Important Legal Recommendations

The executive regulation of White Land Fees was recently issued to promote urban development and increase real estate supply by encouraging owners to develop and utilize their lands. The regulation has direct legal implications for landowners and real estate companies, making it necessary to review its updates and determine appropriate legal steps to ensure compliance and avoid liabilities.

Q: Which lands are subject to the fees

All undeveloped land over 5,000 m² that is developable and located within the urban boundary designated by the Minister of Municipal and Rural Affairs and Housing.

Q: What is meant by "construction" in the regulation

Constructing complete buildings and structures on the land pursuant to duly issued building permits and in line with applicable requirements.

Q: What is meant by "land development"

Complete execution of infrastructure in accordance with the issued permits, regulatory requirements, and the approved master plan.

Q: Who is the taxable person (mukallaf)

Any natural or legal person in whose name the land is registered when the fee invoice is issued, including successors by law or Sharia.

Q: What is the "geographical scope"

The spatial boundary encompassing a group of lands within the city subject to the fee application.

Q: When do fees begin to apply

Application in Riyadh City starts on 1 January 2026, as announced by the Ministry of Municipal and Rural Affairs and Housing.

The owner should verify:

• The land’s location within the specified urban boundary.
• Whether it qualifies as "white land."
• That permits and development requirements are fulfilled.
• The clarity of the taxable person’s legal status.

Owners are advised to retain all title deeds and documents evidencing non-applicability or justifying an exemption.

Fee percentages by tier:

• Tier 1 (highest priority): annual fee of 10% of the property value.
• Tier 2 (high priority): annual fee of 7.5% of the property value.
• Tier 3 (medium priority): annual fee of 5% of the property value.
• Tier 4 (low priority): annual fee of 2.5% of the property value.
• Tier 5 (outside priorities): no annual fee.

Conditions for fee application to a land:

• The land is white (undeveloped).
• It is developable or buildable.
• It lies within the urban boundary designated by the minister.
• Its area or the aggregate of owned lands is not less than 5,000 m².
• Its use falls within the uses designated by the minister.

Conditions for fee suspension:

The fee stops when any of the following occurs:

• Loss of any statutory condition, such as area dropping below 5,000 m².
• Existence of a real legal or judicial impediment preventing disposition during the payment period.
• An administrative barrier preventing issuance of permits despite meeting requirements.
• Full development or construction before the end of the due period.

If the fee stops for part of a land only, the fee applies to the remaining part.

The owner may file a written objection within 60 days from notification of the fee decision before the Committee for Violations under the White Land Fees Law. He may then appeal before the Administrative Court (Board of Grievances) within 60 days from the committee’s decision.

• Register lands within the specified deadlines and disclose all data.
• Monetary fines up to twice the due fee for non-compliance.
• Fees may continue even after ownership transfer to a new owner.
• Real estate deals may be impeded if the land is listed among defaulters.

• Early registration through the designated White Land platform.
• Prepare a complete legal file including title deeds and official documents.
• Add clear clauses in real estate contracts (sale partnership development) allocating fee liability.
• Engage a specialized legal advisor to track regulatory updates.
• Request statutory exemption where documented legal or regulatory impediments exist.

The taxable person may request fee exemption if the land is:

• Endowed (waqf).
• Allocated for public benefit.
• Or subject to an official decision preventing its use.

The request should be supported by documents (title deeds decisions official letters).

Fees are calculated based on fair market value per the Ministry’s approved valuation standards. The owner may contest the valuation if there are errors or exaggeration. Review by accredited valuers is recommended to ensure accuracy.

• Restructure ownership through companies or investment funds.
• Partial subdivision to reduce financial burden.
• Partner with qualified developers to turn fees into investment value.
• Utilize statutory exceptions for non-developable lands.
• Reassess strategy via sale or long-term leasing.
• Expedite building and development permits to avoid being subject to the fee.

Are fees applied to all lands

No, only to white lands within the announced urban boundary.

Does building a perimeter wall exempt from fees

No, a wall is not considered development.

Can the fee be refunded after payment

Yes, in certain cases allowed by the law.

Are heirs’ and partners’ holdings aggregated

They are counted according to each party’s share unless ownership is unified under a single entity.

Applying the executive regulation of White Land Fees requires precise understanding and full compliance. AT Lawyers & Consultants confirms its readiness to provide specialized legal support to clients through:

• Preparing and reviewing legal memoranda and objections.
• Representation before competent committees.
• Legal opinions on compliant development strategies.
• Exploring lawful solutions to avoid fee imposition.
• Preparing legal studies and reports to support investors’ decisions.

📩 Contact:

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🏢 Riyadh – Al-Malqa – Anas Bin Malik Road

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