تنفيذ أحكام التحكيم الأجنبية في الإمارات والسعودية

Enforcing a foreign arbitral award in the UAE and Saudi Arabia

Winning an arbitration is only half the job. If the losing party's assets are in the UAE or Saudi Arabia, you need a local court to enforce the award. Both countries are parties to the 1958 New York Convention, which limits the reasons a court can give for refusing enforcement.

In the UAE (mainland)

• Law: Articles 222 and 223 of the Civil Procedure Law (Federal Decree-Law No. 42 of 2022), together with the UAE Arbitration Law. The New York Convention, which the UAE joined in 2006, takes precedence.
• Where: you apply to the execution judge.
• Speed: the judge must decide within five days of the application. The decision can be appealed within 30 days.
• Conditions: the subject of the dispute must be arbitrable under UAE law, and the award must be enforceable in the country where it was made.
• Common pitfalls: courts have refused awards where the reasoning and the operative part were not properly signed by the arbitrators, and have examined whether the person who signed the arbitration agreement for a company had authority to do so.

The DIFC Courts have their own enforcement route, which some creditors use for assets connected with the DIFC.

In Saudi Arabia

• Law: Article 11 of the Enforcement Law of 2012 and the Arbitration Law of 2012. Saudi Arabia joined the New York Convention in 1994, on the basis of reciprocity.
• Where: you file directly with the Enforcement Court. There is no separate recognition case first.
• Main conditions: reciprocity with the country where the award was made, a tribunal with jurisdiction, a final award, proper notice to the parties, no conflict with an earlier Saudi judgment, and no conflict with Sharia or public policy.
• Documents: the original award or a certified copy, a certified Arabic translation, proof that the award is final, and legalisation or an apostille as required.
• Fees: the court fee for monetary claims is 2% of the amount, with a minimum of SAR 500 and a maximum of SAR 10,000.

Saudi Arabia's new Enforcement Law

A new Enforcement Law was issued by Royal Decree No. M/237 in April 2026 and replaces the 2012 law. It comes into force 180 days after its publication in the Official Gazette, which places it in late October 2026. Points to note for creditors:
• arbitral awards remain enforcement instruments, and foreign awards are enforced in line with the Kingdom's treaties;
• an enforcement request will not be accepted if more than ten years have passed since the amount became due;
• debtors must disclose their assets, with daily fines and stronger penalties for those who hide them.
If you hold an old award, do not delay filing.

Before you file in either country

• Check that the award is signed correctly and is final at the seat.
• Gather translations and legalisation early: missing documents are the most common cause of delay.
• Locate the debtor's assets first, so enforcement has something to attach to.

The LexArab assistant can check your award against these conditions and list the documents you still need.

This article is general legal information, not legal advice. Enforcement practice changes, so confirm the current position with a lawyer before filing.