Comparative Guide On Onshore Vs Offshore Arbitration Seats In The UAE

At the outset, it may be useful to note that the laws applied in each of the onshore jurisdictions outlined above, i.e. Abu Dhabi and Dubai, the Dubai International Financial Centre ("DIFC") and the Abu Dhabi Global Markets ("ADGM") are largely based on the UNICITRAL Model Law, aligning the UAE's arbitral framework with international standards, and making the UAE (including the financial free zones named above) an arbitration-friendly legal landscape.

When selecting an arbitration seat, the contracting parties are essentially submitting to arbitrate within one of these three jurisdictions. This choice directly impacts the courts that will oversee with curial and supervisory jurisdiction of the arbitration process and the procedural laws governing it, and it can influence various procedural aspects of an arbitration, including rights of appeal, availability of interim remedies, and grounds for challenging an award.