Major risks for the Maldives

Five hundred hectares next to Malé will shape housing, tourism, traffic, labour demand and the skyline for the rest of the century. Awarding that block as a whole, without a public land-use plan, transfers the right to design the city.

Evidence so far

No land-use plan or masterplan for the 500 hectares has been published. Eagle Hills’ own concept is the only plan in public view.

What would reduce it

A state-approved masterplan, published for comment before land is handed over. Public land such as beaches, parks and civic plots fixed in the contract. Government approval required for each phase.

Watch for

Publication of a masterplan; how planning approval is handled in the Real Estate Bill.

Decided by

Ministry of Housing; People’s Majlis

A Real Estate Law drafted after the term sheet is signed is exposed to capture. Resetting 99-year leases, off-plan sale of city land, and master-developer discretion may be legalised because the deal needs them, not because they are the best public rule.

Evidence so far

Commercial terms were signed on 21 September. The Attorney General says the project depends on a Real Estate Law still being drafted. No bill has been reported as submitted.

What would reduce it

Publish the draft bill for public comment. Write general rules that would apply to any developer. Full committee scrutiny in the Majlis before any definitive agreement.

Watch for

Whether the bill’s terms fit only this project; whether the bill passes before or after the definitive agreement is signed.

Decided by

Attorney General’s Office; People’s Majlis

If every transfer starts a new 99-year term, the state’s reversion is politically and legally weakened. “The land is not sold” can coexist with the land never coming back under usable public control.

Evidence so far

Eagle Hills published a lease that starts a new term on each sale or inheritance. On 20 October the President said there is no automatic renewal. The conflict is unresolved in any text.

What would reduce it

A fixed expiry date for the head lease set in law. Unit leases that cannot outlast the head lease. No new term on transfer.

Watch for

Tenure clauses in the Real Estate Bill and the lease instrument.

Decided by

People’s Majlis; Ministry of Housing

The tourism sector’s stalled-island record shows that paper termination rights do not equal recovery. After foreign apartments are sold, recovery of unused Ras Malé land would confront buyer rights and diplomatic cost. The President’s 20 October statement adds a second exposure: if the state must buy every unit back after 99 years, the price rule and payment period decide whether that is a manageable reversion or a large future liability. For resorts the Tourism Act sets these rules. For Ras Malé they have not been stated.

Evidence so far

The buy-back claim has no stated price rule, payment period or re-tender mechanism. The Housing Minister says non-completion terms will be set in the definitive agreement.

What would reduce it

Step-in and termination rights tied to phase deadlines. A buy-back formula based on depreciated value, paid by an incoming buyer through re-tender, as with resorts. No obligation on the state to pay market price.

Watch for

Termination clauses; any buy-back formula in the bill or contract.

Decided by

Ministry of Housing; Attorney General’s Office

The land is being reclaimed at public initiative and public environmental cost. If development then waits on off-plan demand, the Maldives will have manufactured scarce land and then allowed it to be banked.

Evidence so far

The developer says funding will come from equity, loans and sales, with construction in about a year. The investment schedule has been deferred to the definitive agreement. iHavan and Faafu show that large announcements are not delivery.

What would reduce it

Binding phase deadlines, with undeveloped plots returning to the state. A minimum equity commitment before land handover. A performance bond.

Watch for

The investment schedule; equity requirements; land-handover terms.

Decided by

Ministry of Housing; Ministry of Finance

Schools, hospitals, marina operations, and especially power, water and waste, can become closed systems. That creates tariff, security, data and continuity risks that a housing-and-tourism state cannot treat as ordinary real-estate detail.

Evidence so far

No utility or services plan has been published. The 2025 township law requires townships to run their own energy and waste systems, a possible template, although Ras Malé is not a township.

What would reduce it

Utilities regulated by the national regulator, with tariff controls and state step-in rights. Service data held in the Maldives.

Watch for

Utility and services clauses; the regulator’s role in the bill.

Decided by

Utility Regulatory Authority; Ministry of Housing

Three resorts inside the site are already announced. If they sit outside ordinary tourism licensing and construction deadlines, the Maldives will have created a privileged hospitality zone beside the regulated resort industry.

Evidence so far

The government says no SEZ or Tourism Act tax relief applies, and that tourism GST will be charged.

What would reduce it

Resorts licensed under the Tourism Act, with the same deadlines, rents and levies as other resorts.

Watch for

How the three resorts are licensed.

Decided by

Ministry of Tourism

Ras Malé was sold to the public as the structural answer to Greater Malé housing. Allocating 500 hectares to a commercial enclave requires a transparent residual housing plan. That plan has not been published. The 5,000 Hulhumalé units are a side payment, not a substitute for a city plan.

Evidence so far

The 5,000 homes are at concept stage at Hulhumalé Urban Isle. The ministry says pledged Ras Malé plots are unaffected but has published no map.

What would reduce it

A published Greater Malé housing plan showing supply after the 500 hectares. A plot-level map of pledged land. Delivery dates and allocation rules for the 5,000 homes.

Watch for

An HDC land map; allocation rules; whether construction starts in early 2027 as claimed.

Decided by

Ministry of Housing; HDC

Alabbar has already indicated that Emaar may participate and that other investors will be invited. The likely operating model is: Eagle Hills keeps the masterplan and premium plots; other foreign companies take components. Maldivian firms risk becoming subcontractors on their own new city unless local equity and local operator quotas are hard conditions.

Evidence so far

Other investors, and local firms, have been invited in interviews. No assignment or local-content terms are public.

What would reduce it

State consent for any sub-concession or assignment. Local equity and procurement targets written into the contract. Public disclosure of every sub-developer.

Watch for

Assignment clauses; local-content terms.

Decided by

Ministry of Housing; Ministry of Economic Development

If this structure stands, every future reclaimed city — Giraavaru, Uthuru Thilafalhu, later phases — will be bargained on the same template: one foreign master developer, one special law, one unpublished plan. The scarcity value of new Maldivian land will have been institutionalised as a concession commodity.

Evidence so far

Ayla became the first township in December 2025. Ras Malé adds a second route through a new law. Both used developer-initiated proposals rather than tenders.

What would reduce it

A general law that makes competitive allocation the default. Majlis approval for every large land award.

Watch for

The next reclaimed-land award, and whether it follows the same route.

Decided by

People’s Majlis; Cabinet

Ten percent of developer revenue and four percent of transactions can be large if the project is fully built and sold at high prices. They can also be small if phases slip, internal transfer pricing appears, or the investor’s costs are loaded before the state’s share. Without an open contract, independent audit rights, and a ground rent that does not depend on sales success, the state is taking upside participation without a floor.

Evidence so far

Two official revenue figures differ: over USD 11 billion during development, and about USD 3.1 billion over 10 years from the 10% share. Gross revenue is not defined in public. The housing cost is to be deducted from the state’s share.

What would reduce it

A minimum annual payment that does not depend on sales. Gross revenue defined in the contract. Audit access for the Auditor General, and rules against pricing sales to related companies below market.

Watch for

The revenue definition, any minimum payment, and audit clauses.

Decided by

Ministry of Finance; Auditor General; People’s Majlis

A waterfront city of this size, once plotted for branded residences and a marina, cannot easily be redesigned for climate setback, public beach access, or higher social housing. The first masterplan is the lasting one.

Evidence so far

No project-level environmental assessment has been published. Climate setbacks and beach access are not addressed in any statement.

What would reduce it

A project environmental assessment published before the masterplan is approved. Climate setbacks and public beach access fixed in the masterplan.

Watch for

Environmental Protection Agency filings; the masterplan.

Decided by

Environmental Protection Agency; Ministry of Housing

There were no competing bids. Eagle Hills was selected through its own proposal, so there is no market test of whether a 10% revenue share with no acquisition fee is the best available price for 500 hectares next to the capital. The public must rely on the evaluation, which has not been published.

Evidence so far

The Housing Minister confirmed on 15 October that the project was accepted as a private-sector-initiated proposal.

What would reduce it

Publish the proposal and its evaluation. An independent valuation of the land. A stage inviting counter-offers before the definitive agreement.

Watch for

The evaluation paper; any independent valuation.

Decided by

Ministry of Finance; Ministry of Housing; Auditor General

The project relies on a law that does not exist yet, and a Supreme Court petition on Articles 250 and 251 is pending. If a definitive agreement is signed before the legal basis is settled, a later court ruling or change of policy could leave the state facing investor claims.

Evidence so far

The Attorney General says definitive agreements will follow the new law. The petition is pending. The dispute-resolution forum has not been disclosed.

What would reduce it

No definitive agreement before the law is passed and the petition is decided. Disclosure of the governing law and dispute forum.

Watch for

The Supreme Court’s handling of the petition; the dispute-resolution clause.

Decided by

Supreme Court; Attorney General’s Office

Selling high-value homes off-plan to foreign buyers carries money-laundering risk. A 2025 review by the regional watchdog cited the government’s own finding that the real estate sector is highly vulnerable. The economic ministry’s public business registry shows each company’s listed shareholders. But records of beneficial owners, the people who ultimately own or control a company, are filed with the Registrar and are not publicly searchable. Where a shareholder is a foreign company, the public trail stops at that company.

Evidence so far

The escrow bank, who controls the account and the release rules have not been published. Buyer screening has been described only for nationality.

What would reduce it

Source-of-funds checks for every buyer, and beneficial-ownership disclosure through the full ownership chain, written into the law. Public access to beneficial-ownership records for companies buying in the project. Reporting duties for the developer and agents. A named escrow bank with state-controlled release.

Watch for

Anti-money-laundering clauses in the bill; escrow terms.

Decided by

Maldives Monetary Authority; Financial Intelligence Unit; People’s Majlis

Key documents are unpublished: the commercial terms, the paper that selected Eagle Hills, and the Henley agreement for the related residency scheme. Officials have given conflicting statements on tenure and revenue. In that gap, claims on all sides spread faster than documents. That makes informed public consent harder and raises the chance of abrupt political reversal.

Evidence so far

A Majlis disclosure resolution has been debated, with the outcome pending. An opposition campaign launched on 19 October. The developer’s chairman has said the project will not proceed without public support.

What would reduce it

Publication of the commercial terms and the definitive agreement, with only narrow commercial redactions. One official, dated question-and-answer page kept current.

Watch for

The Majlis vote; publication of any text.

Decided by

Ministry of Housing; People’s Majlis

The 5,000 homes are planned on Hulhumalé Urban Isle, land previously named for a financial-centre plan and a Commercial Spine project. If earlier awards are not formally ended, disputes, compensation claims or delays could hit the homes presented as the public’s main benefit.

Evidence so far

Concept designs were published in October. No statement on the status of earlier awards on the site has been found.

What would reduce it

A published statement on each earlier award on the land. A plot survey and allocation list.

Watch for

HDC notices; any cancellation or compensation decisions.

Decided by

HDC; Ministry of Housing