Arbitration In The United Arab Emirates: Key Differences Between DIFC, ADGM, And Onshore Courts

Key takeaway

The United Arab Emirates is characterised by a "jurisdiction within a jurisdiction" model for international dispute resolution. The UAE offers three distinct jurisdictions: the onshore civil law system, the Dubai International Financial Centre (DIFC), and the Abu Dhabi Global Market (ADGM).

While onshore UAE arbitration operates under a civil law system governed by Federal Law No. 6 of 2018, the DIFC and ADGM offer common law jurisdictions modelled on English law, providing a familiar environment for international parties. The ADGM applies English law directly, whereas the DIFC is heavily influenced by English law but has statutes and evolving common law of its own.