Referral Program
Synonyms: Referral scheme، Refer-a-friend program، Customer referral rewards
Last updated: 2026-09-25
Short Definition
A referral program is a scheme in which a real estate firm rewards customers or partners who recommend new customers who actually do business with it, using a cash reward, discount, gift or free service, and drawing on people's trust in recommendations from those they know.
Overview
Legal Basis
Designing real estate referral programs rests on: (1) the Real Estate Brokerage Law, Royal Decree No. M/130 dated 30/11/1443H, which defines real estate brokerage as mediating the completion of a real estate transaction in return for a commission, including electronic brokerage (Art. 1), permits it only under a licence (Art. 4), allows a broker to contract with another real estate broker (Art. 8), and treats unlicensed practice as a violation (Art. 18) punishable by a fine of up to SAR 200,000 (Art. 19); (2) the Anti-Commercial Fraud Law, Royal Decree No. M/19 dated 23/4/1429H, whose Article 4 requires a Ministry of Commerce licence to run commercial competitions by any means; and (3) the Personal Data Protection Law, Royal Decree No. M/19 dated 9/2/1443H, amended by Royal Decree No. M/148 dated 5/9/1444H, which limits marketing processing to data collected directly from the data subject with consent (Art. 26).
Practical Example
A property management company in Riyadh offers its current landlords a SAR 1,000 gift voucher for each new landlord they refer who signs a management contract of at least one year. The current landlord is not asked to present properties or negotiate; they simply send acquaintances a unique link through which the new landlord registers their own details and consents to contact. Over a year, 18 management contracts are signed through the program, with average annual management fees of SAR 9,000 per property, SAR 162,000 of annual revenue against SAR 18,000 in rewards. When the team proposed adding a monthly draw for a grand prize among referrers, the idea was postponed until a competitions licence could be obtained from the Ministry of Commerce.
Common Mistakes
- ✗Paying a percentage of commission per deal to unlicensed people who present properties and negotiate, which may amount to brokerage without a Fal licence.
- ✗Taking customers' friends' numbers from them and contacting those friends for marketing without their consent, whereas the Law limits marketing processing to data collected directly from the data subject.
- ✗Adding prize draws or competitions without a Ministry of Commerce licence.
- ✗Not writing clear program terms (when the reward is due and its value), leading to disputes with referrers.
- ✗Paying the reward on referral rather than on an actual signed contract, turning the program into a cost with no return.
International Differences
Markets differ in how they control real estate referral rewards: in a number of US states, transaction-based referral fees are limited to licensed brokers, while other markets allow thank-you gifts to customers subject to disclosure rules. The Saudi approach ties the question to the definition of brokerage and the Fal licence requirement, plus licensing of commercial competitions and data protection limits. The UAE, Egypt and Turkey each have their own brokerage licensing rules, which should be checked before running a cross-border program.

