Enforcing a foreign judgment or arbitral award in the Gulf and Egypt: conditions, documents and timelines

When a judgment from another country is enforced, what the New York Convention, the Riyadh Convention and national laws require, and the documents needed for an enforcement application.

Winning the judgment is half the road; the other half is enforcing it where the debtor's assets are. A short guide to what the Gulf states and Egypt require to enforce foreign judgments and arbitral awards.

Foreign arbitral awards: the New York Convention

All Gulf states and Egypt are parties to the 1958 New York Convention. Foreign awards are enforced unless one of the limited grounds for refusal applies: invalid arbitration agreement, improper notice, award beyond the scope of the submission, irregular constitution of the tribunal, annulment at the seat, or public policy. Courts in the UAE, Saudi Arabia and Egypt have become markedly more consistent in applying the Convention in recent years.

Foreign court judgments

Governed by national law and judicial cooperation treaties: the Riyadh Arab Agreement for Judicial Cooperation, the GCC Convention on the Enforcement of Judgments, and bilateral treaties. The usual conditions: the judgment is final and res judicata, issued by a competent court, after proper service and an opportunity to defend, not in conflict with an earlier judgment or public policy, and reciprocity where required.

Documents usually required

- The original or a certified copy of the judgment or award.
- The arbitration agreement (for awards).
- A certificate of finality.
- Proof of service on the judgment debtor.
- Certified Arabic translations of all of the above.
- Consular legalisation or apostille, depending on the country.

Timelines

Limitation periods for enforcement differ and must be checked immediately; so does the competent court: the Execution Court in the UAE, the Enforcement Court through Najiz in Saudi Arabia, the Court of First Instance in Egypt.

How LexArab helps

Choose the enforcement country and upload the judgment and the arbitration agreement; the assistant drafts the enforcement application in the accepted form, identifies the conditions to prove under the national law and the applicable treaty, and prepares the document checklist. The documents are then assembled into one numbered bundle with the Document Bundle tool.

Note: procedural details change and some countries apply additional conditions to particular judgments. Check the current text and recent court decisions before filing.