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Seven Escrow Regimes. One Cashflow Engine.

Seven Escrow Regimes. One Cashflow Engine.

Rashdan·19 Oct 2026·3 min readJurisdiction

Seven escrow regimes. Six countries. One cashflow engine. Most proformas treat off-plan buyer payments as a single inflow line — but every jurisdiction runs its own legal machine. Here is how each one works, and how FeasiBuild models it natively.

Australia — 10/90 Rule

10% deposit at contract, 90% at completion. No project escrow — the deposit is held under state conveyancing trust rules, and the developer carries interest on equity until settlement.

  • Governing law: Conveyancing Act 1919 (NSW) · Property Law Act 1974 (Qld) · Sale of Land Act 1962 (Vic)
  • Retention: none — no escrow account exists
  • In FeasiBuild: 10/90 timing + interest carry; splits editable (20/80, 30/70)

China — Closed-Loop Escrow Rule

Pre-sale proceeds enter government-supervised bank accounts; withdrawals are ring-fenced to construction of that project and released node by node.

  • Governing law: Urban Real Estate Administration Law (PRC) · MOHURD Measures · municipal pre-sale funds supervision measures
  • Retention: 3% of building works retained from the main contractor for 24 months post-completion
  • In FeasiBuild: node-gated releases; zero free cash before certification

India — Proportionate Escrow Rule

70% of every buyer payment is locked in the designated account; 30% is immediate free cash. Withdrawals equal certified completion % × permitted cost, and the lender sweep is locked ON.

  • Governing law: RERA 2016 s.4(2)(l)(D) & s.4(3) · State RERAs (MahaRERA, TS RERA…)
  • Retention: none — the five-year structural defect liability is a separate legal obligation
  • In FeasiBuild: 70% split and sweep locked for India; editable elsewhere

Malaysia — Progress Drawdown Rule

Payments enter the statutorily controlled Housing Development Account; withdrawals only per certified Schedule of Progress stages.

  • Governing law: Housing Development (Control and Licensing) Act 1966 (Act 118) + Regulations 1989 · KPKT
  • Retention: 5% of GDV — 2.5% released after 8 months, remaining 2.5% after 24 months
  • In FeasiBuild: stage-based drawdown curve, native

Saudi Arabia — Milestone & Retention Escrow Rule

Payments enter supervised escrow; certified milestone releases apply with a 20% completion floor (locked), and the lender sweep is locked ON.

  • Governing law: Off-Plan Sale & Lease Law + Implementing Regulations (Wafi programme) · REGA
  • Retention: 20% completion floor (locked) + 5% held for 12 months after completion
  • In FeasiBuild: floor and sweep locked for KSA

UAE · Abu Dhabi — Project Guarantee Account Rule

Buyer payments enter a project guarantee account; developer access only against certified project progress.

  • Governing law: Abu Dhabi Law No. 3 of 2015 · DMT — Real Estate Regulatory Committee
  • Retention: 5% held for 12 months after project completion
  • In FeasiBuild: native preset in the cashflow engine

UAE · Dubai — Staged Escrow Rule

Payments are locked in project escrow, released at certified construction milestones, with retention held to handover.

  • Governing law: Law No. 8 of 2007 · Dubai Land Department (DLD) / RERA
  • Retention: 5% of GDV held for 12 months after completion
  • In FeasiBuild: milestone releases + retention, automatic

Everywhere Else

Market not on the list? Pin-drop any country: choose the No-Escrow Rule, or adopt and edit any of the seven regimes — split %, certification cadence, sweep, retention, horizon. The mechanism is not a country label.

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