Major Real Estate Development Projects in Syria: Towards a Framework Linking Investment to the Protection of Property Rights and Occupants and Guaranteeing Objection and Compensation

Mazen Ezzi, Mohamad Manar Hemejo

Executive summary

This paper approaches major real estate development projects as a test of how reconstruction is managed in Syria, rather than merely as investment or urban development projects. When land and property become a means of attracting finance and reactivating assets, protecting housing, land, and property rights becomes a necessary condition for preventing investment from turning into a tool for redistributing space and value outside a clear rights-based process.

The risks arise from a gap between the speed with which projects are proposed and the slow pace at which the Syrian war’s effects on ownership, documentation, and occupancy are addressed. This gap appears in projects such as “New Damascus” and the coastal Al-Bassa project, where more investment and urban-planning information is available than rights-related information concerning the boundaries of the land, its legal status, rights holders, occupants, and the procedures for objection and compensation. The central role of the Syrian Sovereign Fund in consolidating assets and offering them for investment further increases the need for transparency concerning the origins of these assets, how they are valued, and the existing rights attached to them.

The paper proposes a temporary framework to precede contracting and implementation in major real estate development projects. This framework is based on publishing information about land and property, identifying the legal process applicable to each project, establishing local claims registers, adopting a multi-source mechanism for proving rights, suspending any final disposal of land until objections have been resolved, and separating the roles of the owning, regulatory, implementing, and contracting bodies. Without these safeguards, reconstruction projects may create new property-related injustice, particularly against absentees, displaced people, occupants, and holders of rights that have not been formally documented.

First: The policy problem

Syria’s transitional administration is addressing real estate development within a fragile rights-related and institutional context. The issue concerns not only attracting external finance or launching major urban projects, but also the state’s ability to prevent these projects from becoming new means of redistributing land and housing before the rights of their owners have been established. Any large-scale development project not preceded by scrutiny of housing, land and property rights can create disputes over ownership, occupancy, compensation and the right to return to the original area. 

The Syrian authorities are proposing these projects at a time when the effects of the war remain embedded in the structure of property ownership itself. Years of internal displacement, exile and destruction have led to the loss of real estate documents, inability to access records or properties, and damage to some Land Records. Informal settlements and areas with building violations also continue to be governed by ownership and occupancy relationships that are not documented in the Land Registry. Introducing these areas into development projects before rights have been inventoried may therefore transfer the burden of the war onto rights holders themselves and make proof of ownership or possession a precondition for protection or compensation. 

These risks increase with the emerging role of the Syrian Sovereign Fund (SSF) in offering assets and property for investment. The fund is presented as a central channel for reactivating public and unused assets, but it requires publicly available rules determining how properties are selected, valued, and transferred into investment and how existing rights attached to them are addressed. Without such transparency, the fund may shift from being an asset-management tool into a process that bypasses traditional safeguards for protecting rights.

This problem appears in projects such as the “New Damascus Project” and the coastal Al-Bassa project. The available information points to large-scale projects with administrative, residential and commercial functions, but does not provide sufficient detail concerning the boundaries of the land, its legal status, the nature of existing ownership, or the fate of occupants and potential rights holders. The currently available information does not allow any definitive conclusion that specific violations have occurred, but it is sufficient to reveal a gap between the scale of the investment proposals and the limited rights-related information that has been published. 

This gap is inseparable from urban planning and the legal process applicable to the projects. A zoning plan determines land use, value, the fate of existing buildings and the share of rights holders in any subsequent project. The project’s legal process also determines the responsible authority, how the land is secured, and the mechanisms for objection and compensation. It is not sufficient to present a project as an investment opportunity before clarifying whether it will be established as a real estate development and investment zone, managed as a direct investment, or implemented through a private partnership arrangement. 

Accordingly, the principal policy problem is the absence of a transitional framework linking every major real estate development project to prior scrutiny of housing, land, and property rights. Such a framework requires the publication of project boundaries before contracting, disclosure of the legal status of the land before it is offered to investors, an inventory of ownership, occupancy and usufruct rights, an opportunity to object before implementation, and the establishment of compensation principles before land use is changed or its value redistributed. Without these conditions, real estate development may shift from an entry point for reconstruction into a tool for creating new property-related injustice, particularly against absent people, displaced people, occupants, and holders of incomplete documentation.

Second: real estate development projects and areas of risk

The major real estate projects presented by SSF officials during the Syrian–Emirati Investment Forum, held in Damascus on May 11, 2026, reveal a gradual transition from general discussions about attracting investment towards identifying land and areas that can be converted into large-scale urban, residential and commercial projects. The forum did not result in any signed investment agreements or memoranda of understanding, but it did demonstrate the fund’s role in consolidating real estate assets and presenting them to investors.

The sensitivity of this transition lies in the fact that the land itself becomes the subject of investment, together with the private ownership, public property, occupancy, usufruct rights, different uses, and unresolved disputes arising from the years of war that it carries. These projects cannot be evaluated solely from the perspective of finance or urban design—they must also be assessed in terms of their potential impact on housing, land, and property rights.

The “New Damascus Project” stands out as the clearest example of this direction. It was presented as part of a package of major urban projects offered for investment on both sides of the Damascus-Beirut highway, extending from the Mazzeh motorway to the Sabboura area in Rural Damascus, over an area of 3,300 hectares. 

The project is not proposed as an ordinary urban extension, but as a new mixed-use city including residential and commercial neighbourhoods, educational, health and recreational facilities, and extensive infrastructure. Published information also indicates that it may include diplomatic, financial and residential functions, with plots allocated to private investors. Investment requirements were estimated at between USD 40 billion and USD 50 billion, including USD 7.6 billion for infrastructure. 

A project of this scale makes it essential to determine the legal status of the land included in it, identify rights holders and occupants, and establish the mechanism by which land will be converted into plots and investment opportunities before any contract is signed.

The information presented concerning the fate of existing residents within the project area further increases the importance of a rights-based process before implementation. Two compensation mechanisms have been proposed: occupants of state-owned land would receive financial compensation for vacating it, while landowners, including owners in parts of Western Dummar, Moadamiyeh, Mazzeh and parts of Qudsaya suburb, would be given the option of receiving shares in the new project or financial compensation. 

This process covers approximately 700 properties. It transforms compensation from a general question into a matter requiring detailed legal treatment concerning the basis for distinguishing occupants from owners, the method used to calculate compensation, the mechanism for calculating shares, and the rights of heirs, absentees, tenants, and holders of incomplete documentation.

Urban development pressure around the Damascus-Beirut highway also extends to smaller projects. The “Damascus Hills Complex” project was proposed in the Dimas area of Rural Damascus, on the western side of the highway, for the development of residential buildings and schools over an area of 284 hectares, with an estimated investment value of USD 384 million. 

There was no information concerning the legal status of the land, the owning authority, or the existence of occupants and existing rights. Its significance, however, lies in the fact that it reveals a direction towards treating the highway’s surroundings as a multi-project investment belt, requiring rights-related scrutiny across the entire area rather than only within the boundaries of the “New Damascus” project.

By contrast, the coastal Al-Bassa project is more developed from an investment perspective but remains unclear from a rights-related perspective. The project was presented under the name Laodicea Ad Mare and extends for more than 10 kilometres between Al-Bassa and Al-Sanobar in the southern countryside of Lattakia city, over an area of 1,150 hectares. It has an estimated investment value of between USD 20 billion and USD 30 billion. The project is not limited to tourism facilities; it combines residential complexes, tourism facilities, shopping centres and a golf course. This makes it closer to a project for reshaping a large, multifunctional coastal strip than to a limited tourism investment. 

The breadth of the available urban and investment information concerning Laodicea Ad Mare is not matched by comparable clarity in the rights-related information. The available information does not clarify the legal status of the land between Al-Bassa and Al-Sanobar or whether it includes private property, state property, existing occupancies, homes, structures or usufruct rights. No information is available concerning the mechanism for identifying rights holders, compensating them or enabling them to object. The project could therefore become a clear example of the gap between its detailed presentation as an investment opportunity and its opacity as a housing, land and property rights issue. 

The importance of these projects is also connected to the context in which they were presented. The forum demonstrated openness to potential Gulf partnerships in real estate development projects, but did not result in the signing of investment agreements or memoranda of understanding. These projects remain at the proposal and partnership-seeking stage rather than implementation.

The forum should consequently be treated as a window into how land and projects are presented to investors, rather than as the sole framework for understanding the course of real estate development in Syria. The rights-related risk does not arise from the nationality of the investor, but from the absence of prior information concerning the land included, the existing rights attached to it and the safeguards preceding contracting and implementation.

The significance of the projects extends beyond the “New Damascus Project” and Al-Bassa. Officials in the SSF’s Real Estate Development Sector announced that the fund holds more than 7,000 hectares of land allocated for real estate development at 47 sites across Syria. This figure makes the matter broader than 1 or 2 projects and requires major real estate development projects to be treated as a potential public policy for land reuse, rather than as isolated investment initiatives. While this scale expands the fund’s capacity to attract investors, it also increases the need to scrutinise housing, land and property rights before any new site is offered for investment. 

This question becomes more important in the absence of a clear announcement concerning the legal process applicable to each project. The available information does not clarify whether the “New Damascus Project”, Al-Bassa or other proposed sites will be established as real estate development and investment zones, offered as direct investments in real estate assets managed by the fund, or implemented through partnership agreements with developers and investors. This uncertainty concerns not only the administrative form but also directly affects housing, land and property rights, because each process produces different consequences for the inventory of rights, compensation, alternative housing, objections, subdivision and real estate registration. 

The risks begin before implementation. Every large-scale project assumes an existing ability to determine the legal status of the land and property included in it. This ability remains limited by the effects of the war on documents, records, and access to property. Although processes have been launched to restore cadastral records and digitise the Land Registry, addressing this gap requires more time than the pace at which investment projects are being proposed. Introducing land into development projects before the completion of rights inventories may shift disputes to the post-contracting stage and impose on rights holders a delayed and weaker burden of proof.

These risks are also connected to the failure to update urban plans in destroyed or damaged areas and to the question of how informal settlements that expanded during the war will be treated. Local councils face difficulties in regularising these areas legally, while regional committees appear almost absent, and the Engineers’ Syndicate has not yet been consulted regarding the proposed real estate projects.

Economic feasibility studies or announcements of new projects are therefore insufficient to assess their feasibility. Before any large-scale real estate development project is launched, the following issues require clear treatment: proof of ownership, updated plans, the role of local councils, the participation of technical bodies, and legal safeguards allowing objections and disputes to be resolved before the land becomes an investment asset. 

Third: Risks in the legal and institutional framework

The legal and institutional risks begin with the body that will lead the presentation of land and property for development projects. The SSF was established under Decree No. 113 of 2025 as a public institution of an economic nature, affiliated with the Presidency of the Republic and enjoying legal personality and financial and administrative independence.

This structure places it in a central position in managing unused government assets and converting them into development and productive projects. Its position becomes sensitive in real estate development because the fund does not deal solely with liquid assets, but also with property and land that may be connected to ownership, occupancy or usufruct rights, or disputes that have not yet been resolved.

Real estate development projects also do not operate in a legal vacuum. Following the repeal of Real Estate Development and Investment Law No. 15 of 2008, real estate development and investment projects became subject to Investment Law No. 18 of 2021, as amended by Law No. 2 of 2023. The powers of the General Commission for Real Estate Development and Investment were transferred to the Syrian Investment Agency (SIA). The executive instructions for Law No. 2 of 2023 also regulated the establishment of real estate development and investment zones, the development plan, the securing of land, contracting with developers, implementation of infrastructure, subdivision, registration, and the relationship between the real estate developer and the responsible administrative authority. 

This framework itself, however, presents rights-related and institutional risks. The executive instructions were issued under 2 separate Resolutions, Nos. 1575 and 1576, which overlap in their scope of application and in defining the relationship between the public authority and the real estate developer. Incorporating real estate development into the Investment Law also strengthened the logic of attracting investment and providing incentives without eliminating the tension between the rapid offering of land for investment and the slow inventory of rights and settlement of disputes. 

The central question is whether the proposed projects will actually follow the process for establishing real estate development and investment zones, including establishment decisions, plans and responsible authorities, or whether the land and real estate will be treated as investment assets available for contracting before rights have been fully inventoried and their legal status resolved. In either case, announcing the project or presenting the land to investors is insufficient before clarifying its legal status, the rights of occupants and owners, and the objection and compensation mechanism. 

The dangers of this framework become particularly apparent in areas where documented ownership is mixed with unregistered occupancy, licensed construction with building violations, and private land with agricultural land used for housing or with state property. The 2023 executive instructions reopened the possibility of establishing real estate development and investment zones within or outside urban plans and within informal-settlement areas. They did not, however, eliminate the distinctions between a registered owner, an occupant, the owner of an unlicensed building, and the owner of land whose actual use has changed without its legal status being amended.

One of the most sensitive points is that unlawful occupants of state property are entitled only to remove the rubble of their buildings, while they may be allocated non-free alternative housing at cost, subject to availability, either inside or outside their original area. This means that the legal process selected for a project may determine in practice whether a person is treated as an owner, a holder of a housing right, an occupant requiring regularisation, or an unlawful occupant entitled only to limited compensation and conditional alternative housing. 

The SSF does not operate alone within the reconstruction structure. Alongside it, the Syrian Development Fund (SYDF), established under Decree No. 112 of 2025, has emerged as a channel for financing infrastructure and essential-service projects and supporting administrative units in rehabilitating damaged areas, removing rubble and repairing homes. Available information also indicates that the SYDF, the Syrian Investment Agency and the SSF operate under the umbrella of the Higher Council for Economic Development (HCED). This makes real estate development part of a broader institutional structure combining finance, investment, asset management, planning and reconstruction. 

That means it is not enough to scrutinise the role of the SSF alone. The relationship between these bodies, the limits of their respective powers, and the process preventing housing and infrastructure projects from shifting from public support into property investment without prior rights safeguards must also be clarified.

The fund’s role in real estate development projects presents an additional problem concerning overlapping functions. The fund may simultaneously manage assets, offer land and real estate, negotiate with investors, and supervise implementation, amid a reorganisation of existing real estate development companies and their relationship with the Syrian Investment Agency. In projects affecting housing, land and property rights, this overlap may weaken transparency unless the powers of the landowner, the regulatory authority, the contracting authority and the body receiving objections from rights holders are clearly separated. 

The issue became yet more sensitive with the SSF’s recent announcement that it owns or manages a real estate portfolio of approximately 2,000 properties with an estimated value of up to USD 2.5 billion. The problem concerns not only the size of the portfolio, but also the absence of published information about the nature of the properties it contains, their locations, legal status, valuation methods and the existing rights attached to them. This is particularly important because assets offered for investment are not necessarily limited to public property in the narrow sense. They may include state-owned assets or assets transferred to the fund through confiscation, settlement or ownership-transfer processes whose details have not been published. In such cases, describing an asset as an “investment opportunity” is insufficient. Its legal origin and any previous or existing rights attached to it must be identified before it is introduced into a contract or partnership. 

The limitations of financial oversight of the SSF become apparent here. Even if its revenues and expenditures are audited, this is insufficient to protect housing, land and property rights unless oversight also covers the origins of the properties offered, their legal status, and existing rights or disputes. The SSF’s governance should therefore not be measured only by its ability to attract investment, but also by its ability to prevent real estate assets from being converted into contractual opportunities before rights-related scrutiny has been completed. 

An additional problem concerns the legal safeguards available to both investors and rights holders. Weak confidence in the judicial system does not merely slow investment. It also weakens the ability of owners, occupants, heirs, holders of unregistered contracts, displaced people, and absentees to protect their rights before implementation begins. In projects of this scale, an administrative process within the implementing body or the body owning the asset is insufficient. An independent and effective objection process must be available before the land becomes part of a major investment project.

Accordingly, the institutional risks lie in the possible concentration of several functions within a single process: asset management, offering land to investors, negotiation, planning, and supervision of implementation. This concentration may accelerate the launch of projects, but it weakens rights holders’ ability to know what will happen to their land or object to it. Major real estate development projects require a clearer separation between the owning, regulatory, and contracting authorities, and any proposed investment must be linked in advance to rights-related scrutiny and an objection and compensation process.

Fourth: Public policy options

The transitional administration needs a special framework for major real estate development projects that does not merely regulate relations with investors, but restructures the relationship between investment and rights. This framework should move scrutiny of housing, land, and property rights from a stage following implementation to one preceding contracting. The issue is not merely technical, but concerns whether the land will enter investment as an asset considered free of disputes, or as an area subject to ownership, occupancy, and rights that require settlement beforehand.

The first option is to make transparency a condition for classifying the project itself. Before determining the project’s cost or partnership structure, it must be clear whether the land will be subject to the legal process governing a real estate development and investment zone, offered for direct investment, or managed through a special partnership arrangement. 

This classification determines the responsible authority, the method of securing the land, the rules for subdivision and registration, and the scope of the rights of owners, occupants and usufruct holders. Urban and investment information is therefore insufficient unless accompanied by rights-related and legal information concerning the project boundaries and the land included in it. 

The second option involves treating urban planning as a tool for confirming rights rather than as a separate technical stage. A zoning plan determines land use, value and the share of rights holders in the project, and may transform existing ownership and occupancy into compensation, shares or replacement units. Any zoning amendment should be preceded by scrutiny of ownership, possession and actual land use, particularly in destroyed areas, informal settlements and land used for housing without complete documentation. 

The third option is to separate the state’s functions within the project. Combining asset management, offering land, negotiating with investors, planning, and considering objections within a single process accelerates contracting but weakens the protection of rights holders. Any policy framework requires a clear distribution of roles between the body owning or managing the asset, the body regulating investment, the technical authority responsible for planning, and the body receiving objections and deciding compensation.

In this sense, objection and compensation become part of the design of the project rather than a corrective procedure introduced after implementation begins.

Fifth: Implementation recommendations

The following recommendations translate the preceding options into specific measures distributed among the authorities responsible for investment, asset management, planning and the protection of rights.

1- The transitional administration should issue a temporary framework specifically governing major real estate development projects, linking any project affecting housing, land, and property rights to prior scrutiny of those rights before contracts are signed or land is introduced into any investment partnership.

2- The Syrian Investment Agency and the bodies regulating investment should determine the legal process applicable to each project before presenting it to investors, including whether it will be subject to Investment Law No. 18 of 2021, as amended by Law No. 2 of 2023 and its executive instructions, or to another legal arrangement.

3- The Syrian Sovereign Fund should publish information concerning the land and property it intends to offer for investment, particularly their location, area, legal status, the source of their transfer to the fund, the body owning or managing them, and the method used to value them.

4- The Ministry of Local Administration and Environment, in coordination with administrative units, should establish a local claims register in every area included within a major real estate development project, allowing rights holders to submit official and alternative documentation under a clear verification mechanism.

5- Local administrative units should suspend any final disposal of land or change in its use within development-project areas until the initial objection period has ended and the principal claims have been resolved.

6- The transitional administration should separate institutional roles within major real estate development projects between the body owning or managing the assets, the body regulating urban planning, the body contracting with investors, and the body considering objections submitted by rights holders, while linking any international support to standards protecting housing, land and property rights.