What law governs enforcement of foreign judgments in the UAE?
Chapter Four of the Civil Procedure Code (Federal Decree-Law No. 42 of 2022, Articles 222 to 225) governs the execution of foreign judgments, orders, arbitral awards and instruments. These rules apply without prejudice to treaties between the UAE and other countries (Article 225), so a treaty can make enforcement easier, for example the New York Convention for foreign arbitral awards, which the UAE joined by Federal Decree No. 43 of 2006.
| What you hold | Main rules |
|---|---|
| Foreign court judgment or order | Civil Procedure Code, Article 222, and any applicable treaty |
| Arbitral award made abroad | New York Convention; Civil Procedure Code, Article 223 |
| Foreign notarised document or court-certified settlement | Civil Procedure Code, Article 224 |
| Arbitral award made in the UAE (onshore seat) | Arbitration Law, Articles 55 and 57; see arbitration in Dubai |
What conditions must a foreign judgment meet?
A foreign judgment can be enforced in the UAE on the same conditions that the issuing country applies to UAE judgments (reciprocity), and only after the Execution Judge verifies five conditions in Article 222 of the Civil Procedure Code.
- Jurisdiction: the UAE courts did not have jurisdiction over the dispute, and the foreign court did under its own rules of international jurisdiction.
- Competent court: the judgment was issued by a court competent under the law of its country and is duly authenticated.
- Proper notice: the parties were summoned and duly represented.
- Finality: the judgment has the force of res judicata under the law of the issuing court, shown by a certificate of finality or by the judgment itself.
- No conflict: it does not conflict with a judgment or order of a UAE court, and contains nothing contrary to morals or public order in the UAE.
How is a foreign arbitral award enforced in the UAE?
Foreign arbitral awards follow the same procedure as foreign judgments, with two extra conditions: the dispute must be arbitrable under UAE law, and the award must be enforceable in the country where it was made (Article 223). Because the UAE is a party to the New York Convention, enforcement can be refused only on the limited grounds in Article V of the Convention.
What is the procedure, step by step?
- 1. Check the legal basisIs there a treaty with the issuing country, or does that country enforce UAE judgments (reciprocity)? For arbitral awards, the New York Convention usually applies.
- 2. Collect the documentsA certified copy of the judgment or award, a certificate that it is final, proof of service on the other party, and for awards the arbitration agreement.
- 3. Authenticate and translateForeign documents are normally legalised for use in the UAE and translated into Arabic by a certified translator.
- 4. File the petitionA petition with the required details is submitted to the Execution Judge (Article 222). The judge may ask for supporting documents.
- 5. Decision within 5 working daysThe judge issues the order within five working days of the petition. The decision can be appealed under the rules for appealing judgments.
- 6. ExecuteOnce enforceable, the judgment or award is executed like a UAE judgment: attachment of bank accounts, real property, vehicles and company shares. See debt recovery in the UAE.
Why can enforcement be refused?
- The UAE courts had jurisdiction over the dispute themselves.
- The defendant was not properly summoned or represented abroad.
- The judgment is not yet final, or no proof of finality is filed.
- A UAE court has already ruled on the same dispute.
- The judgment or award conflicts with UAE public order or morals.
- For awards: the subject cannot be arbitrated under UAE law, or the award is not enforceable where it was made.
Key rules and time limits
| Rule | Figure or requirement | Article |
|---|---|---|
| Who decides | The Execution Judge, on a petition | 222 |
| Time for the decision | 5 working days from the petition | 222 |
| Challenge to the decision | Appeal under the rules for appealing judgments | 222 |
| Basis | Reciprocity, unless a treaty provides otherwise | 222, 225 |
| Foreign arbitral awards | Same rules, plus arbitrability under UAE law and enforceability where made | 223 |
| UAE-seated arbitral awards | Court decision within 60 days; grievance within 30 days | Arbitration Law, 55 and 57 |
How much does enforcement cost?
Costs include legalisation and certified Arabic translation of the foreign documents, the court's execution fees, and legal fees. We quote in writing after checking the judgment or award, the treaty position with the issuing country, and where the debtor's assets are.
Do not rely solely on the information available on the website; you should consult a lawyer to clarify many matters.
Related guides: arbitration in Dubai and the UAE, debt recovery for companies, commercial and corporate litigation.
Frequently asked questions
Can a foreign judgment be enforced in the UAE?
Yes, by a petition to the Execution Judge under Article 222 of the Civil Procedure Code, on the same conditions the issuing country applies to UAE judgments, unless a treaty provides otherwise.
How long does it take to enforce a foreign judgment in the UAE?
The Execution Judge must issue the order within five working days of the petition (Article 222). Preparing, legalising and translating the documents usually takes longer than the decision itself.
What documents do I need?
A certified copy of the judgment or award, proof that it is final, proof that the other party was properly summoned, and certified Arabic translations. For an arbitral award, also the arbitration agreement.
Can a foreign arbitral award be enforced in Dubai?
Yes. The UAE joined the New York Convention by Federal Decree No. 43 of 2006, and Article 223 of the Civil Procedure Code applies the same procedure to foreign awards, provided the subject is arbitrable under UAE law and the award is enforceable where it was made.
Can the UAE court review the merits of the foreign judgment?
No. The Execution Judge checks the conditions in Article 222: jurisdiction, competent court, proper notice, finality, and no conflict with a UAE judgment or UAE public order.
What if the UAE courts also had jurisdiction?
Then the foreign judgment cannot be enforced under Article 222, because one of the conditions is that the UAE courts had no jurisdiction over the dispute.
Can the enforcement decision be challenged?
Yes. The Execution Judge's order can be appealed under the rules and procedures for appealing judgments (Article 222).