Value-Add Methodology
The Documents a Developer Should Show You
A pitch deck proves nothing. A title register entry, a construction escrow account and a notarial deed prove something specific, in a specific order, verifiable by a third party who is not the developer. This is the paper trail an allocator should request before the site visit, jurisdiction by jurisdiction.

Why the documents come before the tour
A render proves that a design team exists. It proves nothing about title, permit or completion risk. The principal evaluating an off-plan resort unit is being asked to fund construction before it exists, in a jurisdiction whose land law it may not practise daily. The only defence against that asymmetry is documentary. Each jurisdiction that regulates real estate development has built a specific chain of paper, issued by bodies independent of the seller, that the buyer can request and verify without relying on the developer's word.
This is a companion piece, not a substitute, to [[what-investors-look-for-in-a-developer]]. That analysis asks whether the operator is the kind of counterparty worth underwriting: track record, co-investment, cap-stack alignment, exit. This one asks a narrower, more mechanical question. Given a specific unit in a specific jurisdiction, which documents exist, what does each one prove, in what order should the buyer obtain them, and how does the buyer confirm that the copy in hand is genuine and current. Quality and paper are separate diligence tracks. Both are required.
The chain is jurisdictional, not universal. There is no single global standard for off-plan buyer protection. Some jurisdictions mandate a construction-linked escrow account policed by a regulator. Others rely on a notary's statutory duty of verification. Others rely on a federal disclosure filing. None of them are interchangeable, and a developer operating across borders should be able to produce the correct instrument for each one, not a generic reassurance.
United Arab Emirates (Dubai): escrow account, Oqood, title deed
The Dubai chain runs on three linked documents, in a fixed sequence. Law No. 8 of 2007 requires every developer selling units off-plan to open a project-dedicated escrow account before collecting payment, held by a Real Estate Regulatory Agency (RERA)-approved trustee bank and registered against that specific project with the Dubai Land Department (DLD). No creditor of the developer can attach the funds in it, and the trustee releases money to the developer only against certified construction milestones, not against the sales calendar.
The buyer's first document to request is the escrow account registration reference for the specific project, not a general assurance that "the project is escrowed." The DLD publishes project-level escrow status; a project without a registered escrow account, or one collecting payment before registration, is outside the regulated structure regardless of what the sales contract says.
The second document is the Oqood certificate. When the Sale and Purchase Agreement is signed, the developer is required to register it with the DLD through the Oqood system within 90 days; the resulting interim registration is the buyer's only registered evidence of the transaction until the building is complete. Oqood is not a title deed. It is the provisional record that precedes one.
At handover, Oqood converts into the title deed, DLD's permanent proof of ownership, issued only after the developer's completion notice, the final payment and the buyer's snagging inspection. Before any transfer at this stage, the developer must also issue a No Objection Certificate (NOC) confirming no outstanding service charges or instalments; DLD will not register a transfer without one. Every one of these instruments is independently verifiable, free of charge, through the DLD website or the Dubai REST app, which returns one of five statuses on a title deed check: valid, mortgaged, restrained, blocked or invalid. A buyer who has not run this check has not verified anything; they have only read a PDF the seller supplied.
Italy: permesso di costruire, fideiussione, visura catastale, atto notarile
The Italian chain is built around two independent professionals, a public registry and a mandatory insurance instrument. Construction on a new or reconstructed building requires a permesso di costruire (or, for lesser works, a SCIA), issued by the Comune under the Testo Unico dell'Edilizia (Presidential Decree 380/2001). The buyer's first document is the permit number and the Comune's confirmation that it is current, since a suspended or expired permit exposes the buyer to an unfinished, unauthorised structure regardless of what has been built.
*The second document is the fideiussione, the surety bond required under Legislative Decree 122 of 2005 for any sale of a building still under construction.* Article 2 obliges the developer to deliver the buyer a bank or insurance guarantee covering every sum paid until title transfers; Article 3 requires the surety to come from an authorised bank or insurer, not from the developer itself. The Consiglio Nazionale del Notariato treats the protection as non-waivable: a preliminary contract without it is defective, and the defect can only be raised by the buyer. The document to request is the surety's policy number and issuing institution, checked directly with that institution, not with the developer's sales office.
The third and fourth documents predate any signature. The visura catastale, issued by the Agenzia delle Entrate, confirms the property's cadastral identity: category, surface, and registered owner. Since January 2025 it is available free online to the registered rights-holder through the Agenzia's own portal, using SPID, electronic ID or the national services card. The visura ipotecaria, obtained from the Conservatoria dei Registri Immobiliari, is a separate document that discloses mortgages, liens and judicial encumbrances on the property, typically checked over a twenty-year window. A clean cadastral record and an encumbered mortgage record are two different findings; a buyer needs both.
*The transfer itself happens only through an atto notarile, the notarial deed, and Italian notaries carry statutory liability for the accuracy of the checks that precede it. The final document, confirmed only after construction, is the agibilità (habitability) certificate, filed since 2016 as a Segnalazione Certificata di Agibilità* (SCA) within fifteen days of finishing work, per Articles 24 and 25 of DPR 380/2001. A unit without a filed SCA is not legally habitable, whatever the finish level suggests on a site visit.
A clean render is not a clean title. The document that matters is the one issued by an office that does not work for the seller.
Victaura Research
Indonesia: Sertifikat, PPAT, Akta Jual Beli, BPN check
The Indonesian chain centres on a single licensed official and a national registry the buyer can query independently. Foreign-compatible structures typically hold land under Hak Guna Bangunan (HGB, right to build) rather than freehold Hak Milik, registered with the Badan Pertanahan Nasional (BPN), Indonesia's national land agency. The certificate the seller presents states registered owner, boundaries and any encumbrance; none of that is proof until it is checked against the BPN record itself.
The transfer instrument is the Akta Jual Beli (AJB), the deed of sale and purchase, which under Indonesian law is the only act capable of producing a valid change of registered title. It can be executed only by a Pejabat Pembuat Akta Tanah (PPAT), a licensed Land Deed Official who is statutorily required, before signing, to verify that the certificate is genuine, that the land carries no mortgage block, and that the physical description matches the BPN registry. A purchase agreement that never passes through a PPAT does not, in Indonesian law, transfer registered title, regardless of payment made.
*The document sequence for a buyer is therefore: request the certificate number, instruct an independent PPAT to run the formal certificate check (pengecekan sertifikat) directly at the local BPN office, and only then proceed to AJB execution. BPN also operates a public self-service channel, the Sentuh Tanahku application and the atrbpn.go.id portal, that lets a buyer confirm a land plot's registered status without going through the seller's intermediary at all. The rule that recurs across every credible source on Indonesian property diligence is the same: a photocopy from the seller is a starting point, never a conclusion. The BPN record is the conclusion.*
United Kingdom: title register, planning decision notice, new-build warranty
England and Wales run on a single centralised registry, which simplifies verification relative to the jurisdictions above. HM Land Registry (HMLR) holds records for most property sold since 1993, and its title register, title plan and title summary can be searched by address directly on GOV.UK. An online copy (£7) is useful for reconnaissance; only the official copy (£11), certified by HMLR and admissible in court, functions as legal proof of ownership, and a buyer relying on a developer-supplied scan rather than an official copy has not confirmed anything HMLR itself would stand behind.
For a development still under construction, the second document is the planning decision notice, issued by the relevant local planning authority once permission is granted, and searchable, for applications made since 2010, through the authority's own online register or the national register-of-planning-decisions service on GOV.UK. The notice records any conditions attached to the permission; a scheme built in variance from its own conditions can face enforcement action irrespective of what a brochure promises.
The third document is the new-build warranty and its accompanying Consumer Code coverage. Most new-build homes in the UK are covered by a structural warranty, most commonly NHBC's ten-year Buildmark policy, underpinned by inspections against NHBC Technical Standards during construction. The Consumer Code for Home Builders, supported by NHBC, Premier Guarantee, LABC Warranty and Checkmate, extends protection from reservation through two years after legal completion, including the right to a pre-completion snagging inspection. The document to request is the specific warranty provider and policy reference, not a generic statement that the scheme is "NHBC standard"; only a named policy number is checkable against the provider directly.
France: permis de construire, garantie financière d'achèvement, acte authentique
*French off-plan sales, structured as Vente en l'État Futur d'Achèvement (VEFA), transfer ownership of the land immediately and ownership of the building progressively as construction advances, which is precisely why the completion guarantee is not optional. Before any VEFA contract can be signed, the promoter must subscribe a garantie financière d'achèvement* (GFA), an external guarantee from a bank, insurer or mutual surety company that steps in to fund completion if the promoter defaults. Since building permits filed from 1 January 2015, French law requires this external, or "extrinsic," guarantee rather than a self-funded internal one; a promoter offering an internal guarantee on a post-2015 permit is offering a weaker instrument than the law contemplates as standard.
The document to request is the guarantor's name and the guarantee reference, verifiable directly with the issuing bank or insurer, alongside the permis de construire itself, since the guarantee and the permit are the two instruments that establish whether the project is authorised and financially covered to completion. The land parcel's cadastral identity can be checked independently on cadastre.gouv.fr, the Direction Générale des Finances Publiques's public cadastral plan service.
*The transaction itself becomes binding only through the acte authentique, the notarial deed, and the French notary carries a statutory duty to verify the developer's permits, the completion guarantee and the insurance cover of the construction professionals involved before the deed is signed. A reservation contract (contrat de réservation) is not the VEFA sale; it is a preliminary step, and the GFA reference is the document that should exist before any deposit beyond the statutory reservation deposit changes hands.*
United States: property report, county recorder, title insurance
The American federal-plus-county structure works differently from the other five jurisdictions: it is disclosure-based at the federal level and record-based at the county level, rather than escrow-based. The Interstate Land Sales Full Disclosure Act (ILSA), now administered by the Consumer Financial Protection Bureau, requires a developer of a subdivision or condominium with 100 or more non-exempt lots or units to register with the Bureau and deliver every purchaser a Property Report before any contract is signed, with a statutory minimum seven-day right to cancel after delivery. The document to request is the Property Report itself and, where applicable, the state-level condominium public offering statement; a development marketed without either, above the 100-unit threshold, is outside a registration regime it is legally required to be inside.
Title, separately, runs through the county, not the federal government. Deeds are recorded at the county recorder's (or register of deeds') office, and a title company's search of that chain of title, before closing, is what an Owner's Policy of title insurance, in the standardised form set by the American Land Title Association (ALTA), is underwritten against. The document to request is the preliminary title report or title commitment, issued by the title company ahead of closing, followed at closing by the recorded deed and the ALTA Owner's Policy itself, which remains in force for as long as the buyer or their heirs hold an interest in the property and defends against title defects predating the recorded deed.
| Jurisdiction | Core pre-completion instrument | What it proves | Issuing / verifying authority |
|---|---|---|---|
| UAE (Dubai) | Project escrow account + Oqood registration | Buyer funds are ring-fenced and released only against certified construction milestones | Dubai Land Department / RERA-approved trustee bank |
| Italy | Fideiussione (D.Lgs. 122/2005 surety) | Sums paid pre-completion are refundable via an external bank or insurer if the developer defaults | Bank or authorised insurer; verified independently of the developer |
| Indonesia | Akta Jual Beli via licensed PPAT | The only act that produces a valid change of registered title at the BPN | Pejabat Pembuat Akta Tanah, checked against Badan Pertanahan Nasional |
| United Kingdom | HM Land Registry official copy (title register + plan) | Certified, court-admissible proof of registered ownership and any charges | HM Land Registry, via GOV.UK |
| France | Garantie financière d'achèvement (GFA) | An external guarantor funds completion if the promoter defaults on a VEFA contract | Bank, insurer or mutual surety company; permit and guarantee verified by the notaire |
| United States | ILSA Property Report + ALTA Owner's Policy | Federally mandated pre-sale disclosure, plus insured protection against title defects | CFPB registration; title company issuing the ALTA policy against the county record |
The order of retrieval: a sequence that holds across jurisdictions
Despite the jurisdictional differences, the sequence in which a buyer should request documents is structurally similar everywhere. First, the permit or planning authorisation that makes construction lawful at all: permesso di costruire in Italy, the planning decision notice in the UK, the permis de construire in France, the underlying land certificate and building approvals in Indonesia, the DLD project registration in Dubai. Without this, every later document describes a building that is not legally allowed to exist as marketed.
Second, the instrument that protects money paid before completion: the escrow account in Dubai, the fideiussione in Italy, the GFA in France, the ILSA Property Report and rescission right in the US. This is the document that answers the single most consequential question in off-plan buying, what happens to the buyer's capital if the developer fails to finish.
Third, the registered evidence of the transaction itself, distinct from the final title: Oqood in Dubai, the signed and registered contrat de réservation / VEFA contract in France, the preliminary title commitment in the US. Fourth and last, the completion and transfer documents: the title deed in Dubai, the agibilità / SCA and atto notarile in Italy, the AJB in Indonesia, the recorded deed and ALTA Owner's Policy in the US, the updated HMLR entry in the UK. A buyer who is offered only the fourth category, a glossy completion certificate, without having seen the first three, has been shown the easiest document to produce and none of the ones that actually carry risk.
The sequence matters more than any single document. A completion certificate without an escrow reference is a photograph of the last step, offered in place of the first three.
Victaura Research
How to verify authenticity, without trusting the seller's copy
Every jurisdiction covered here now offers at least one verification channel that does not run through the developer. In Dubai, the DLD website and the Dubai REST app return a live status, valid, mortgaged, restrained, blocked or invalid, on any title deed, free of charge. In Italy, the visura catastale has been freely accessible online to a rights-holder via the Agenzia delle Entrate's own portal since January 2025, and the visura ipotecaria is obtainable from the Conservatoria independently of the seller. In Indonesia, the BPN's Sentuh Tanahku app and the atrbpn.go.id portal let a buyer check a land plot's registered status directly, and a licensed PPAT is statutorily obliged to run the formal certificate check before any AJB is signed. In the UK, only an HMLR official copy, not a developer-issued scan, is admissible as proof of ownership. In France, the GFA guarantor and the permit can each be confirmed directly with the issuing bank, insurer or Comune-equivalent authority, and the notary carries a statutory duty to have done so before the acte authentique. In the US, a title company's preliminary report is itself the independent verification, built from the county recorder's chain of title before an ALTA policy is underwritten.
The common failure mode, across every one of these jurisdictions, is the same: accepting a document because the developer supplied it, rather than because an independent authority confirmed it. A scanned title deed, an unverified surety policy number, a certificate photograph without a registry check behind it, all share the same defect. They may be entirely genuine. They may also not be. The verification channel exists precisely so the buyer does not have to guess which.
Honestly disclosed
This list is not exhaustive, and it should not be read as one. Each jurisdiction above carries additional documents, energy performance certificates, service-charge statements, homeowners' association bylaws, that matter for specific transactions but are not the core proof-of-title and proof-of-protection chain this piece maps. A buyer working a real transaction needs jurisdiction-specific legal counsel, not a blog article, to confirm the current state of the law and the specific documents applicable to that unit.
Verification channels described here can change without notice. Fees, portals and thresholds are current as of publication (Sentuh Tanahku, HMLR fees, ILSA's 100-unit threshold, the 2025 Agenzia delle Entrate portal change) and should be re-confirmed at the time of any transaction rather than assumed static. The sequence proposed in this piece, permit, then payment protection, then registered contract, then completion, is Victaura Research's synthesis of how these systems function, not a codified rule that appears verbatim in any single statute. It is offered as a working method, not as a substitute for jurisdiction-specific legal advice.
Skin in the game disclosure. Victaura, through its parent Greystone B.V. (Netherlands), holds an active operating position in prime resort property. Readers should assume commentary may be influenced by, or benefit, Greystone's position. This document is classified as marketing material under MiFID II Article 24(3). It is not investment advice.
Key takeaways
- - Dubai: escrow account (Law No. 8 of 2007) registered per project, then Oqood interim registration, then title deed at handover; verify live status free via DLD or the Dubai REST app.
- - Italy: permesso di costruire, then the fideiussione (D.Lgs. 122/2005 external surety), then visura catastale + visura ipotecaria, then atto notarile, then the SCA habitability filing within 15 days of works finishing (DPR 380/2001 Art. 25).
- - Indonesia: only an Akta Jual Beli executed by a licensed PPAT transfers registered title; verify the underlying certificate directly at BPN or via the Sentuh Tanahku app before signing.
- - UK: HM Land Registry holds records for most property sold since 1993; only the £11 official copy of the title register/plan is admissible proof of ownership, not a £7 online copy or a developer scan.
- - France: a VEFA sale requires an external garantie financière d'achèvement before contract signature (mandatory for permits filed from 1 January 2015); the notaire has a statutory duty to verify permit and guarantee before the acte authentique.
- - US: ILSA requires CFPB registration and a Property Report, with a 7-day rescission right, for developments of 100+ lots or units; title itself runs through the county recorder and an ALTA Owner's Policy.
- - The order of retrieval is structurally similar everywhere: lawful-to-build permit, then payment-protection instrument, then registered preliminary contract, then completion/transfer document.
- - The common failure mode across all six jurisdictions is accepting a developer-supplied copy instead of running the independent registry or regulator check each jurisdiction now offers, several of them free.
References
- Dubai Land Department, Law No. 8 of 2007 Concerning Escrow Accounts for Real Estate Development
- Dubai Land Department, Title Deed Verification service
- Dubai Land Department, Property Sale Registration
- Dubai Land Department, Issue Title Deed
- Italy, Decreto Legislativo 122/2005 (garanzia fideiussoria su immobili da costruire), Consiglio Nazionale del Notariato
- Italy, D.P.R. 380/2001, Testo Unico dell'Edilizia, Artt. 24-25 (Agibilità / SCA)
- Agenzia delle Entrate, Visura catastale, come e dove richiederla
- ATR/BPN, Sentuh Tanahku official land-certificate check platform
- SSEK Legal Consultants, Real Estate in Indonesia: Registration and Recording (AJB / PPAT regime)
- GOV.UK / HM Land Registry, Search the register (official copies, fees, coverage since 1993)
- GOV.UK, Search the register of planning decisions
- Consumer Code for Home Builders, What is the Code
- NHBC, Consumer protection codes, homeowner guidance
- Service-Public.fr, Vente en l'état futur d'achèvement (VEFA)
- Direction Générale des Finances Publiques, cadastre.gouv.fr official cadastral plan service
- 15 U.S.C. Chapter 42, Interstate Land Sales (official US Code)
- Consumer Financial Protection Bureau, Interstate Land Sales Full Disclosure Act supervisory guidance
- American Land Title Association, Title Insurance: A Comprehensive Overview
The information on this website is provided for informational purposes only and does not constitute an offer, solicitation, or financial advice. Indicated returns are estimates and are not guaranteed; past performance is not indicative of future results. Capital invested is at risk.
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