Mahmoud Ahmed July 7, 2025July 7, 2025 When a court or arbitration panel issues a ruling in another country, enforcing it in the UAE isn’t always automatic. Specific legal steps are required to ensure that foreign judgments and arbitration awards are recognized and executed within the country. Here’s a simplified breakdown of how it works and the potential challenges involved. Understanding Enforcement: Two Key Steps Enforcing a foreign judgment or arbitration award in the UAE generally involves two stages: Ratification – Officially recognizing the judgment or award as valid in the UAE. Execution – Taking legal steps to enforce the judgment, such as seizing assets or compelling payment. Enforcing Foreign Court Judgments in the UAE The UAE has agreements in place to facilitate the enforcement of foreign court rulings. It is a signatory to the GCC Convention and Riyadh Convention and has bilateral treaties with various countries. Additionally, specialized courts such as the ADGM Courts and DIFC Courts have agreements with international commercial courts to streamline enforcement processes. Two Routes for Enforcement There are two main avenues for enforcing a foreign judgment in the UAE: Onshore Courts – A request is filed with an Execution Judge, who must confirm that the country issuing the judgment has a reciprocal enforcement agreement with the UAE. DIFC Courts – The DIFC Court can recognize a foreign judgment and issue a ratification order, making it easier to enforce within the UAE. Key Requirements for Onshore Enforcement For a judgment to be recognized by onshore UAE courts, it must: Come from a country with a reciprocal enforcement agreement with the UAE. Be issued in accordance with the laws of its home country. Ensure that all parties involved had legal representation and a fair trial. Be final and not subject to further appeal. Not contradict UAE public order or morality laws. Common Challenge: Reciprocity A major hurdle for onshore enforcement is proving reciprocity. If the issuing country does not recognize UAE judgments in return, enforcement can be difficult. Because of this, many practitioners prefer the DIFC Court route, which offers more flexibility in recognizing foreign judgments. Enforcing Foreign Arbitral Awards in the UAE The UAE is widely regarded as a global leader in recognizing and enforcing foreign arbitration awards, largely due to its commitment to the New York Convention. This international treaty provides a standardized approach to enforcement, minimizing potential objections and legal roadblocks. Why Arbitration Is Easier to Enforce The New York Convention streamlines enforcement procedures, ensuring arbitration awards are recognized in over 160 countries. The DIFC and ADGM Courts provide an alternative to onshore enforcement, simplifying the process. The UAE’s legal framework supports businesses and investors by promoting fair and efficient enforcement. Collecting Assets and Execution Once a foreign judgment or arbitration award is ratified, the next step is execution—ensuring the ruling is actually carried out. The UAE provides clear guidelines and efficient timelines to help creditors recover assets swiftly, giving businesses and individuals confidence in the legal system. Need Help? Navigating the enforcement process can be complex, but our team of experienced legal professionals is here to help. Whether you need assistance with court judgments or arbitration awards, we’re ready to support you every step of the way.
