Many markets have Islamic home financing without having Islamic banking at all. We structure and certify it for the specialist providers who serve them, across Oceania, North America and Europe.
The problem
Islamic home financing is not a subset of Islamic banking. In North America, Australia and a good many other markets there are no Islamic banks at all, and the providers meeting Muslim demand for home ownership are specialist non-bank lenders, cooperatives and fintechs operating entirely inside a conventional regulatory perimeter. That is who we work with.
It is also the most difficult consumer product in Islamic finance to structure well. The asset is large, the term is long, the customer is a household rather than an institution, and the whole arrangement has to operate inside a legal system designed around one instrument: a security interest securing a loan at interest.
Every serious question follows from that mismatch. Does the provider acquire the property before selling it, and does the land registry agree. Who bears the risk of the asset between acquisition and sale. How is transfer duty treated when the property changes hands twice. What happens on early settlement, on default, on divorce, on death. How is the customer's equity accounted for in a diminishing musharakah when the market falls.
None of these are answerable from a template. They are answerable jurisdiction by jurisdiction, against local property law, registry practice, tax treatment and consumer credit regulation, none of which was written with this in mind. That is why these engagements run long, and why the ones that go wrong tend to go wrong quietly, years in.
Acquisition first
Does the provider own it, and does the registry agree
Risk between stages
Who bears the asset risk before the second sale
Transfer duty
Double duty on a two-stage transfer
Life events
Default, early settlement, divorce, death
What we do
Murabahah, ijarah muntahia bittamleek, diminishing musharakah or a hybrid, chosen against what local property and tax law will permit, not against what reads best.
Working alongside your lawyers on how ownership is held and recorded, and whether the structure survives contact with the land registry.
Double duty on a two-stage transfer is the recurring commercial obstacle. The structure has to answer it, not footnote it.
What happens on default, early payoff, death, divorce and negative equity, settled at design stage rather than discovered in year six.
Financing documents, disclosure and the customer-facing explanation of what they are entering into.
Certification under a verifiable reference, and review as the product, the portfolio and the regulation change.
Why ADL
Our team pairs certified Muftis holding AAOIFI qualifications with people who understand code, systems and product architecture. We hold Malaysia Digital Status from the Malaysian Digital Economy Corporation, a technology credential, held by a Shariah advisory firm. Where there is an app, we go into it. Where there is a core banking system, we review the configuration.
Registered Shariah Adviser with the Securities Commission Malaysia and with Labuan Financial Services Authority.
We work primarily against AAOIFI standards and reconcile with the applicable local regime. An opinion grounded in AAOIFI travels across borders.
Beyond applying Islamic finance standards, our team has been commissioned by a standard-setting body: research towards a governance standard, participation in the drafting of a preliminary standard, and a series of training assignments.
Auditing against another adviser's pronouncement is ordinary work for us, as is being audited by another firm. Independence is the point of the exercise.
We work in jurisdictions with mature Islamic finance regulation and in markets with none at all, where the structure has to satisfy Shariah while operating entirely within a conventional rulebook.
Best Shariah Advisory in Islamic Asset Management, presented in Jeddah in February 2026.
Members of our team hold Shariah board and committee seats across the institutions we serve, so our advisory work is informed by governance experience, not only by external review.
How we hold ourselves
Our measure of a good year is not only revenue. It is whether we helped one more business get to halal. That is why we will take a call from a founder at ideation stage, and why our pricing bends to what a client can actually carry. We would rather a small platform get its structure right at the start than be priced out and get it wrong at scale.
A business built on an Islamic label still has to be a good business. Sound fundamentals, capable people, honest disclosure, and a high standard of compliance with local regulation, because that is what protects the customer and the investor. Shariah compliance sits on top of that foundation. It is not a substitute for it, and we will say so if we see it being treated as one.
The Lifecycle
Compliance is a state you maintain rather than a certificate you obtain, and the audit cycle is how you maintain it.
We understand the property law, the tax treatment and the registry practice before we quote.
Scope, timeline and fee agreed, agreement signed.
The deep stage: title structuring, transfer duty treatment, and how default, early settlement and life events are handled.
Findings returned and worked through with your legal team and the land registry's own requirements; the structure is adjusted.
Issued by a certified Mufti.
Issued under a reference any counterparty can verify independently.
For a home financing product the cycle runs for as long as it is offered: the structure is re-tested every year, and every time regulation, registry practice or the portfolio changes.
We commit to two to four weeks for a first pronouncement. In practice it often runs longer, and in our experience the reason is the round trip rather than the review. We raise amendments, and your product and engineering teams need time to work through them. We would rather set that expectation now than surprise you in week three.
Engagements are scoped and priced individually. We have worked with providers structuring their first product in a market with no Islamic finance framework and with providers several years into an existing portfolio. One size does not fit all. Tell us what you are building and we will tell you what it takes.
Evidence
Three home financing providers (Oceania)Long-running engagements to structure and certify Shariah-compliant home financing in a market with no Islamic finance framework. Each presented substantial structural and legal challenges; each was certified.
A home financing provider (North America)Structuring and certification for Shariah-compliant residential property financing.
A home financing provider (Europe)An ongoing engagement supporting the delivery of Shariah-compliant home financing in a European market.
Home financing and affordable housing financing also structured for a peer-to-peer platform in Southeast Asia.
Questions
No, and the difference is testable. In a mortgage the lender advances money and takes security over the property. In a compliant structure the provider must acquire an ownership interest and bear the risk that goes with it. Where that ownership does not truly arise, or arises only momentarily, on paper, to satisfy a form, the arrangement is a loan with a mark-up, and it will be read that way by anyone who examines it.
Because the answer is different in every jurisdiction. Property law, registry practice, transfer duty and consumer credit rules all constrain the structure, and none of them were designed to accommodate it. A structure that works in one market frequently cannot be lifted into another.
Yes. Almost all of our home financing work has been in exactly those markets, where there is no Islamic framework to rely on and the structure has to satisfy Shariah entirely within a conventional rulebook.
It is the most common commercial obstacle in a two-stage transfer. Some jurisdictions provide relief and others do not, and where they do not the structure has to absorb it or avoid triggering it. This is a design question that decides whether the product is viable, not a legal footnote.
Our certification confirms Shariah compliance. It is not an assessment of whether a business is viable, whether its financials are sound, or whether the people running it can execute. Look at both questions, and do your own due diligence on the second. Every ADL certificate carries a reference you can check independently.
Book a consultation, whether you are structuring your first product or already carrying a portfolio.