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On 1 May 2026, new rules came into effect, marking profound changes to the financial services licensing regime in the Qatar Financial Centre (“QFC”). The INMA (Wholesale Advisory Firm) Amendment Rules 2026 (or “WAF Rules”) have dramatically simplified the application process for firms wishing to obtain an authorization from the Qatar Financial Centre Regulatory Authority (“QFCRA”) to perform regulated activities in and from the Qatar Financial Centre. The WAF Rules have primarily amended the Investment Management and Advisory Rules (“INMA”) but have also made targeted amendments to the Governance and Controlled Functions Rules 2020 (“CTRL”), as well as other rules. The day-to-day obligations contained in the General Rules 2005 (“GENE”) remain largely intact, and wholesale advisory firms (“WAFs”) will remain responsible for compliance with most of the prudential, reporting and other obligations contained therein. Other rules typically central to financial services firms regulated by the QFCRA, such as the AML/CFT Rules 2019 (“AML/CFTR”) and the Customer and Investor Protection Rules 2019 (“CIPR”) will be largely disapplied with respect to WAFs.  Most notably, the WAF Rules will now allow certain qualifying existing financial institutions to take advantage of a simplified QFCRA authorization process, with significantly lighter requirements during both the application process and during post-authorization operations. The WAF Rules allow firms to largely rely on their group-wide AML, Risk, and Governance policies, thus substantially reducing the QFC-specific documentation, staffing and compliance work previously applicable to all QFCRA-authorized firms. Not all firms are eligible to become wholesale advisory firms under the WAF Rules. Prospective applicants must be subject to regulatory oversight in a jurisdiction that is “broadly equivalent” to the regulatory framework in the QFC. There are some important trade-offs involved in the WAF route, most specifically: Limited options for legal structures; Limited licensed activities (WAFs cannot manage a QFC-registered fund or engage in investment management activities; they are limited to advising/arranging); and Limited customer/investor pool (e.g. state-owned entities and listed companies with substantial assets Finally, the governance structure is simplified to just three “controlled functions”, namely the senior executive function (“SEF”), the senior management function (“SMF”), and the Money Laundering Reporting Officer (“MLRO”) function. WAFs are further eligible to combine multiple controlled functions in a single, competent individual. Non-WAFs are subject to greater requirements with respect to controlled functions and must typically invest in directly filling these requirements with full-time staff or relying on outsourcing these controlled functions to qualified third party service providers.   Conclusion For financial services firms considering doing business in and from the Qatar Financial Centre, the new WAF Rules provide a pathway for a fast-tracked authorization and streamlined regulatory environment. To learn more about the WAF Rules and the QFCRA regulatory regime, please contact us. Authors: Dean Jaloudi, Partner and Jehan Saleh, Associate.

The Ministry of Commerce and Industry has issued its first formal guideline governing food and goods delivery via digital platforms — reshaping obligations for apps, restaurants, and couriers alike. Qatar's delivery sector has grown at a remarkable pace over the past decade. Apps connecting consumers to restaurants, supermarkets, and retailers have become a fixture of daily life in Doha. Until now, however, the relationships between platforms, providers, and couriers operated with limited regulatory structure. That has changed. In April 2026, Qatar's Ministry of Commerce and Industry (“MOCI”) published its Guideline for Delivery Activities and Services via Digital Platforms and Applications, the country's first dedicated regulatory framework for the sector. Grounded in existing competition protection and consumer rights legislation, the guideline draws clear lines around pricing, transparency, promotional offers, and the conduct of all parties involved. Businesses operating in this space, whether as platforms, restaurants, or independent couriers, should treat compliance as an immediate priority. One of the guideline's most commercially significant provisions is its protection of provider pricing autonomy. Restaurants and retailers may set different prices on delivery platforms than they charge in-store and platforms cannot require price parity. This directly challenges practices that some global platforms have historically imposed on partners. All commissions, fees, and deductions charged to providers must be fully disclosed in written contracts. Any amendment to these terms requires the provider's written approval. Hidden margins, undisclosed financial conditions, and the exploitation of a provider's dependence on a platform to impose unfair terms are expressly prohibited. When it comes to how providers are ranked, platforms must disclose the criteria they use, including distance, ratings, delivery time, reliability, and capacity, and must clearly label any placement that results from paid advertising. The guideline introduces a clear fault-based framework for cancellations. If a consumer cancels before food preparation begins, no cost falls on the consumer. Cancellation after preparation begins entitles the provider to recover actual costs only, but no penalty charges or inflated fees. For cash-on-delivery orders, platforms must implement a prior confirmation mechanism and establish contractual rules that allocate responsibility when an order goes uncollected. Where non-collection results from a provider error, the provider bears the cost. Where it results from platform or courier fault, the platform is liable. All discounts, promotional campaigns, and prize draws must be licensed by MOCI before launch. Prices before and after discounts must be displayed with full transparency. Inflating prices ahead of a "discount" is expressly prohibited, as is changing discount rates without prior approval or running offers beyond their licensed period. Key obligations for each party For platforms: pricing, commissions, and ranking criteria must be fully disclosed; price parity clauses are prohibited; paid placements must be labelled. For providers: products must be sold at the price shown on the platform; hidden charges at the door are not permitted; product descriptions must be accurate in all material respects: including ingredients, weight, calories, and special attributes. For delivery companies: pricing must be registered and electronically linked with the Ministry; any changes to pricing data must be reported promptly. For couriers: no payments beyond what appears on the platform may be requested. This includes tips presented as mandatory; orders must be delivered intact, on time, and using approved equipment such as temperature-controlled bags. Oversight sits with MOCI's Consumer Affairs sector, which has authority to conduct pre- and post-market monitoring, intervene to deter violations, and document breaches under Qatar's competition protection and consumer rights legislation. If you would like to discuss how this guideline affects your operations, contracts, or compliance obligations, our commercial and regulatory team in Doha is available to assist. Authors: Dean Jaloudi, Partner and Jehan Saleh, Associate.

Small and medium-sized enterprises (SMEs) often struggle to secure credit due to a lack of real estate, securities and other easily securitized assets. Recognizing this limitation, the State of Qatar recently established a modern, centralized Movable Collateral Registry to diversify the range of acceptable security interests, reshaping the credit landscape in the country. This article reviews the legal foundation and operational procedures of the Qatar Movable Collateral Registry (“MCR”), administered by the Qatar Central Securities Depository, commonly known as Edaa (“Edaa” or “QCSD”). We also highlight a highly valuable practical precedent from our experience: the successful cross-border use of this mainland registry by a foreign lender/pledgee, on the one hand, and a borrower/pledgor registered in the Qatar Free Zones (“QFZ”), on the other hand. Governing Laws: The Regulatory Shift The mechanism for securing interests in non-real estate property is primarily governed by Law No. 16 of 2021 on the Regulation of Pledge over Movable Assets (the “MCR Law”), as well as Decision No. 1 of 2022 of the Qatar Central Bank Governor on the Procedures for Regulating the MCR (the “QCB Governor Decision”). This transformative piece of legislation provides a comprehensive, transparent framework for creditors, or secured parties, to formalize their claims over a debtor’s movable assets. The law’s objective is twofold: to provide certainty for lenders, and to allow borrowers to leverage the full value of their operating assets. The Administrator: Edaa’s Role Edaa is a financial company licensed by Qatar Financial Market Authority. It provides services such as clearing, safekeeping, settlement of securities and other financial instruments listed on the Qatar Exchange. Under article 6 of the MCR Law, Edaa is designated as the implementing platform for the registration and publication of security rights over movables, ensuring creditor protection and maintaining a central searchable public database of such interests. Edaa oversees the operational administration and supervision of the MCR. What is MCR and What Movable Assets Could Be Registered? The MCR is an electronic public database that contains information on security interests over movable property. Pursuant to article 3 of the MCR Law, movable collateral is a broad category encompassing virtually all assets not classified as land or buildings, such as: Inventory and raw materials Machinery and equipment Accounts receivable (invoices owed to the debtor) Contractual rights and intellectual property Agricultural crops, animals, and their products Bonds and negotiable instruments, including commercial instruments and bank deposit certificates. The Purpose/ Function of the MCR The primary purpose of the MCR is to enhance market transparency by allowing pledgees to access information via MCR website and verify whether a particular asset has already been pledged. Article 3(2) of the QCB Governor Decision allows a pledgee to simply “search” the MCR database to confirm that an asset is not already encumbered by a security right over it to a former pledgee. This boosts lender confidence and mitigates risk. Ultimately, the MCR strengthens the infrastructure of financial instruments in the Qatari market, positioning Qatar as an attractive regional and global financial hub. Registration and Perfection For diligent lenders, the registration process is ideally preceded by searching the MCR database to confirm the absence of any prior registrations on the intended movable asset. To make a security interest legally effective and enforceable against third parties, the following steps are required: Execution of the Security Agreement: The debtor (pledgor) and the secured party (pledgee) must execute a definitive pledge over movables agreement in writing, clearly outlining the assets being pledged. Open a User Account in the MCR Portal: Pledgee (acting directly or through its representative) must register as “user” in the MCR system, accepting the Edaa general terms, paying the required deposit, and providing required identification documents. Once approved, the user obtains access to the MCR services. Submission of the Registration Request: The pledgee or the pledgor must then electronically submit a registration request via the Edaa platform, detailing the relevant parties and the pledged movable asset description. Under article 6 of the MCR Law, the pledgee is responsible for the registration fees, unless otherwise agreed. Issuance of a Registration Certificate: Upon completion, the MCR issues an electronic certificate confirming the registration of the security interest. Legal Effect and Priority: First-to-register Principle Upon registration, the pledge becomes public and enforceable against third parties. Qatar follows the “first-to-register” principle. Under article 16 of the MCR Law, priority between competing security rights is determined primarily by the date of registration in the MCR. A secured creditor who registers its security interest first will generally have superior priority in the collateral and its proceeds, regardless of when the underlying debt was granted. Enforcement Rights In case a pledgee wishes to enforce the pledge, articles 27 and 29 of the MCR Law provide that a pledgee may enforce the pledge upon default through: Contractual Enforcement: After notice to the Pledgor, by sale at a public auction; or Judicial Enforcement: By application to the judge sitting in the executions circuit. Can QFZ Entities’ Assets Be Registered in the MCR? The MCR is a state-wide register for pledges over movable assets in the entirety of Qatar. Though there is no explicit carveout in the law excluding QFZ, some might assume that the assets of the entities registered with the Qatar Free Zones Authority (“QFZA”) may not be pledged in the MCR. This is complicated by the fact that the QFZA issued “the Collateral and Security Regulations” on 16 December 2020, which outlines the intent to establish a separate, dedicated movable collateral registry for the Free Zones created and maintained by the QFZA, accompanied by an FAQ Guide, which serves as supplementary guide to the regulations.  However, there is currently no evidence that such QFZ register is in force yet. In all cases, article 40 of Law No. 34 of 2005 on Free Zones as amended by Decree Law No. 21 of 2017 and Law No. 15 of 2021 provide that “Save for what is inconsistent with the provisions of this Law and the Regulations, all the laws, Regulations, and civil rules applicable in the State will be applied to the Free Zones.” Based on our firm’s successful precedent, we confirm that QFZ-registered entities can and should register their movable assets as collateral in the MCR. We believe this principle should equally apply to Qatar’s other sub-jurisdictions, such as the Qatar Financial Centre and the Qatar Science and Technology Park (QSTP). Conclusion The MCR represents a major step forward for financing in Qatar. By allowing movable assets to be pledged as security, it provides lenders with clear, enforceable rights while enabling borrowers to unlock the value of their operational assets. The registry is transparent, centralized, and accessible through Edaa, ensuring confidence for all market participants. GLA is a member of the MCR and has successfully registered a security interest over movable collateral on behalf of one of its clients. Recommendations Creditors and borrowers should actively utilize the MCR to register and search for pledges, ensuring priority and reducing risk. Further, QFZ-registered entities should register their movable assets in the mainland MCR to benefit from the same protection as mainland entities. Lastly, policymakers and stakeholders should continue to raise awareness of the MCR’s benefits to encourage wider adoption and improve market efficiency. Authors: Maryam Tarek, Dean Jaloudi, Ashraf Hendi

For decades, establishing a commercial presence in Qatar meant one thing as a prerequisite: a physical office. Securing a lease was as fundamental to business setup as obtaining a commercial registration. That landscape has now materially shifted. On 4 March 2026, Qatar's Ministry of Commerce and Industry (“MOCI”) issued Ministerial Decision No. 25 of 2026 (the “Decision”), which came into force on 16 March 2026 following publication in the Official Gazette. The Decision introduces a dedicated licensing framework allowing certain commercial activities to be conducted exclusively through digital platforms — without the requirement to maintain physical commercial premises. This is a significant regulatory development for entrepreneurs, SMEs, and international businesses eyeing the Qatari market. The framework establishes a mandatory e-commerce license for businesses operating through websites, social media channels, or other digital platforms. Crucially, the term "website" is defined broadly under the Decision to encompass any technology-based system facilitating communications or transactions between parties — meaning platforms ranging from dedicated e-commerce sites to Instagram storefronts may fall within scope. Permitted activities under the framework will be determined by a MOCI-approved list, subject to ministerial sign-off and publication on the Ministry's website. Businesses may not conduct eligible activities digitally without first obtaining the e-commerce license and paying the applicable fees. Where a business operates across multiple platforms, a separate license must be obtained for each. The Decision carries meaningful compliance obligations. Licensed operators must ensure their platforms display commercial registration and license numbers, customer service contact details, product and service descriptions, return and exchange policies, and consumer complaint mechanisms. Electronic payment options must also be made available. Regulators have been deliberate in signaling that operating online does not diminish accountability to consumers. Businesses and advisors should note several important initial questions the Decision leaves open. The framework ostensibly applies only to MOCI-registered entities. Businesses established within the Qatar Financial Centre (“QFC”), Media City Qatar (“MCQ”), or other free zones likely fall outside its direct scope. Additionally, the Decision expressly excludes personal-use transactions that do not involve commercial quantities. It is important to contextualize this Decision, as it did not emerge in isolation. Qatar's Cabinet gave in-principle approval to the concept as far back as January 2025, signaling the government's intent to formalize digital commerce regulation as part of the broader MOCI Strategy 2024–2030 targeting full-service digitalization and a more competitive, investor-friendly business environment. The framework sits alongside a series of recent e-service expansions, including the ability for investors to obtain many government services digitally. This digital transformation, along with a number of other pro-investor initiatives (notably the expansion of commercial activities eligible for 100% foreign ownership), have resulted in making Qatar a globally competitive business environment for foreign investors. For businesses currently selling via social media or digital platforms without a formal license, this Decision brings both an opportunity and an obligation, which is to formalize your operations or risk non-compliance. For those considering entering the Qatari market without the overhead of a physical establishment, the framework offers a new and meaningful pathway. Either way, careful analysis of which activities qualify, which platforms require separate licensing, and how consumer disclosure obligations apply to your model will be essential. Our team advises clients across the GCC on commercial licensing, digital regulatory compliance, and market entry strategy. If you would like to understand how Ministerial Decision No. 25 of 2026 applies to your business, please do not hesitate to reach out. Authors: Dean Jaloudi, Partner, Head of Doha Office and Jehan Saleh, Associate.

Qatar has taken a significant step in adopting the OECD Pillar Two framework. We set out below what this means for multinational enterprise groups with a presence in Qatar, including through QFC-licensed entities. 15% - Minimum effective tax rate €750M Consolidated revenue threshold Effective from 1 Jan 2025 Legislative background. Council of Ministers Resolution No. 2 of 2026, published on 12 February 2026, introduced the implementing rules for Qatar's Global and Domestic Minimum Tax under Law No. 22 of 2024. The legislation aligns Qatar with the OECD's GloBE Rules and applies to fiscal years beginning on or after 1 January 2025. Scope. The rules apply to MNE groups with consolidated group revenues of at least EUR 750 million in at least two of the previous four fiscal years. All in-scope QFC-licensed entities will be captured. KEY COMPONENTS DMTT Domestic Minimum Top-up Tax: ensures Qatar collects top-up tax locally before it can be collected by another jurisdiction b1 Jan 20251 Jan 2025 Income Inclusion Rule: allows a parent entity's jurisdiction to impose top-up tax where a subsidiary is undertaxed COMPLIANCE OBLIGATIONS Registration In-scope entities will be required to register with the relevant authority Notification  Notification obligations apply; details are being finalised by QFC in coordination with the GTA Return filing Returns for FY 2025 are expected to be filed by 30 June 2027 What should you do now? MNE groups with QFC-licensed entities should assess their exposure to the Global and Domestic Minimum Tax as a matter of priority. This includes reviewing group revenue thresholds, effective tax rates across jurisdictions, and readiness for registration and filing obligations. If you would like to discuss how this legislation may affect your group or require assistance with a GMT exposure assessment, please do not hesitate to contact our Qatar team.

On 4  August 2025, the Board of Directors of the Qatar Financial Markets Authority (“QFMA”) issued Decision no. 5 of 2025, issuing the Governance Code of Listed Companies (the “New Code”). The New Code, published in the Official Gazette dated 17 August 2025, came into effect immediately. However, affected companies have one year to make changes necessary to comply with its provisions. With over 50 companies listed on the Qatar Stock Exchange (“QSE”) as of this writing, dozens of prominent Qatari companies may need to consider how to come into compliance before August 2026. Here are some key takeaways from the New Code that QSE-listed companies should consider: As mentioned above, affected companies have one year to make necessary amendments to come into compliance with the New Code. Nevertheless, the New Code is effectiveupon publication, meaning that companies currently applying to convert into a Qatari Public Shareholding Company (“QPSC”) and be listed on the QSE may have to make last minute adjustments in order to comply with the New Code. These adjustments could include: Revising their proposed QPSC Memorandum and Articles of Association Revising Board Charters before they take effect Expanding their proposed Board of Directors Updating the draft Offering Prospectus before publication in order to accurately reflect the governance structure, size and names of Board members, among other information. It would be advisable for companies currently going through the listing application process to check with the QFMA and confirm whether they may proceed with their applications as is. The New Code applies to both Main Market and Venture Market public listed companies. Previous governance codes were limited to one category or the other. (As of this writing there is only 1 company on the Venture Market, but it is expected that this number will increase in the next year or so.) 6.The definition of “Insider” has been expanded to include both Board Committee Members and the spouses and children of Insiders. Higher standards now apply to Independent Board Members, including the following requirements: Relevant education and professional experience Shareholding restrictions also apply to the first degree relatives of the potential Independent Board Member Employment restrictions apply to both the Independent Board Member and his/her first degree relatives Independent Board Members cannot serve more than 2 consecutive terms Instead of a minimum requirement for one-third (1/3) of the Board to be independent, the New Code requires an absolute minimum of 3 Independent Board Members. For smaller boards (with the minimum of 7 members), this would result in a largely independent Board (nearly 50%). For larger boards (e.g. 11 members), this could potentially result in a board that is less than 1/3 independent. More focus has been given to ESG issues, with an obligation on listed companies to consider their impact on the environment and on society, in addition to good governance. The Chairman of the Board of the QFMA may extend the one-year compliance grace period for one or more additional one-year periods. GLA will continue to monitor developments with respect to the 2025 Governance Code and will publish a more detailed summary in the coming weeks. For more information, please feel free to contact Dean Jaloudi, Partner and Head of Qatar Office ([email protected]). Author: Dean Jaloudi, Partner

Corporate groups operating in Qatar have long faced a structural friction when reorganizing their internal arrangements: asset and share transfers within a group could crystallize a capital gains tax liability, even where no economic gain was realized outside the group. That friction has now been formally addressed. The Council of Ministers issued Decision No. 3 of 2026, published in the Official Gazette on 1 March 2026 and entering into force on 2 March 2026, introducing relief for capital gains arising from qualifying corporate restructuring transactions. The measure is one of the most meaningful tax developments in Qatar in recent years, and its implications deserve careful attention from any corporate group with a presence in the country. At the center of the Decision is a straightforward but significant principle: capital gains arising from qualifying intra-group transfers of assets may be disregarded for tax purposes when those transfers occur as part of a legitimate corporate restructuring. In practical terms, this means that a gain is not taxed at the point of a qualifying transfer, which introduces what is effectively a tax-neutral reorganization regime into Qatar's framework for the first time. Both resident companies undergoing group restructuring and resident natural persons can now transfer assets or shares within their group without immediate capital gains tax exposure, provided the prescribed conditions are met. The Decision identifies five categories of qualifying transactions: asset swaps as part of internal group restructuring; asset revaluations for the purpose of in-kind capital contributions; disposals in the context of mergers and demergers; transfers aimed at contributing to the capital of a resident holding company; and disposals connected with a listing on the Qatar Stock Exchange. The relief is conditional—not automatic—and groups should not assume eligibility without careful analysis. For example: Where assets are transferred for group restructuring purposes or revalued as an in-kind contribution, the transferee must retain those assets for a minimum of two years. Capital increases in the context of mergers must be completed within two years. Contributions to a holding company's capital must be finalized within the same tax year. For any restructuring related to a QSE listing, the listing must be completed within one year following the year in which the relief is claimed. Critically, the transfer must be executed for a valid economic reason. If the statutory conditions are later breached, the capital gains may become taxable from the year in which the relief was originally claimed. From a procedural standpoint, taxpayers must submit an application to the General Tax Authority (“GTA”) to benefit from the relief. Importantly, if the GTA does not respond within 30 days, the application is deemed implicitly accepted. The GTA has confirmed that the intra-group restructuring exemption was introduced to strengthen the existing exemptions under the Income Tax Law and its Executive Regulations, which had previously offered only limited relief in this area. The measure also reflects Qatar's intention to remain aligned with international best practices, the explicit inclusion of entities subject to the Income Inclusion Rule and Domestic Minimum Top-Up Tax signals Qatar's awareness of the need to keep domestic restructuring relief compatible with the OECD Pillar Two global minimum tax framework. The GTA has also highlighted that the exemption is designed to support the listing of companies on the Qatar Stock Exchange, contributing to increased market activity which is an objective that aligns closely with Qatar's National Vision 2030 goals around capital market development. For holding companies, family-owned business groups, and multinational enterprises with Qatari operations, this regime opens a meaningful planning window. Groups that have deferred internal reorganizations precisely because of tax exposure should now reassess those plans in light of the new framework. As noted above, some of the Decision’s conditions (particularly the holding period requirements, the economic purpose test, and the procedural GTA filing obligation) mean that eligibility cannot be assumed. Documentation of the commercial rationale for any restructuring will be essential, as will timely GTA engagement before a transaction is executed. Our team advises corporate clients across the region on tax structuring, group reorganizations, and regulatory compliance in Qatar. If you would like to discuss how Decision No. 3 of 2026 may affect your group's structure or planned transactions, we would be pleased to assist. Authors: Dean Jaloudi, Partner and Jehan Saleh, Associate.

The International Chamber of Commerce ("ICC") has approved a revised version of its Rules of Arbitration, which will enter into force on 1 June 2026 (the "2026 ICC Rules"), replacing the 2021 Rules of Arbitration (the "2021 ICC Rules"). The revised Rules will apply to all requests for arbitration filed on or after 1 June 2026. Described by the ICC as the most substantial revision since 2012, the 2026 ICC Rules are designed to enhance efficiency, clarity and user-friendliness, ensuring ICC arbitration remains responsive to the evolving needs of global users. Claudia Salomon, President of the ICC International Court of Arbitration, has noted that the revisions "make the Rules clearer and arbitration more efficient, while preserving the flexibility and procedural integrity that parties expect". As the 1 June 2026 entry into force date approaches, it is essential for businesses, in-house counsel and practitioners across the region to familiarise themselves with the key changes that the new Rules will bring. This article provides an overview of the most significant amendments introduced by the 2026 ICC Rules, together with our initial observations on their practical significance for businesses and practitioners in the Middle East and beyond. Introduction of a Highly Expedited Procedure One of the most notable innovations under the 2026 ICC Rules is the introduction of a new highly expedited procedure, enabling tribunals to issue a final award within just three months. This mechanism is designed to meet the increasing demand for swift and enforceable decisions in urgent, time-sensitive disputes, and will operate on an opt-in basis as a pilot project subject to ongoing review. Under this framework, disputes may be resolved solely on the basis of written submissions, without a hearing, and parties may agree to the issuance of an award without reasons. Parties will be required to present their full case at the outset, including all evidence and arguments, and joinder and consolidation will not be permitted. A sole arbitrator is to be agreed upon by the parties within 20 days or, failing agreement, appointed by the ICC Court. It remains to be seen which sectors will adopt this procedure, although it is likely to appeal to industries such as cryptocurrency and commodities where speed is often commercially critical. Commentators have also noted that the procedure is likely to attract significant attention in the construction and energy sectors, as well as intellectual property, technology-related disputes and M&A arbitrations, where the ability to secure a rapid and final determination is often critical. In the construction and energy context, how this procedure will interact with DAB and adjudication mechanisms remains to be seen; however, it could prove a valuable additional tool for achieving timely, contemporaneous final resolution of issues central to the delivery of major projects, including disputes over development commitments, design standards, serial defects, acceleration instructions or the application of liquidated damages to interim milestones. Increased Threshold for the Expedited Procedure Under the 2026 ICC Rules, the monetary threshold for the automatic application of the Expedited Procedure Provisions ("EPP") will increase from USD 3 million to USD 4 million for claims brought under arbitration agreements concluded on or after 1 June 2026. Given that, in 2025 alone, over 40% of ICC cases did not exceed USD 4 million, this adjustment broadens the range of disputes eligible for expedited arbitration. Since the introduction of the EPP in 2017, the ICC Court has administered 1,034 cases resulting in 591 awards under these provisions. Importantly, party autonomy is preserved: parties remain free to opt in or out of the EPP regardless of whether a case falls within the automatic monetary threshold. Removal of Mandatory Terms of Reference Perhaps the most significant procedural change is the removal of mandatory Terms of Reference ("TORs"), long regarded as a defining feature of ICC arbitration. Under Article 23 of the 2021 ICC Rules, the arbitral tribunal was required to draw up TORs within 30 days of the file being transmitted to it, though extensions were frequently granted in practice. Under the 2026 ICC Rules, TORs are no longer a necessary step in ICC proceedings, although arbitral tribunals retain the discretion to establish them where appropriate as a useful case management tool. This approach builds on the experience of the EPP, under which TORs were already optional; the ICC Court has administered more than 1,000 cases under the EPP, with fewer than 25 tribunals deciding to draw up TORs. In parallel, the Case Management Conference ("CMC"), which remains mandatory and must be held within 30 days of the transmission of the file to the arbitral tribunal, assumes a more central role as the principal procedural milestone for structuring proceedings. Notably, no party may introduce new claims after the initial CMC without the authorisation of the arbitral tribunal, taking into account, amongst other factors, the nature of the new claims, the stage of the proceedings and any cost implications. Early Determination of Claims Taking inspiration from common law mechanisms and similar provisions already adopted by the LCIA, the 2026 ICC Rules introduce an early determination mechanism. Any party may request the arbitral tribunal to make an early determination of one or more claims or defences where such claims or defences are manifestly without merit or manifestly outside the jurisdiction of the tribunal. The arbitral tribunal retains full discretion as to whether to allow the request to proceed and, if so, shall adopt such procedural measures as it considers appropriate, after consulting the parties. This provision is a welcome development for practitioners seeking to prevent unmeritorious arguments from delaying proceedings and inflating costs. Flexible Time Limits for Rendering Awards Under Article 31 of the 2021 ICC Rules, arbitral tribunals were generally required to issue their final award within six months from the date the TORs were signed or approved, though this deadline was frequently extended in practice. The 2026 ICC Rules replace this fixed default with a more flexible approach: under Article 34, the President of the ICC Court shall fix, or subsequently extend, the time limit for rendering the final award, taking into account the procedural timetable or a reasoned request from the arbitral tribunal. In practice, most arbitrations will continue to operate under time limits aligned with the procedural timetable, as was already the prevailing approach under previous editions of the ICC Rules. Fully Electronic Communications and Awards Codifying what has become established practice, the 2026 ICC Rules specify that all communications and submissions should be conducted in electronic form, whether via email, ICC Case Connect or other digital means. This reflects a continued move toward greater efficiency, cost reduction and environmental sustainability in arbitration proceedings. In addition, upon consultation with the parties, arbitral tribunals will be empowered to sign awards electronically and in separate counterparts. Parties will, however, still be able to request hard copies where necessary — for instance, for enforcement purposes in jurisdictions where national courts require certified hard copies or original signed documents. Enhanced Disclosure Requirements and Arbitrator Independence The 2026 ICC Rules strengthen the framework governing arbitrator independence and impartiality. From the outset of the arbitration, each party must submit to the ICC Secretariat a list of persons and entities which it believes prospective arbitrators should consider, together with the reasons for such consideration. This new provision formalises a structured mechanism through which parties can proactively raise potential points at an early stage, thereby promoting efficiency and reducing the risk of late-stage challenges. For the first time, the 2026 ICC Rules codify the ICC Court's long-standing practice that any doubts a prospective arbitrator may have about whether to make a disclosure shall be resolved in favour of disclosure, and that disclosure alone does not, by itself, establish a lack of independence or impartiality. Confidentiality The ICC considered introducing default confidentiality for ICC arbitrations under the 2026 ICC Rules but ultimately decided against it. A blanket confidentiality regime was seen as potentially problematic, particularly for government parties that may require a greater degree of transparency. Instead, the 2026 ICC Rules introduce an express duty of confidentiality on arbitrators themselves, mirroring the existing obligation applicable to the ICC Court and Secretariat. By comparison, arbitral proceedings are confidential by default under several other leading arbitration rules, including the LCIA Rules (Article 30), the SIAC Rules (Rule 59) and the HKIAC Rules (Article 45). Enhanced Emergency Arbitration Provisions The 2026 ICC Rules introduce important clarifications to the emergency arbitration provisions. Emergency arbitrator proceedings may now be initiated not only against signatories to the arbitration agreement and their successors, but also against any party for which the President of the ICC Court is satisfied, on a prima facie basis, that a binding arbitration agreement may exist. This reflects the evolution in practice developed over 287 emergency arbitration applications administered since the provisions were first introduced in 2012. For the first time, the 2026 ICC Rules also expressly acknowledge preliminary orders, including on an ex parte basis. A party may request a preliminary order directing another party not to frustrate the purpose of the application — for instance, to prevent asset dissipation or destruction of evidence. Procedural safeguards are built into the framework: if a preliminary order is granted, the emergency arbitrator must immediately afford all other parties a reasonable opportunity to present their case and retains the power to modify or revoke the order in light of subsequent submissions. Truncated Tribunals The 2026 ICC Rules introduce a new provision addressing situations where an arbitrator dies or is removed after the last hearing or the filing of the last submissions. In such circumstances, the ICC Court may decide that the remaining arbitrators shall continue the arbitration without replacing the departed member, having taken into account the views of the remaining arbitrators and the parties, as well as any other relevant matters. This is a pragmatic measure designed to prevent the costly re-running of arbitrations that have already reached an advanced stage. Tribunal Secretaries The 2026 ICC Rules formalise the role of tribunal secretaries. After consulting the parties, the arbitral tribunal may appoint a tribunal secretary to work under its direction and control, without delegating its decision-making authority. Tribunal secretaries shall satisfy the same requirements of independence, impartiality and confidentiality as those applicable to arbitrators under the Rules, and shall sign a declaration of acceptance, availability, impartiality and independence prior to their appointment. Practical Implications for the Middle East The 2026 ICC Rules are of particular relevance to practitioners and businesses operating in the UAE, KSA, Egypt and Kuwait, where ICC arbitration remains a widely used dispute resolution mechanism across sectors including construction, energy, banking and finance, and infrastructure. The removal of mandatory TORs, the introduction of the highly expedited procedure, and the strengthening of the emergency arbitration provisions are likely to be of significant practical value in these jurisdictions, where the speed and enforceability of arbitral awards are often of paramount commercial importance. Businesses and in-house counsel in the region should review their existing arbitration clauses and dispute resolution strategies in light of the 2026 ICC Rules ahead of their entry into force on 1 June 2026. In particular, parties may wish to consider whether the new highly expedited procedure or the enhanced EPP threshold may be suitable for the types of disputes they most commonly encounter. GLA & Co's dispute resolution team is available to assist clients in understanding the impact of the 2026 ICC Rules and in reviewing and updating their contractual dispute resolution provisions accordingly. Authors: May El Mahdy, Senior Associate and Mohammed Al Awadhi, Partner.