{"id":148272,"date":"2026-09-03T12:43:26","date_gmt":"2026-09-03T12:43:26","guid":{"rendered":"https:\/\/my.legal500.com\/guides\/?post_type=comparative_guide&#038;p=148272"},"modified":"2026-09-03T13:09:23","modified_gmt":"2026-09-03T13:09:23","slug":"united-arab-emirates-enforcement-of-judgments-in-civil-and-commercial-matters","status":"publish","type":"comparative_guide","link":"https:\/\/my.legal500.com\/guides\/chapter\/united-arab-emirates-enforcement-of-judgments-in-civil-and-commercial-matters\/","title":{"rendered":"United Arab Emirates: Enforcement of Judgments in Civil and Commercial Matters"},"content":{"rendered":"","protected":false},"template":"","class_list":["post-148272","comparative_guide","type-comparative_guide","status-publish","hentry","guides-enforcement-of-judgments-in-civil-and-commercial-matters","jurisdictions-uae"],"acf":[],"appp":{"post_list":{"below_title":"<div class=\"guide-author-details\"><span class=\"guide-author\">Awatif Mohammad Shoqi Advocates &amp; Legal Consultancy<\/span><span class=\"guide-author-logo\"><img src=\"https:\/\/my.legal500.com\/guides\/wp-content\/uploads\/sites\/1\/2026\/08\/logo-awatif-highres-01.jpg\"\/><\/span><\/div>"},"post_detail":{"above_title":"<div class=\"guide-author-details\"><span class=\"guide-author\">Awatif Mohammad Shoqi Advocates &amp; Legal Consultancy<\/span><span class=\"guide-author-logo\"><img src=\"https:\/\/my.legal500.com\/guides\/wp-content\/uploads\/sites\/1\/2026\/08\/logo-awatif-highres-01.jpg\"\/><\/span><\/div>","below_title":"<span class=\"guide-intro\">This country specific Q&amp;A provides an overview of Enforcement of Judgments in Civil and Commercial Matters laws and regulations applicable in United Arab Emirates<\/span><div class=\"guide-content\"><div class=\"filter\">\r\n\r\n\t\t\t\t<input type=\"text\" placeholder=\"Search questions and answers...\" class=\"filter-container__search-field\">\r\n\t\t\t<\/div>\r\n\r\n\t\t\t\r\n\r\n\r\n\t\t\t<ol class=\"custom-counter\">\r\n\r\n\t\t\t\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What international conventions, treaties or other arrangements apply to the enforcement of foreign judgments in your jurisdiction and in what circumstances do they apply?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The enforcement of foreign judgments in the UAE is governed by international agreements and domestic law. Article 225 of Federal Decree-Law No. 42 of 2022 Promulgating the Civil Procedure Code provides that the rules governing the enforcement of foreign judgments, orders and instruments apply without prejudice to conventions and agreements concluded between the UAE and other states. Accordingly, where an applicable treaty exists, enforcement is governed by that treaty. In the absence of an applicable treaty, enforcement before the UAE onshore courts is subject to Article 222 of the Civil Procedure Code. The main multilateral frameworks are:<\/p>\n<p>GCC Convention on the Execution of Judgments, Delegations and Judicial Notifications \u2013 applies between the UAE and other GCC states (Bahrain, Kuwait, Oman, Qatar and Saudi Arabia). It provides for reciprocal recognition and enforcement of qualifying judgments, subject to limited grounds for refusal.<\/p>\n<p>Riyadh Arab Agreement for Judicial Cooperation 1983 applies between contracting Arab states. It requires recognition of final civil, commercial, administrative and personal status judgments, subject to conditions such as proper jurisdiction, due process, and compliance with public order.<\/p>\n<p>The UAE has also entered into bilateral judicial cooperation treaties with several states, including France, India, China, and Kazakhstan. These vary in scope and may cover enforcement of judgments or be limited to judicial assistance. Each treaty must be reviewed to confirm its applicability and requirements.<\/p>\n<p>The DIFC and ADGM Courts have entered into Memoranda of Guidance with certain foreign courts explaining the procedures and legal principles applicable to the enforcement of money judgments. These memoranda are generally non-binding and do not themselves create a right to enforcement or override applicable legislation, treaties or court rules.<\/p>\n<p>The UAE is not a party to the Hague Judgments Convention 2019 or the Hague Choice of Court Convention 2005, and these do not currently apply in the UAE.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What, if any, reservations has your jurisdiction made to such treaties?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The UAE has not made any published reservation materially limiting the recognition and enforcement of civil or commercial judgments under the GCC Convention or the Riyadh Arab Agreement. It ratified the GCC Convention by Federal Decree No. 41 of 1996 and the Riyadh Arab Agreement by Federal Decree No. 53 of 1999 without any relevant reservation. Riyadh Arab Agreement further prohibits reservations that expressly or implicitly conflict with the Agreement or its objectives. Any reservation or declaration relating to a bilateral treaty must be considered by reference to the particular instrument.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Can foreign judgments be enforced in your jurisdiction where there is not a convention or treaty or other arrangement, e.g. under the general law?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. A foreign judgment may be enforced in the UAE even where no applicable convention, treaty or other arrangement exists. Enforcement before the UAE onshore courts is governed by Article 222 of Federal Decree-Law No. 42 of 2022, subject to reciprocity and the statutory conditions for enforcement. Separate regimes apply in the DIFC and ADGM.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What basic criteria does a foreign judgment have to satisfy before it can be enforced in your jurisdiction? Is it limited to money judgments or does it extend to other forms of relief?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>As noted in Question 3 above, where no applicable treaty provides otherwise, enforcement before the UAE onshore courts is governed by Article 222 of Federal Decree-Law No. 42 of 2022. Under Article 222(1), enforcement is subject to reciprocity, meaning that the foreign judgment may be enforced on the same conditions under which the courts of the country of origin would enforce a UAE judgment. Under Article 222(2), the Execution Judge must also be satisfied that:<\/p>\n<ul>\n<li>the UAE courts did not have exclusive jurisdiction over the underlying dispute, and the foreign court had jurisdiction under the rules of international jurisdiction applicable in the country of origin;<\/li>\n<li>the judgment or order was issued by a court in accordance with the law of the country of origin and has been duly authenticated;<\/li>\n<li>the parties were properly summoned and duly represented;<\/li>\n<li>the judgment or order has acquired the force of res judicata under the law of the country of origin; and<\/li>\n<li>the judgment or order does not conflict with a judgment or order previously issued by a UAE court and does not contain anything contrary to UAE public order or morals.<\/li>\n<\/ul>\n<p>Article 222 is not expressly confined to money judgments. The enforceability of non-monetary relief will nevertheless depend on whether the order is sufficiently definite, remains enforceable in the country of origin and can be implemented using remedies available under UAE law without infringing exclusive jurisdiction or public orde<\/p>\n<p>Separate enforcement frameworks apply in the DIFC and ADGM. Under Article 31 of Dubai Law No. 2 of 2025, the DIFC Enforcement Judge may enforce foreign judgments and judicial decisions, including interim and precautionary orders, where the applicable jurisdictional connection with the DIFC is satisfied, and enforcement is sought within the DIFC, in accordance with the Rules of the DIFC Courts. Separately, the ADGM has a statutorily recognised foreign court framework. Under sections 171 to 173 of the ADGM Courts, Civil Evidence, Judgments, Enforcement and Judicial Appointments Regulations 2015, qualifying money judgments issued by courts formally designated as recognised foreign courts may be registered and enforced in the ADGM, subject to the applicable statutory requirements.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What is the procedure for enforcement of foreign judgments pursuant to such conventions, treaties or arrangements in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Where an applicable treaty governs enforcement, the judgment creditor must apply to the competent UAE Execution Judge for an order recognising and enforcing the foreign judgment. The treaty determines the substantive conditions for enforcement, while the procedural steps are generally governed by UAE law unless the treaty provides otherwise. The application is made by petition and must be supported by the documents required under the relevant treaty. Article 225 of the Civil Procedure Code preserves the application of treaty provisions, while Article 222 provides that an application for enforcement is submitted to the competent Execution Judge.<\/p>\n<p>Under the GCC Convention, the applicant must generally provide:<\/p>\n<ul>\n<li>an authenticated true copy of the judgment;<\/li>\n<li>a certificate confirming that the judgment is final, unless this is stated in the judgment itself; and<\/li>\n<li>where the judgment was issued in the defendant\u2019s absence, certified evidence that the defendant was properly notified.<\/li>\n<\/ul>\n<p>The Execution Judge\u2019s examination is limited to determining whether the Convention\u2019s requirements have been satisfied and does not extend to reconsidering the merits of the underlying dispute. If the requirements are met, the court orders the judgment to have the same enforceable effect as a UAE judgment. The application may relate to the whole judgment or a divisible part of it.<\/p>\n<p>Under the Riyadh Arab Agreement, the applicant must generally provide:<\/p>\n<ul>\n<li>an official copy of the judgment;<\/li>\n<li>evidence that the judgment is final and has acquired the force of res judicata; and<\/li>\n<li>where the judgment was issued in absentia, evidence that the defendant was duly notified.<\/li>\n<li>where enforcement is sought, a certified copy of the document establishing that the judgment is executable.<\/li>\n<\/ul>\n<p>The competent UAE judicial authority verifies compliance with the Agreement without reconsidering the merits of the underlying dispute. Where the requirements are satisfied, the judgment is granted the same enforceable status as a domestic judgment. Matters not specifically regulated by the Agreement are governed by UAE procedural law.<\/p>\n<p>Documents submitted before the UAE onshore courts should generally be accompanied by a certified Arabic translation, as Arabic is the official language of the courts, unless the matter is heard by a tribunal authorised to conduct proceedings in English. Authentication and legalisation requirements depend on the terms of the applicable treaty.<\/p>\n<p>Once an enforcement order is issued, the judgment creditor may commence execution proceedings and seek the enforcement measures available under UAE law against the judgment debtor\u2019s assets. Bilateral treaties may impose different requirements concerning supporting documents, authentication, legalisation or transmission of the application and must therefore be considered individually.<\/p>\n<p>Memoranda of Guidance entered into by the DIFC or ADGM Courts with foreign courts do not establish an independent treaty-based enforcement procedure. They explain the procedures and legal principles that may apply but are generally non-binding. Applications before the DIFC or ADGM Courts must therefore be made under the applicable DIFC or ADGM legislation and court rules.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">If applicable, what is the procedure for enforcement of foreign judgments under the general law in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The application is made by petition to the competent Execution Judge under Article 222(2) of the Civil Procedure Code. The petition must contain the particulars specified in Article 44, including:<\/p>\n<ul>\n<li>the names, identification and contact details of the applicant and the judgment debtor;<\/li>\n<li>the court before which the application is filed;<\/li>\n<li>the date of filing;<\/li>\n<li>the subject matter of the application, the relief sought, and the grounds relied upon; and<\/li>\n<li>the signature of the applicant or the applicant\u2019s representative.<\/li>\n<\/ul>\n<p>The application should also be accompanied by the documents necessary to establish that the conditions under Article 222(2) have been satisfied. The substantive conditions are set out in Question 4.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What, if any, formal requirements do the courts of your jurisdiction impose upon foreign judgments before they can be enforced? For example, must the judgment be apostilled?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>A foreign judgment submitted to the UAE onshore courts must be duly authenticated in accordance with Article 222(2)(b) of the Civil Procedure Code. Where no applicable treaty provides otherwise, the judgment will generally need to be legalised through the competent authorities in the country of origin, the UAE diplomatic mission in that country and the UAE Ministry of Foreign Affairs. Documents submitted to the UAE onshore courts in a language other than Arabic must generally be accompanied by a certified Arabic translation.<\/p>\n<p>The Hague Apostille Convention does not apply in the UAE. In the absence of a treaty dispensing with legalisation, an apostille alone will not replace the UAE legalisation requirements. The treaty-specific documents are summarised in Question 5.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How long does it usually take to enforce or register a foreign judgment in your jurisdiction? Is there a summary procedure available?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Under Article 222(2) of Federal Decree-Law No. 42 of 2022 Promulgating the Civil Procedure Code, the Execution Judge must issue an order on an application\/petition to enforce a foreign judgment within five (5) working days from the date the petition is submitted.<\/p>\n<p>The GCC Convention and the Riyadh Arab Agreement do not prescribe a fixed timeframe for determining an enforcement application. Where the applicable treaty is silent, the procedure is governed by UAE law.<\/p>\n<p>There is no fixed timeframe for completing the overall enforcement process. The duration will depend on factors including whether the enforcement order is appealed or challenged, the identification and location of the debtor\u2019s assets, and whether attachment, sale or other realisation measures are required.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is it possible to obtain interim relief (e.g. an injunction to restrain disposal of assets) while the enforcement or registration procedure takes place?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>A judgment creditor may apply to the UAE courts for interim measures to preserve the judgment debtor\u2019s assets while recognition and enforcement proceedings are pending.<\/p>\n<p>The GCC Convention and the Riyadh Arab Agreement do not establish a separate procedure for obtaining interim relief in the UAE. Where the applicable treaty does not regulate the issue, interim measures are governed by UAE procedural law. Article 25(c) of the Riyadh Arab Agreement also excludes provisional and precautionary measures issued in another contracting state from recognition and enforcement under the Agreement. A creditor may nevertheless apply separately to the UAE courts for precautionary relief.<\/p>\n<p>Under Article 247 of Federal Decree-Law No. 42 of 2022 Promulgating the Civil Procedure Code, the creditor may seek a precautionary attachment over the debtor\u2019s assets, subject to satisfying the applicable statutory requirements. Depending on the nature of the asset, precautionary attachment may extend to movable property, immovable property, bank accounts or debts owed by third parties.<\/p>\n<p>The attachment preserves the assets pending determination of the enforcement application but does not permit the creditor to realise or receive them until the foreign judgment has been recognised and enforcement has been authorised.<\/p>\n<p>Any applicable bilateral treaty should be reviewed to determine whether it contains specific provisions on interim or protective measures. Separate interim-relief frameworks, including freezing orders, are also available before the DIFC and ADGM Courts, subject to their respective jurisdictional requirements and court rules.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What is the limitation period for enforcing a foreign judgment in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Article 222 of Federal Decree-Law No. 42 of 2022 Promulgating the Civil Procedure Code does not prescribe a separate limitation period for filing an application to recognise and enforce a foreign judgment. However, under Article 212(5), an execution writ may not be enforced if it has remained unexecuted for 15 years from its date of issuance, or for 15 years from the date of the last execution measure where execution proceedings have commenced. Its application should therefore be distinguished from the initial recognition stage.<\/p>\n<p>Neither the GCC Convention nor the Riyadh Arab Agreement prescribes a specific limitation period. Under Article 3(B) of the GCC Convention and Article 31(b) of the Riyadh Arab Agreement, matters of enforcement procedure not regulated by the relevant treaty are governed by the law of the state where enforcement is sought. The judgment must also remain final and enforceable in the country of origin, as required under the relevant treaty.<\/p>\n<p>Different periods apply in the financial free zones. Under Rule 48.28 of the Rules of the DIFC Courts, the DIFC Courts shall not ordinarily make an order to enforce a judgment or order more than six years after it was made. Under section 173(1) of the ADGM Courts Regulations 2015, an application to register a judgment issued by a recognised court must be made within six years of the judgment or, where it was appealed, within six years of the last judgment in the appeal proceedings.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">On what grounds can the enforcement of foreign judgments be challenged in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Where no applicable treaty provides otherwise, the enforcement of a foreign judgment before the UAE onshore courts may be challenged on the ground that one or more of the conditions in Article 222(2) of Federal Decree-Law No. 42 of 2022 Promulgating the Civil Procedure Code have not been satisfied. These grounds include:<\/p>\n<ul>\n<li>the absence of reciprocity between the UAE and the country of origin;<\/li>\n<li>the underlying dispute falling within the exclusive jurisdiction of the UAE courts;<\/li>\n<li>the foreign court lacking jurisdiction under the rules of international jurisdiction applicable in the country of origin;<\/li>\n<li>the judgment not having been issued in accordance with the law of the country of origin or not having been duly authenticated;<\/li>\n<li>the parties not having been properly summoned or duly represented;<\/li>\n<li>the judgment not having acquired the force of res judicata in the country of origin;<\/li>\n<li>the judgment conflicting with a judgment or order previously issued by a UAE court; or<\/li>\n<li>the judgment containing anything contrary to UAE public order or morals.<\/li>\n<\/ul>\n<p>The enforcing court does not reconsider the merits of the underlying dispute. A challenge must therefore relate to the conditions for recognition and enforcement rather than an alleged error of fact or law by the foreign court.<\/p>\n<p>Under Article 2 of the GCC Convention, enforcement may be refused where:<\/p>\n<ul>\n<li>the judgment conflicts with Islamic Sharia, the Constitution, or public order of the requested state;<\/li>\n<li>a default judgment was issued without proper notification of the proceedings or judgment;<\/li>\n<li>there is an earlier final judgment involving the same parties, subject matter, and grounds;<\/li>\n<li>an earlier proceeding concerning the same dispute is pending before a court of the requested state;<\/li>\n<li>the judgment is against the requested state or one of its officials in respect of official acts;<\/li>\n<li>enforcement would conflict with an applicable international convention or protocol;<\/li>\n<li>the judgment does not satisfy the Convention\u2019s requirements on jurisdiction, finality, and enforceability.<\/li>\n<\/ul>\n<p>Under Articles 25 and 30 of the Riyadh Arab Agreement, recognition or enforcement may be refused where:<\/p>\n<ul>\n<li>the judgment conflicts with Islamic Sharia, the Constitution, public order, or morals of the requested state;<\/li>\n<li>a defendant in a default judgment was not properly notified to enable a defence;<\/li>\n<li>the rules of the requested state on representation of persons lacking or having limited legal capacity were not observed;<\/li>\n<li>there is an earlier final judgment concerning the same dispute;<\/li>\n<li>an earlier proceeding involving the same dispute is pending before a court of the requested state;<\/li>\n<li>the originating court lacked jurisdiction as required by the Agreement;<\/li>\n<li>the judgment is no longer enforceable in the country of origin;<\/li>\n<li>the judgment falls within a category excluded under Article 25(c).<\/li>\n<\/ul>\n<p>Where enforcement is sought before the DIFC Courts in the absence of an applicable treaty, the foreign judgment must satisfy the common-law requirements recognised by the DIFC Courts, including that it is final and conclusive and was issued by a foreign court having jurisdiction over the judgment debtor under DIFC conflict-of-laws principles. Enforcement may also be resisted where the judgment was obtained by fraud, the foreign proceedings were contrary to natural justice, or enforcement would be contrary to UAE public policy.<\/p>\n<p>In the ADGM, Article 175 of the ADGM Courts Regulations 2015 requires registration to be set aside where, among other matters, the judgment was registered contrary to the Regulations, the originating court lacked jurisdiction, a default judgment was issued without sufficient service, the judgment was obtained by fraud, the applicant is not entitled to the rights under the judgment, or enforcement would be contrary to public policy in Abu Dhabi or the ADGM. Registration may also be set aside where the dispute was previously determined by a final judgment of another competent court.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Will the courts in your jurisdiction reconsider the merits of the judgment to be enforced?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>No. The UAE courts do not rehear the underlying dispute or reconsider whether the foreign court correctly determined the facts or applied the law. The enforcing court examines only whether the applicable statutory or treaty conditions are satisfied and whether a recognised ground for refusal applies. This approach is reflected in Article 7 of the GCC Convention and Article 32 of the Riyadh Arab Agreement. The principal refusal grounds are summarised in Question 11.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Will the courts in your jurisdiction examine whether the foreign court had jurisdiction over the defendant? If so, what criteria will they apply to this?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The UAE courts will examine whether the foreign court had jurisdiction to determine the dispute and bind the judgment debtor.<\/p>\n<p>Where no applicable treaty applies, Article 222(2)(a) of Federal Decree-Law No. 42 of 2022 Promulgating the Civil Procedure Code requires the Execution Judge to be satisfied that:<\/p>\n<ul>\n<li>the underlying dispute was not within the exclusive jurisdiction of the UAE courts; and<\/li>\n<li>the foreign court had jurisdiction under the rules of international jurisdiction applicable in the country where the judgment was issued.<\/li>\n<\/ul>\n<p>Accordingly, the onshore court principally considers whether the foreign court was competent under its own international jurisdiction rules, while also ensuring that the dispute was not reserved exclusively to the UAE courts.<\/p>\n<p>Where the GCC Convention applies, Article 4 treats the originating court as having jurisdiction in civil and commercial matters where, among other circumstances:<\/p>\n<ul>\n<li>the defendant was domiciled or resident in the originating state when the proceedings were commenced;<\/li>\n<li>the defendant had an office or branch there and the dispute related to its activities;<\/li>\n<li>the contractual obligation was performed or was required to be performed there;<\/li>\n<li>the act giving rise to non-contractual liability occurred there;<\/li>\n<li>the defendant expressly agreed to the court\u2019s jurisdiction; or<\/li>\n<li>the defendant defended the merits without objecting to jurisdiction.<\/li>\n<\/ul>\n<p>Article 6 separately gives jurisdiction over rights in immovable property to the courts of the state where the property is situated.<\/p>\n<p>Under Articles 25 and 28 of the Riyadh Arab Agreement, the originating court must be competent under the jurisdictional rules recognised by the requested state and the dispute must not fall within the exclusive jurisdiction of another court. Article 28 recognises substantially similar connections, including the defendant\u2019s domicile or residence, a relevant branch or place of business, the place of contractual performance, the place of the harmful act, an agreement to jurisdiction, or participation in the merits without objecting to jurisdiction. Under Article 29, the enforcing court will generally rely on the jurisdictional facts recorded in the foreign judgment, except where the judgment was issued in absentia. Immovable property disputes are governed by Article 27 and fall within the jurisdiction of the courts where the property is located.<\/p>\n<p>The requirements under a bilateral treaty depend on its particular terms and should be reviewed separately.<\/p>\n<p>In the DIFC, the common-law jurisdiction test generally treats the foreign court as competent where the judgment debtor was present in the foreign jurisdiction when proceedings commenced, was the claimant or counterclaimant, submitted to the foreign court\u2019s jurisdiction, or had previously agreed to submit the relevant dispute to that court.<\/p>\n<p>Under section 175(2) of the ADGM Courts Regulations 2015, the original court may be treated as having jurisdiction where, among other matters, the judgment debtor voluntarily appeared, was a claimant or counterclaimant, agreed in advance to the court\u2019s jurisdiction, was resident or incorporated in the originating country, or maintained an office or place of business there through which the relevant transaction was conducted. For judgments concerning property, jurisdiction may also depend on the property having been situated in the country of the original court.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Do the courts in your jurisdiction impose any requirements on the way in which the defendant was served with the proceedings? Can foreign judgments in default be enforced?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>A foreign default judgment may be enforced in the UAE if the debtor was properly notified of the proceedings and had a fair opportunity to defend.<\/p>\n<p>Under Article 222(2)(c) of Federal Decree-Law No. 42 of 2022, the Execution Judge must be satisfied that the parties were properly summoned and represented. No specific service method is required, but evidence of proper notice must be provided. Default alone does not prevent enforcement.<\/p>\n<p>Under the GCC Convention (Articles 2 and 9), enforcement may be refused if the defendant was not properly notified, and proof of notification must be submitted.<\/p>\n<p>Under the Riyadh Arab Agreement (Articles 30(b) and 34(c)), recognition is refused if the defendant was not properly notified in a way that allowed a defence, and evidence of service is required.<\/p>\n<p>Bilateral treaties must be assessed on their own terms.<\/p>\n<p>In the DIFC, enforcement may be refused if lack of notice breaches natural justice. In the ADGM, a default judgment must be set aside if the defendant was not duly served in time to defend under section 175(1)(a)(iii) of the ADGM Courts Regulations 2015.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Do the courts in your jurisdiction have a discretion over whether or not to recognise foreign judgments?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The UAE courts do not have a broad discretion to refuse recognition of a foreign judgment and will generally recognise it where the applicable statutory or treaty requirements are satisfied, subject only to the recognised grounds for refusal discussed in Question 11.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any types of foreign judgment which cannot be enforced in your jurisdiction? For example can foreign judgments for punitive or multiple damages be enforced?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Not every foreign judgment is enforceable in the UAE. Although Article 222 of Federal Decree-Law No. 42 of 2022 does not contain a closed list of excluded judgment types, enforcement will be refused where the applicable statutory conditions are not satisfied, including where the UAE courts have exclusive jurisdiction, the judgment is not final, it conflicts with an existing UAE judgment, or enforcement would be contrary to UAE public order or morals. UAE legislation does not establish a blanket rule governing punitive or multiple-damages awards. While Article 255 of Federal Decree-Law No. 25 of 2025 assesses compensation by reference to the loss suffered and profit lost, it does not expressly determine whether a foreign punitive award is enforceable. A component that is penal rather than compensatory may therefore be refused on public-order grounds, depending on the substance and purpose of the award.<\/p>\n<p>Under the GCC Convention, qualifying final judgments in civil, commercial, administrative and personal status matters are generally enforceable. Enforcement may nevertheless be refused under Article 2, including where the judgment conflicts with Islamic Sharia, the Constitution or public order, or where it was issued against the UAE Government or an official in respect of acts performed in an official capacity. Article 7 permits enforcement of a divisible part of a judgment.<\/p>\n<p>Article 25(c) of the Riyadh Arab Agreement expressly excludes provisional and precautionary measures, judgments issued in bankruptcy, tax and duty matters, judgments against the government of the requested state or its officials in respect of official acts, and judgments whose enforcement would conflict with an applicable treaty. Article 30 also requires refusal where enforcement would conflict with Islamic Sharia, the Constitution, public order or morals. A divisible part of a judgment may be enforced under Article 32.<\/p>\n<p>In the DIFC, the common-law approach reflected in the DIFC Courts\u2019 Memoranda of Guidance excludes judgments ordering the payment of taxes, fines or penalties and permits refusal on public-policy grounds. Whether punitive or multiple damages are enforceable will therefore depend on whether the award is regarded as a private civil remedy or, in substance, a penalty.<\/p>\n<p>In the ADGM non-treaty recognised-court framework, section 171(2) of the ADGM Courts Regulations 2015 expressly excludes sums payable in respect of taxes or similar charges and fines or other penalties. There is no separate statutory exclusion for \u201cmultiple damages,\u201d but a punitive component may be excluded if it is characterised as a penalty or if another statutory ground for refusal applies.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Can enforcement procedures be started in your jurisdiction if there is a pending appeal in the foreign jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes, provided that the judgment remains final and enforceable under the law of the country of origin. Under Article 222(2)(d) of Federal Decree-Law No. 42 of 2022, the judgment must have acquired the force of res judicata. If the pending appeal suspends its finality or enforceability, enforcement in the UAE cannot proceed until the appeal is determined.<\/p>\n<p>Similarly, Articles 1 and 3(A) of the GCC Convention require the judgment to have acquired the force of res judicata and to remain enforceable in the originating state. Articles 25(b) and 31(a) of the Riyadh Arab Agreement impose equivalent requirements.<\/p>\n<p>In the DIFC, a foreign judgment may be regarded as final and conclusive despite a pending or possible appeal, although enforcement may be stayed where execution has been suspended in the country of origin.<\/p>\n<p>In the ADGM, section 172(3) of the ADGM Courts Regulations 2015 provides that a judgment may be final and conclusive notwithstanding a pending or possible appeal. However, it cannot be registered if it is not enforceable by execution in the country of origin. The Court may also stay proceedings or set aside registration where an appeal is pending or intended.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Can you appeal a decision recognising or enforcing a foreign judgment in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. Under Article 222(2) of Federal Decree-Law No. 42 of 2022, an order granting or refusing enforcement of a foreign judgment may be appealed directly in accordance with the procedures applicable to appeals against judgments.<\/p>\n<p>The GCC Convention and Riyadh Arab Agreement do not prescribe a separate appeal procedure. Accordingly, where enforcement is sought before the UAE onshore courts, the applicable UAE procedural rules govern the appeal unless the relevant treaty provides otherwise.<\/p>\n<p>In the DIFC and ADGM, a decision recognising or enforcing a foreign judgment may also be appealed, generally subject to permission to appeal.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Can interest be claimed on the judgment sum in your jurisdiction? If so on what basis and at what rate?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. Where the foreign judgment itself awards interest, the judgment creditor may seek enforcement of the principal sum together with the interest awarded, subject to the requirements of Article 222 and UAE public order. Article 222 does not prescribe an independent interest rate for foreign judgments. Any claim for interest beyond that expressly included in the foreign judgment should be addressed under the applicable UAE execution rules and should not be assumed to arise automatically.<\/p>\n<p>The GCC Convention and Riyadh Arab Agreement do not prescribe an independent interest rate. Accordingly, any entitlement to interest will generally depend on the terms of the foreign judgment and the law applied by the originating court.<\/p>\n<p>In the ADGM, a foreign judgment registered under section 173 of the ADGM Courts Regulations 2015 carries any interest due under the law of the country of origin up to the date of registration. From registration, it is treated as an ADGM judgment and carries interest at 5% per annum where no other rate applies, unless the Court orders otherwise.<\/p>\n<p>In the DIFC, interest awarded under the foreign judgment may be included in the amount recognised. Once the DIFC Courts enter a judgment recognising and enforcing the foreign judgment, the judgment generally carries simple interest at 9% per annum from the date of entry, unless the Court orders otherwise, pursuant to Practice Direction No. 4 of 2017.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Do the courts of your jurisdiction require a foreign judgment to be converted into local currency for the purposes of enforcement?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>A foreign judgment may be presented by reference to the currency stated in the judgment. For court-fee, accounting or execution purposes, the enforcing court may require an AED equivalent. The applicable conversion date and rate may depend on the court\u2019s order and execution practice. Neither Article 222 nor the principal multilateral treaties prescribe a uniform currency-conversion rule.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Can the costs of enforcement (e.g. court costs, as well as the parties\u2019 costs of instructing lawyers and other professionals) be recovered from the judgment debtor in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes, although the extent of recovery depends on the court in which enforcement is sought.<\/p>\n<p>Before the UAE onshore courts, Article 133 of Federal Decree-Law No. 42 of 2022 generally requires the unsuccessful party to bear the legal costs, including court fees, necessary expenses and an amount for lawyers\u2019 fees determined by the court. However, the lawyers\u2019 fees awarded are not necessarily equal to the actual fees paid by the successful party.<\/p>\n<p>The GCC Convention and Riyadh Arab Agreement do not establish a separate costs regime, so costs are generally determined under the procedural law of the enforcing court.<\/p>\n<p>In the DIFC and ADGM, the courts have discretion to order the unsuccessful party to pay the successful party\u2019s reasonable legal and professional costs, subject to assessment.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are third parties allowed to fund enforcement action in your jurisdiction? If so, are there any restrictions on this and can third party funders be made liable for the costs incurred by the other side?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. Third-party funding may be used in enforcement proceedings in the UAE, but the position depends on the forum.<\/p>\n<p>In the UAE onshore courts, there is no specific legislation regulating or prohibiting third-party funding. It is therefore governed by general contract principles and public policy. There is no automatic duty to disclose funding, and funders are not generally liable for adverse costs unless they have agreed otherwise or are independently liable.<\/p>\n<p>In the DIFC Courts, third-party funding is expressly regulated by Practice Direction No. 2 of 2017. The existence of funding and the funder\u2019s identity must be disclosed, although the funding agreement itself is not usually disclosed unless ordered. Funding may be relevant to security for costs, and the Court may in appropriate cases make costs orders against funders.<\/p>\n<p>In the ADGM Courts, third-party funding is regulated under Article 225 of the ADGM Courts Regulations 2015 and the Litigation Funding Rules 2019. The agreement must be in writing, the funder must meet eligibility requirements, and the funded party must obtain independent legal advice. The agreement must address key issues such as costs, settlement, termination, and conflicts of interest, and the funder must not control the proceedings.<\/p>\n<p>The funded party must disclose the existence of the funding arrangement. The rules also require clarity on adverse costs coverage and provide that the funder submits to the Court\u2019s jurisdiction for costs matters. The Court may, in appropriate circumstances, order costs against a funder, but this is not automatic.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What do you think will be the most significant developments in the enforcement process in your jurisdiction in the next 5 years?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The enforcement process in the UAE has continued to evolve in recent years, reflecting the broader development of the country\u2019s legal and judicial framework. Over the years, further changes may be introduced to improve the efficiency, accessibility and effectiveness of enforcement procedures. These developments may arise through legislative amendments, procedural reforms or evolving court practice.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Has your country ratified the Hague Choice of Courts Convention 2005, and if so when did it (or will it) come into force? If not, do you expect it to in the foreseeable future?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>No. The UAE has not ratified or acceded to the Hague Convention of 30 June 2005 on Choice of Court Agreement<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Has your country ratified the Hague Judgments Convention 2019, and if so when did it (or will it) come into force? If not, do you expect it to in the foreseeable future?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>No. The UAE has not ratified or acceded to the Hague Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\r\n<div class=\"word-count-hidden\" style=\"display:none;\">Estimated word count: <span class=\"word-count\">5710<\/span><\/div>\r\n\r\n\t\t\t<\/ol>\r\n\r\n<script type=\"text\/javascript\" src=\"\/wp-content\/themes\/twentyseventeen\/src\/jquery\/components\/filter-guides.js\" async><\/script><\/div>"}},"_links":{"self":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/comparative_guide\/148272","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/comparative_guide"}],"about":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/types\/comparative_guide"}],"wp:attachment":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/media?parent=148272"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}