This is where markets differ most, and the one to check first. Some countries ring-fence buyers' money by law. In others, your protection is only what your contract says. A familiar word like "escrow" on a brochure proves nothing until you know which regime applies.
Pick the market you know and the one you're looking at to see them side by side. These are the closest equivalents, not exact matches, because the law behind each term differs by country.
United Kingdom
- Structural warranty
- NHBC Buildmark
- Deposit protection
New-builds commonly carry a 10-year warranty. NHBC Buildmark, for example, combines deposit protection if the builder becomes insolvent, a two-year builder warranty and eight further years of structural cover.
Watch for: Providers and terms vary. Check who provides the warranty on your home and what it excludes.
Source: Lovell, new home warranties · Barratt Homes, NHBC Buildmark
Dubai
- Escrow account
- Oqood
By law, buyers' off-plan payments go into a project escrow account with an approved agent, and the sale is recorded on the interim register, Oqood.
Watch for: Pay into the project's escrow account only, and check the project is registered with DLD.
Source: Dubai Law No. 8 of 2007 · Dubai Law No. 13 of 2008, Interim Real Property Register
Malaysia
- Housing Development Account
- Schedule H
- Progress payments
Licensed developers must keep a Housing Development Account for each project. Buyers' progress payments go into it, and withdrawals need an architect's, engineer's or quantity surveyor's certificate.
Watch for: This applies to licensed housing developers in Peninsular Malaysia. Check the developer's licence and whether your contract is a statutory Schedule G (landed) or Schedule H (strata) agreement.
Source: HBA, Housing Development Account regulations · HBA, purchasing a home
Georgia
- Contract protections
- Developer due diligence
We could not confirm a dedicated off-plan escrow regime. You are generally not the registered owner until the building is accepted and your unit is registered, so your protection rests on the contract and the developer's record.
Watch for: Some sellers offer earlier registration of the preliminary agreement, so ask exactly what is registered and check for a mortgage on the land.
Source: Realting, pitfalls of buying in Georgia · Chambers, Real Estate 2026: Georgia
Serbia
- Construction permit
- Pre-contract
- Staged payments
Lawyers advise that buying during construction is not safe without a valid construction permit, which can be checked in the public register. Payments should follow actual construction stages.
Watch for: We could not confirm a statutory escrow regime. Ask for a firm completion date, delay penalties and a right to terminate and be repaid.
Source: Stojković Attorneys, buying in Serbia · City Expert, buying under construction
Egypt
- Developer instalments
- Escrow (emerging)
Sources report no nationally standard off-plan escrow regime. Prime Ministerial Decree 2184 of 2022 requires developers to run a dedicated project bank account, post guarantees and report collections, though one source limits it to state-allocated land and its value to buyers in court is disputed.
Watch for: A draft law with compulsory project escrow and buyer protection funds had not passed when we checked. Ask whether your project uses escrow, and plan for currency risk on long instalment plans.
Source: Global Investments, buying off-plan in Egypt · Riad & Riad, off-plan development rules · Daily News Egypt, draft developers' law
Greece
- Preliminary agreement
- Bank guarantee
Two guides report no statutory escrow law for private off-plan sales. Some developers offer bank guarantees on deposits, and buyers negotiate for them.
Watch for: Protections must be written into the agreement before you pay. A correctly structured deposit agreement may let you claim double the deposit if the developer defaults, so ask your lawyer.
Source: Global Investments, buying off-plan in Greece · Global Law Experts, off-plan vs completed in Greece
Cyprus
- Contract deposit at the Land Registry
- Specific performance
Depositing the contract of sale at the Land Registry protects your claim to the property if the seller defaults, and supports a court order compelling transfer.
Watch for: Lodge it within six months of signing or you can lose this protection. It secures your claim to the property, not the money you have paid. Have a lawyer check any land mortgage and get the bank's release letter.
Source: Zeno Legal, Cyprus conveyancing 2026 · Kyprianou, Cyprus legal process, costs and VAT
Ethiopia
- Proclamation No. 1357/2024
- Closed bank account
The law, in force since 31 March 2025, bans false advertising and bars developers from taking advance payments before they hold a land certificate and building permit. For pre-sales by a local developer, Article 9 requires buyer money to go into a closed bank account. A home under 80% complete cannot be transferred without the buyer's consent, and none without its mechanical, electrical, plumbing and sanitary works.
Watch for: Confirm whether Article 9 covers your developer, including any foreign-backed developer. The escrow details depend on a separate regulation, which we could not locate. Ask a lawyer how your payments are held.
Source: Proclamation No. 1357/2024 (gazette) · Capital Ethiopia, mandatory escrow
Last checked 4 November 2026. Many sources are law firms and property guides rather than official texts, and rules change. This is general information, not legal or tax advice, so confirm the details for your purchase with a qualified local adviser.
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