Jonathan Ingles: Tuesday morning. Tenant in Dubai opens their renewal notice. AED 500 itemised as an administrative fee. They assume it's — I don't know, part of registration, part of Ejari, something official. They pay it. The agent deposits it. Nobody files a dispute.
Ben Okonkwo: And this is happening... what, routinely?
Jonathan Ingles: Since at least 2011, when Marwan bin Ghalita — RERA's chief executive at the time — publicly warned agencies it was impermissible. Fifteen years. The Rental Disputes Center has called these clauses unenforceable. The DLD sets the only legitimate renewal charge: AED 120, the Ejari fee. Agents are charging two to four times that. Look, the rule exists. It's just... decorative.
Ben Okonkwo: Decorative. Interesting word for it.
Jonathan Ingles: What else do you call a regulatory warning from 2011 that is still being ignored in 2026?
Ben Okonkwo: Now — I want to separate two things there, because I think they might be doing different work in your argument.
Ben Okonkwo: The law's clarity isn't in dispute — Law No. 26 of 2007, amended by Law No. 33 of 2008, that framework is settled. The RDC exists under Decree No. 26 of 2013 specifically to hear these cases. Tenants have a real judicial mechanism. Now — what we don't actually know is whether they're using it.
Jonathan Ingles: What does that change?
Ben Okonkwo: It changes everything about the diagnosis. Because — okay, two completely different failure modes. Either tenants are filing RDC complaints and losing, or they're not filing at all. The first means the system is broken. The second means... tenants don't know they can. That Khaleej Times piece — Nandini Sircar, June 21st 2026 — a tenant literally asking how to contest a fee that wasn't even in their contract. That's not a defeated plaintiff. That's someone who didn't know the RDC existed.
Jonathan Ingles: Right, but — who benefits from that unawareness persisting?
Ben Okonkwo: That's your political read. I'm not dismissing it. I'm saying the complaint-driven model — where RERA isn't auditing agent books proactively, it's waiting for individual tenants to initiate — that's a structural design choice. Could be capture. Could just be how administrative systems default.
Jonathan Ingles: The Ejari fee is AED 120. That's the government's own ceiling — their number, via the Dubai REST App or trustee centers. Agents are charging up to AED 500. Frankly, the gap isn't accidental.
Ben Okonkwo: The gap is real. Whether it's intentional coordination or just... opportunism meeting low-awareness tenants — I don't think the evidence settles that yet.
Jonathan Ingles: Look, here's where it lands for me. The RDC's position isn't ambiguous — renewal fee clauses cannot lawfully be written into a lease. Full stop. So the 'administrative fee grey zone'? It's not a grey zone. It's a rebrand.
Ben Okonkwo: Hm. That's — yeah, that's the load-bearing point, isn't it.
Jonathan Ingles: The clause can't go in the lease at all. So if an agent is itemising AED 500 as 'administrative fee' on that Deira tenant's renewal notice — it doesn't matter what they call it. The RDC has already said the contractual basis for it cannot exist.
Ben Okonkwo: And the tenant can't contest what they don't — wait, actually, this is the part that gets me. The Ejari fee. It's still AED 120. Unchanged since the system launched. The government's own mandatory renewal cost is AED 120, and agents are charging two to four times that layered on top. The tenant in Deira sees one line item and assumes it's all... registration.
Jonathan Ingles: That's the mechanism. They bundle it, or they inflate it — Ejari plus the unauthorised surplus blurred into one number. Tenant can't identify it as contestable because it looks like a government charge.
Ben Okonkwo: Which means the complaint-driven model fails at exactly the moment it's most needed. If the burden is on the tenant to dispute, but the tenant can't recognise the charge as disputable... the RDC never even sees it.
Ben Okonkwo: Now — the question isn't whether Law No. 26 of 2007 is clear enough. It is. The RDC has confirmed these clauses are unenforceable. That's settled. The question is whether RERA shifts from complaint-driven enforcement to proactive — actually auditing what agents are charging — or whether the burden stays on individual tenants who, right, may not recognise the charge as unlawful in the first place. That's a structural design question. And I'm not sure anyone's seriously asking it.
Jonathan Ingles: They won't ask it. Proactive audits cost money. Political will. You're disrupting an industry that moves transactions. Law No. 26 of 2007 stays on the books, RERA gets to cite it when a journalist calls, and the AED 500 keeps landing on renewal notices. The rule exists to be cited. Not enforced.
Ben Okonkwo: Fifteen years from now someone will probably write another article about this.
