• and the operational rules and workflows described through DLD’s escrow guidance and services (activation, evidence requirements, milestone verification). 

What an escrow audit typically verifies

A strong escrow audit usually tests five core areas:

1. Inflow completeness
   Are all required collections and deposits actually going into escrow (buyer payments, mortgage partner amounts, and project financing)? 

2. Outflow legitimacy
   Are disbursements supported by approvals, contracts, invoices, and progress evidence?

3. Eligibility of payments
   DLD notes that, as a general rule, escrow payments are for contractors, consultants, and marketing involved in the project—and not all developer expenses are eligible. DLD also gives a clear example that only 5% of total sales can be paid for project marketing purposes. 

4. Milestone verification discipline
   DLD explains that milestone release conditions are set in the written agreement, and the trustee engineer visits the site to verify completion before disbursing payments. 

5. Retention and post-completion controls
   DLD FAQ states Article (14) requires retaining 5% for one year after completion as a guarantee for addressing defects that may appear within the year after handover. 

Escrow disbursement activation in Dubai: the cashflow gate you must prepare for

One of the most important operational steps in escrow governance is activating the disbursement mechanism. DLD has a specific eService for this.

DLD’s Escrow Account activation service description states: it allows a developer to apply for activating the disbursement mechanism from the escrow account of the off-plan sold project. 

How the workflow runs (as per DLD)

DLD outlines a step flow via the online system:

• Log in to Oqood → select escrow account link → submit application

• Application goes to the trustee

• Trustee studies capability, uploads and sends documents through the escrow account system

• Escrow account department audits capability (approval/rejection)

• If approved, the system is updated 

Required document (non-negotiable)

DLD lists “Payment plan for the project” as a required document.

Key service terms that drive audit readiness

DLD’s service terms include:

• A recent DLD technical report (not older than 3 months), with no red flags in final stages 

• Conditional activation paths depending on whether there is a bank guarantee, developer contribution, financing/mortgage deposits, or financial solvency—often tied to completion thresholds like 20% (as described in DLD service terms).

The evidence pack auditors expect (and why weak files cause real delays)

If you want a “clean” escrow audit outcome, you need an evidence pack that proves:

A) The escrow account is structured correctly

• Escrow/guarantee account exists for the project

• It is opened in the project’s name and used exclusively for project construction purposes 

• Separate account is maintained per project (if developer has multiple projects) 

B) Deposits are complete and traceable

• Buyer receipts map to unit/customer ledgers and match escrow deposits

• Mortgage partner receipts and project financing deposits are included (where applicable) 

• If financing was obtained via mortgage/loan, escrow law requires financing establishments to deposit the loan sum into the guarantee account to be disposed pursuant to the law. 

C) Disbursements are supported and eligible

• Contracts, invoices, approvals, and supporting documentation exist for payees

• Payments match project scope and progress

• Marketing payments are tracked carefully against restrictions (DLD’s FAQ gives the 5% of total sales example). 

D) Progress evidence matches payment triggers

• The written agreement defines major stages/milestones and release criteria

• DLD states the trustee engineer visits the site and checks completion before disbursing payments. 

E) Retention is handled correctly

• Retention (5%) is withheld according to the one-year post-completion requirement described in Article (14). 

Common Escrow Audit Findings (and How to Fix Them)

Navigating the Dubai real estate sector requires proactive governance to avoid penalties. Many developers in the UAE encounter hurdles during the RERA audit process due to administrative gaps. Utilizing the best RERA audit services helps help real estate firms and associations in Dubai identify risks early. Maintaining a strong relationship with the RERA trust department and hiring RERA auditors in Dubai with deep experience in project trust account management is essential for developers to comply with RERA.

• Mismatched Inflows: Discrepancies between sales receipts and deposits. Fix: Perform monthly reconciliations to ensure project escrow accounts match Oqood records.

• Ineligible Expenses: Paying corporate overheads from escrow violates RERA audit laws. Fix: Follow guidelines prescribed by RERA to ensure funds only cover construction and approved marketing.

• Weak Milestone Evidence: RERA requires verified progress for fund release. Fix: Ensure the trustee engineer’s report is current before seeking audit solutions.

• Retention Errors: Mismanaging the 5% defect guarantee. Fix: Use documented trust account audit procedures to track post-completion holds.

• Reporting Gaps: Poor records make it hard for us to prepare accurate audit files. Fix: Work with firms registered under RERA to streamline audits as required by RERA.

Step-by-Step: How to Prepare for an Escrow Account Audit in Dubai

Preparing for a RERA audit in Dubai requires a systematic approach to ensure all financial activities align with the Dubai Land Department to provide maximum security for investor funds. Establishing a strong relationship with RERA allows us to navigate the complexities of the audit cycle, which typically moves from operational setup to construction-phase financial tracking and final compliance. By maintaining meticulous records and utilizing specialized services in the UAE, developers can seamlessly get their project escrow accounts cleared, as our relationship with RERA allows us to obtain timely clarifications on any regulatory shifts.

Phase 1: Pre-Audit Documentation & Planning

• Appoint an Approved Auditor: Ensure you engage a firm registered with the DLD to carry out audits as required by RERA.

• Organize Project Financials: Gather all sales receipts, bank statements, and the R/T/02 cash flow statements used during the account opening.

• Verify Oqood/TAS Entries: Cross-check that all unit sales and buyer payments are accurately recorded in the Trust Account System (TAS).

Phase 2: Fieldwork & Verification

• Substantiate Disbursements: Prepare all invoices, contracts, and payment certificates for contractors and consultants.

• Technical Report Alignment: Ensure your internal progress reports match the latest DLD technical report to justify fund releases.

• Marketing & Admin Caps: Audit your marketing expenses to ensure they do not exceed the 5% threshold allowed under RERA audit laws.

Phase 3: Final Review & Submission

• Validate Retention Funds: Confirm that the mandatory 5% retention is held in the guarantee account for the one-year defect liability period.

• Draft the Audit Report: Work with your auditor to finalize the findings, ensuring all regulatory standards are met.

• Upload to RERA Portal: Submit the final annual audit report through the official DLD electronic systems for final approval.

How Young & Right Can Help You With RERA Escrow Account Audit Dubai

Young & Right provides professional RERA audit services in Dubai to help real estate teams, including developers in the UAE and property developers in the UAE, meet RERA compliance and RERA requirements per RERA and applicable laws and regulations.

We support:

• Project trust account audits and project escrow accounts audited annually, as required by RERA

• Strong documented trust account audit procedures and clean financial statement support through our accounting services

• End-to-end RERA audit process—from reconciliations to prepare accurate audit reports and a compliant RERA audit report

• Practical coordination with stakeholders, supported by our working relationship with RERA and an auditor with the Dubai Land ecosystem, to help developers respond to amendments to the RERA guidelines and ongoing regulatory standards

Conclusion

In Dubai's real estate sector, financial transparency is the key to investor confidence. By ensuring your project trust account follows all laws prescribed by RERA, you protect your project’s future. Whether you are a new developer or an established firm, maintaining compliance with RERA is the most important step in your real estate business journey.