Enforcing Foreign Judgments and Arbitral Awards in The UAE

Posted onJanuary 26, 2026
Matthew Purcell

The UAE enforced foreign judgments and arbitral awards underwent a fundamental change in September 2022 when the Ministry of Justice confirmed that English court judgments could be enforced under the reciprocity principle. This followed the English High Court's decision in Lenkor Energy Trading DMCC v Puri [2021] EWCA Civ 770, in which the English courts enforced a Dubai judgment, establishing mutual recognition between the jurisdictions.

Historically, proving reciprocity required demonstrating a formal bilateral treaty between the UAE and the issuing country. Without such a treaty, creditors faced rejection. The Ministry directive clarified that reciprocity does not require formal treaties. Instead, it can be established through judicial precedent, as Lenkor demonstrated.

Article 222(1) of the Civil Procedure Law now governs the execution of foreign judgments. Foreign judgments may be executed under the same conditions prescribed by the law of the foreign country for executing UAE judgments. When English courts enforced the Dubai judgment in Lenkor because it was final and conclusive and did not offend public policy, UAE courts recognised this as establishing reciprocity.

The UAE and international enforcement treaties

The UAE is a signatory to multilateral treaties, including the 1996 Gulf Cooperation Council Convention for the Execution of Judgments and the 1983 Riyadh Arab Convention. Where no formal agreement exists, reciprocity must be demonstrated through evidence that the foreign country will enforce UAE judgments under comparable conditions. The Dubai Court of Cassation has recently confirmed that the GCC Convention allows simultaneous enforcement across member states, preventing debtors from evading obligations by relocating within the Gulf region.

Since the UAE signed the New York Convention in 1986, its courts have gradually moved away from older, stricter local rules for recognising foreign arbitration awards. They now follow the more flexible New York Convention rules, which state that a foreign award may be refused only for a limited number of specific reasons, including.

One of the parties lacked legal capacity to enter into the Arbitration Agreement, or the arbitration clause itself was invalid under the relevant law.
The losing party was not properly notified of the appointment of the arbitrator or the arbitration proceedings, or was not given a fair chance to present its case.
The award addresses issues not covered by the parties' agreement to arbitrate.
The arbitral tribunal was not formed as the parties had agreed, or the procedure used did not follow what the parties had agreed or the law of the place of arbitration.
The award is not yet final and binding on the parties, or it has been set aside or suspended by a court in the country where the arbitration was seated.
The type of dispute is something that, under UAE law, cannot be decided by arbitration at all.
Enforcing the award would go against the public policy of the UAE, for example, because it conflicts with fundamental legal or moral principles in the country.

Only the last two grounds, which concern whether the dispute is arbitrable and whether enforcement would breach UAE public policy, may be considered by the UAE court on its own initiative. For all the other grounds, the party resisting enforcement must raise them and prove that they apply.

How to enforce a foreign arbitration award in the UAE

In the UAE, foreign arbitration awards are enforced using the same basic process as foreign court judgments. This process is set out in the New Civil Procedure Law.

To initiate enforcement, the party that prevailed in arbitration files a written request (a petition) with the execution judge in the UAE. This is usually done without notifying the other party at that stage. The judge should issue a decision within five days.

Mohammed Al Dahbashi, Managing Partner of UAE-based ADG Legal, comments on the matter: “It is important to note that the Ministry of Justice and the Ministry of Foreign Affairs launched a digital platform for international judicial cooperation, aimed at simplifying the exchange of requests and legal documents with foreign jurisdictions, reducing bureaucratic delays, and accelerating the enforcement process.”

What the UAE court checks before enforcing

Before the court can order enforcement of a foreign arbitration award, it must check that several conditions are met:

The parties genuinely agreed to arbitration and accepted that the arbitral tribunal would decide their dispute.
The award was made in line with the law of the country where it was issued, and it has been properly authenticated or ratified there.
Both parties were properly notified of the arbitration and had the opportunity to participate, in accordance with the rules of the arbitration centre or institution that handled the case.
The award is final and binding in its home country, so it is no longer open to ordinary appeal there.
Enforcing the award in the UAE will not conflict with any existing UAE court judgment and will not contravene UAE public policy or morals.

What must be in the enforcement application?

The same basic rules that apply to starting a lawsuit in the UAE also apply to an application to enforce a foreign arbitration award. The application must:

Identify both parties to the arbitration, with their key details.
State which UAE court the application is being filed in.
Give the filing date.
Clearly set out what the applicant is asking the court to do and the reasons for that request.

The application must be signed by the party applying, or by someone properly authorised to act for them, such as a lawyer holding a power of attorney.

Currency and time limits

If the award is in a currency other than UAE dirhams (AED), the amount must be converted into AED at the official rate used by the court. If there is any disagreement over the correct rate, the court's accountant will calculate the conversion.

An application to enforce a foreign arbitration award must be filed within 15 years of the date of the award. If the application is filed in time but left without action for more than 12 months, there is a risk that the enforcement process will be treated as time-barred and may need to be restarted.

Effect of the enforcement order

Once the court issues an order enforcing the foreign award, the award can be enforced immediately against the debtor's assets in the UAE. The losing party can appeal to the Court of Appeal, but that appeal does not automatically stop enforcement. The creditor can usually continue enforcement unless the court orders a suspension.

Common pitfalls when enforcing judgments in the UAE

For foreign arbitral awards, applicants must submit the original award or a certified copy, the Arbitration Agreement, a certified Arabic translation by accredited bodies, and supporting corporate authorisations and powers of attorney.

Applicants must be alive to translation rules. Article 48 of the UAE Civil Procedure Code mandates that foreign-language documents be translated into Arabic by certified translators.

Mr Al Dahbashi also told us that “In addition to the well-known Lenkor Energy Trading DMCC v Puri case, which marked a new beginning for recognizing foreign judgments in the UAE even without bilateral treaties, the recent Appeal No. 339/2024 confirmed that foreign judgments can be enforced even when UAE courts have jurisdiction over the dispute, provided it is not exclusive. However, practical and legal challenges remain, particularly with foreign default judgments. In Civil Appeal No. 228 of 2023, the Dubai Court of Cassation refused to enforce a Syrian judgment issued in absentia due to missing formal documents, illustrating that the mere existence of reciprocity or a treaty is not sufficient.”

Many applications fail due to simple technical errors, which is why having an experienced Civil Litigation Solicitor advising you is crucial.

Strategic recommendations

Procedures differ between the onshore UAE courts, the DIFC Courts, and the ADGM Courts, and choosing where to apply will depend largely on where the debtor's assets are located and which forum offers the strongest procedural tools.
Apply for precautionary attachment orders or freezing orders as soon as you file an enforcement application. These can often be obtained without telling the other side in advance, and once you have a court ruling or an arbitral award, the court should grant such an order as of right, without you needing to prove a risk that assets will be moved.
Ensure all foreign documents are properly attested and legalised in accordance with UAE laws. Where the originating country is a party to the 1961 Hague Apostille Convention, an apostille stamp is generally accepted by UAE consulates as part of the legalisation process. However, additional UAE-specific attestation steps are still required. Use a structured case management system and calendar reminders to monitor all limitation periods and procedural deadlines so none are missed.
Set realistic expectations about timing. While an execution judge may issue an initial order within three to five days, tracing and seizing assets usually take longer. In practice, travel bans, freezing injunctions, and asset attachment orders often persuade even the most stubborn of debtors to settle quickly.

Frequently Asked Questions

What changed in 2022 for enforcing English court judgments in the UAE?

In September 2022, the UAE Ministry of Justice issued a directive confirming that English court judgments should be enforced in the UAE under the principle of reciprocity, citing the English courts' enforcement of a Dubai judgment in Lenkor Energy Trading DMCC v Puri as proof of reciprocity.

Does a treaty need to be in place for my foreign judgment to be enforced in the UAE?

Not necessarily. For countries like England and Wales, reciprocity can now be shown through case law rather than a formal treaty, provided the foreign courts enforce UAE judgments on similar terms (final, conclusive, and not contrary to public policy).

How is enforcing an arbitral award different from enforcing a court judgment in the UAE?

Both follow the New Civil Procedure Law, but arbitral awards are tested against the New York Convention criteria (such as validity of the arbitration agreement and due process). In contrast, foreign court judgments are reviewed under Cabinet Resolution No. 57 of 2018 and any applicable treaties or reciprocity principles.

What documents are usually needed to enforce a foreign arbitral award?

Creditors typically need the original or certified copy of the award, the arbitration agreement, certified Arabic translations, and corporate documents and powers of attorney that prove the applicant is properly authorised, all legalised in line with UAE rules.

Why do enforcement applications in the UAE often fail?

Many fail for avoidable technical reasons, such as missing or defective translations, incomplete legalisation, incorrect party details, or filing in the wrong forum, which is why specialist UAE or regional enforcement counsel and robust case management are so important.