TRW & Co · Disputes & Arbitration
International Arbitration in the UAE
International arbitration in Dubai has been reshaped: the DIFC-LCIA closed in 2021, DIAC adopted new rules in 2022, arbitrateAD replaced Abu Dhabi's chamber centre in 2024 and the DIFC consulted on a new arbitration law in 2026. This guide explains how to choose the seat, institution and rules, and how to make the award enforceable.
Key pointThe seat, not the hearing venue, decides which court hears a challenge to your award; under the DIAC Rules 2022 the DIFC is the default seat only where the parties have not chosen one, so "arbitration in Dubai" should never be left unqualified.
At a glance
DIFC-LCIA abolished
Dubai Decree No. 34 of 2021, in force from 20 September 2021, transferred the DIFC-LCIA and maritime centre functions to DIAC.
DIAC Rules 2022
Apply to arbitrations filed from 21 March 2022, with a default DIFC seat and an expedited track for claims up to AED 1 million.
arbitrateAD from 2024
Replaced Abu Dhabi's chamber centre on 1 February 2024, with a default ADGM seat and expedited proceedings up to AED 9 million.
Two common-law seats
The DIFC and ADGM have Model Law-based arbitration laws supervised by English-language courts; the DIFC consulted on reforms in June 2026.
Global enforceability
The UAE joined the New York Convention in 2006, so UAE-made awards can be enforced in more than 170 contracting states.
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What international arbitration in Dubai and the wider UAE covers
International arbitration in Dubai, and in the UAE more widely, is the resolution of cross-border commercial disputes by private tribunals under institutional rules, with the award enforceable in more than 170 countries under the New York Convention. It is the usual choice for joint ventures, M&A, energy, infrastructure, trade finance and technology contracts where at least one party is foreign.
The core decisions are which seat, which institution and which rules. In the UAE those choices changed significantly in recent years: Dubai abolished the DIFC-LCIA centre in 2021, DIAC issued new rules in 2022, Abu Dhabi replaced its chamber centre with arbitrateAD in 2024, and the DIFC launched a consultation on a new arbitration law in 2026.
This page is about those international choices. The onshore framework under the Federal Arbitration Law, and the supervisory role of the onshore courts, is covered on our page on UAE-seated arbitration.
The institutional landscape after 2021
The end of the DIFC-LCIA
Dubai Decree No. 34 of 2021, in force from 20 September 2021, abolished the DIFC Arbitration Institute, which had run the DIFC-LCIA Arbitration Centre with the LCIA, together with the Emirates Maritime Arbitration Centre, and transferred their rights and obligations to DIAC. Dubai now has one arbitral institution.
Arbitration agreements referring to the DIFC-LCIA signed before the decree remain valid. Under the transition arrangements, cases that the DIFC-LCIA had registered on or before 20 March 2022 continued to be administered by the LCIA, while new proceedings under old DIFC-LCIA clauses are generally brought before DIAC under its 2022 Rules unless the parties agree otherwise. Clauses still naming the DIFC-LCIA should be updated.
DIAC and its 2022 Rules
The Dubai International Arbitration Centre adopted new Arbitration Rules that apply to arbitrations filed from 21 March 2022. Key features include an Arbitration Court that appoints tribunals, decides challenges and scrutinises draft awards for form; a default seat in the DIFC where the parties have not agreed one; emergency arbitrator provisions; consolidation and joinder powers; and recovery of legal costs as part of the costs of the arbitration.
Expedited proceedings apply where total claims and counterclaims are AED 1 million or less, where the parties agree, or in cases of exceptional urgency, with a sole arbitrator and a final award due within three months of the file being transmitted, subject to extension. The current rules are published on the DIAC rules page.
arbitrateAD in Abu Dhabi
The Abu Dhabi International Arbitration Centre (arbitrateAD) replaced the Abu Dhabi Commercial Conciliation and Arbitration Centre on 1 February 2024, with new rules applying to arbitrations started on or after that date. The default seat is the ADGM unless the arbitrateAD Court decides otherwise.
The arbitrateAD Rules include expedited proceedings for claims and counterclaims up to AED 9 million, emergency arbitrators, early dismissal of manifestly unmeritorious claims, mandatory disclosure of third-party funders, and scrutiny of awards. Existing cases under the old centre continue under its 2013 rules.
The DIFC and ADGM as seats
The DIFC Arbitration Law of 2008 and the ADGM Arbitration Regulations 2015, amended in 2020, are both based on the UNCITRAL Model Law and give the DIFC Courts and the ADGM Courts supervisory jurisdiction over arbitrations seated there. In June 2026 the DIFC Authority consulted on a replacement Arbitration and Mediation Law that would, among other changes, shorten the window to challenge a DIFC-seated award from three months to 30 days and expressly empower tribunals to dispose of hopeless claims summarily. Check whether it has been enacted before relying on any deadline.
Seat selection for international arbitration in Dubai
The seat determines the procedural law, the supervising court and where the award is "made" for New York Convention purposes. For international arbitration in Dubai, the realistic options are an onshore Dubai seat, a DIFC seat, an ADGM seat, or a foreign seat such as London or Singapore with hearings in Dubai.
| Seat | Arbitration law | Supervising court | Award challenge window | Best suited to |
|---|---|---|---|---|
| Onshore Dubai | Federal Law No. 6 of 2018 (amended 2023) | Dubai Court of Appeal | 30 days from notification | UAE-law contracts with onshore parties and assets |
| DIFC | DIFC Arbitration Law 2008 (reform proposed in 2026) | DIFC Courts (English, common law) | Currently three months; 30 days proposed | Foreign-law contracts wanting English-language court support in Dubai |
| ADGM | ADGM Arbitration Regulations 2015 (amended 2020) | ADGM Courts (English, common law) | Three months unless otherwise agreed | Abu Dhabi projects and arbitrateAD cases |
| Foreign seat (e.g. London, Singapore) | Law of the seat | Courts of the seat | Set by the seat's law | Parties wanting a neutral seat outside the region |
Practical tests help. Where are the assets that will satisfy an award? Which court do you want to hear a challenge, in which language? Is the governing law UAE law, English law or something else? Do you need court support for interim relief in the UAE? A foreign seat does not prevent a party from seeking UAE court assistance, but it adds a layer of recognition before an award can be executed against UAE assets.
If your clause says only "arbitration in Dubai", treat the seat as uncertain. Agree the seat in writing with the counterparty as soon as a dispute looms, before positions harden; it is far cheaper than a jurisdiction fight before the tribunal, the seat's court and possibly the Conflict of Jurisdiction Tribunal.
Choose the seat for the court you would want to hear the challenge to your award, not for the city where you would like to hold the hearing.
Choosing the institution and rules
International parties in Dubai typically choose between DIAC, arbitrateAD, the ICC, the LCIA and occasionally SIAC, paired with a DIFC, ADGM or onshore seat. The right choice depends on case size, the need for speed and the counterparty's familiarity with the institution.
DIAC (Dubai)
Local institution with an Arbitration Court, a default DIFC seat and an expedited track for claims up to AED 1 million. Familiar to onshore counterparties and courts, and often cost-competitive for regional disputes.
arbitrateAD (Abu Dhabi)
Modern 2024 rules with a default ADGM seat, a high expedited threshold of AED 9 million, early dismissal and funder disclosure. Well suited to Abu Dhabi projects and government-linked counterparties.
ICC
Widely used for large construction, energy and M&A disputes, with award scrutiny and a global bench of arbitrators. Pairs well with a DIFC or ADGM seat for Dubai-linked contracts.
LCIA and other foreign institutions
Still chosen for English-law finance and corporate contracts, with a DIFC or foreign seat. Since the DIFC-LCIA closed, the LCIA administers only cases under its own rules, not a Dubai branch.
Ad hoc arbitration under the UNCITRAL Rules remains possible, but without an institution there is no appointing body to fall back on, so the seat's court may need to step in. Our guide to DIAC arbitration in Dubai covers the DIAC procedure in more detail.
Costs, funding and timing
The cost of international arbitration in Dubai has three components: institutional administration fees, tribunal fees and the parties' own legal and expert costs. DIAC and arbitrateAD publish fee schedules based on the amount in dispute, and both institutions fix tribunal fees within those scales. Legal and expert costs are usually the largest item, especially where document production and experts are extensive.
Tribunals generally have power to order the losing party to bear the costs of the arbitration, including reasonable legal costs; the DIAC Rules 2022 expressly treat a party's legal representation costs as part of the arbitration costs. That creates real adverse costs exposure, so a budget should include a downside scenario.
- Third-party funding. Funding is increasingly used by claimants in Dubai and Abu Dhabi. The arbitrateAD Rules require disclosure of funders, and the DIFC reform proposals would add a similar duty for DIFC-seated cases. Disclosure lets arbitrators check conflicts and can affect security for costs.
- Security for costs. Respondents facing a claimant with weak finances may apply for security; the DIFC proposals would make this power express for DIFC-seated cases.
- Timing. Expedited cases can produce an award within a few months. A full international case with document production, experts and a multi-day hearing typically takes considerably longer, and set-aside and enforcement add further time.
Early case assessment that tests merits, quantum and recoverability against likely costs is the best protection against an arbitration that wins on paper but loses money.
How an international arbitration in Dubai runs
- Audit the clause. Check institution name, rules, seat, language, number of arbitrators and any tiered steps. Old DIFC-LCIA or ADCCAC references need a transition analysis.
- Preserve the position. Issue hold notices, map assets and decide whether to seek an emergency arbitrator or court interim relief in the DIFC, ADGM or onshore courts before filing.
- Request for arbitration. File with the institution, nominate an arbitrator where applicable and pay the registration fee. Consider whether the expedited track applies.
- Tribunal and first conference. The institution confirms the tribunal. A case management conference fixes the timetable, document production, hearing format and any bifurcation of jurisdiction or liability.
- Written phase. Statements of claim and defence, document production, witness statements and expert reports, usually in two rounds.
- Hearing. An evidentiary hearing in Dubai, Abu Dhabi, elsewhere or online, followed by post-hearing submissions and costs submissions.
- Award and scrutiny. The tribunal drafts the award; DIAC, arbitrateAD and the ICC scrutinise it for form before issue.
- Recognition and enforcement. Ratify the award in the seat's court or recognise it where assets are located, while defending any challenge at the seat.
Documents and evidence
International tribunals in Dubai usually follow a common-law influenced approach to evidence, often taking guidance from the IBA Rules on the Taking of Evidence. That means targeted document production rather than full disclosure, written witness statements and cross-examination.
- The full contractual chain: main agreement, ancillary contracts, guarantees, and every clause that refers disputes to arbitration
- Corporate authority for each party, including for state-linked entities that may need specific approvals
- Contemporaneous correspondence, minutes and messaging, with privilege reviewed before production
- Quantum evidence and early instructions to independent experts
- Translations of Arabic and other non-English documents into the language of the arbitration
- Evidence of funder arrangements, which must be disclosed under the arbitrateAD Rules and increasingly elsewhere
For joint venture and shareholder disputes, see our shareholder disputes page; for construction, see construction arbitration in the UAE.
Risks and common mistakes
Leaving defunct institutions in contracts
Many group templates still refer to the DIFC-LCIA or the Abu Dhabi Commercial Conciliation and Arbitration Centre. Such clauses are not void, but they invite argument about who administers the case and under which rules, sometimes at the jurisdiction stage. A 2024 decision of the Conflict of Jurisdiction Tribunal turned in part on the DIAC decree's treatment of such references. Review templates and amend live contracts by agreement where possible.
Choosing a seat without thinking about challenge
The seat's court is the only forum for setting aside the award. Parties sometimes pick a seat for convenience without considering the court's language, approach to public order or challenge timetable. An award debtor will exploit any uncertainty. Choose a seat whose courts you would be comfortable appearing in for a set-aside application, and state it expressly in the clause.
Unclear clauses that mix seat and venue
Wording such as "arbitration in Dubai under DIAC Rules" leaves open whether the seat is onshore Dubai or the DIFC. Under the DIAC Rules 2022 the DIFC is the default seat only where none has been chosen, and a court may read "in Dubai" as a choice. Spell out "the seat of the arbitration shall be the DIFC" or "onshore Dubai", and separately state that hearings may be held elsewhere.
Overlooking interim relief
An emergency arbitrator can act within days, but its orders bind only the parties. Freezing a bank account or stopping a share transfer usually needs a court. Since 2025 the DIFC Courts have express power to grant interim measures in support of arbitrations seated elsewhere where the relief is to take effect in the DIFC, and onshore courts can order precautionary attachments. Coordinate the routes; see our emergency and interim relief page.
Planning enforcement too late
Winning an award is half the job. If the respondent's assets are in a country with a difficult enforcement record, factor that into seat, security and settlement strategy from the start. Asset tracing, translation and local counsel take time. Our arbitral award enforcement team plans this alongside the arbitration.
Cross-border angle: Bangladesh, India, the UK, Singapore, China and the GCC
The UAE and all of TRW & Co's main network jurisdictions are parties to the New York Convention, so Dubai and Abu Dhabi awards can generally be enforced across the network, subject to each country's procedures.
- Bangladesh. Bangladeshi exporters, contractors and investors frequently face UAE counterparties. Foreign awards are enforced in Bangladesh under the Arbitration Act 2001, and TRW & Co's Dhaka team can manage that stage.
- India. Indian parties are among the most frequent users of Dubai institutions. Enforcement in India runs under the Arbitration and Conciliation Act 1996, and Indian counsel should confirm the treatment of UAE awards early.
- United Kingdom. London remains a common alternative seat for English-law contracts, and English courts support Dubai-seated arbitrations with enforcement of awards and, in some cases, interim relief.
- Singapore. Singapore is a natural neutral seat for Asia-facing contracts; parties weighing Singapore against the DIFC or ADGM should compare court support, cost and the location of assets.
- China. Chinese contractors and lenders active in the UAE often prefer institutional arbitration; translation and service in China require planning.
- Saudi Arabia and the GCC. Awards are enforceable under the Convention, and regional parties often accept a DIAC or arbitrateAD clause as a neutral compromise.
Bringing foreign awards into the UAE
The traffic runs both ways. An award made in London, Singapore or Riyadh against a party with UAE assets is recognised in the onshore court where the assets are, applying the New York Convention with the federal Civil Procedure Law supplying the procedure. The applicant needs the authenticated award, the arbitration agreement and certified Arabic translations, and should expect the debtor to raise public order and procedural objections.
Where assets sit in the DIFC or ADGM, recognition can be sought in those courts instead. Choosing the right gateway, and securing assets with interim relief while recognition is pending, is often the difference between a paper victory and actual recovery.
Bringing a foreign award into the UAE is covered in our guide to enforcing foreign arbitral awards in the UAE.
How TRW & Co helps with international arbitration in Dubai
TRW & Co advises on international arbitration in Dubai and across the UAE as strategist and coordinator. Where representation before UAE onshore courts or the DIFC/ADGM Courts is required, we work alongside locally licensed advocates and registered practitioners.
Clause and seat design
We design arbitration clauses for cross-border contracts, choosing seat, institution and rules to fit the assets, governing law and counterparties.
Template remediation
We audit group templates for references to the DIFC-LCIA, ADCCAC and other outdated bodies and prepare amendment agreements.
Case strategy
We assess merits, quantum and enforceability before filing, and test settlement and mediation options throughout.
Conduct of the arbitration
We prepare pleadings, manage document production and witnesses, and work with counsel and experts through the hearing.
Court support at the seat
We coordinate interim relief and set-aside work in the DIFC Courts, the ADGM Courts and onshore courts with registered practitioners.
Enforcement across the network
We plan and coordinate enforcement in Bangladesh, India, the UK, Singapore and the GCC through TRW & Co's offices and local counsel.
See all of our services on our practices page.
Checklist for decision-makers
- Is the seat stated expressly (onshore, DIFC, ADGM or foreign)?
- Does the clause name a current institution and the correct rules?
- Do the expedited thresholds (AED 1 million at DIAC, AED 9 million at arbitrateAD) suit the likely claim size?
- Do you need court-ordered interim relief in the UAE, and from which court?
- Is third-party funding involved, and does it need to be disclosed?
- Where are the counterparty's assets, and is the enforcement route mapped?
- Are any old DIFC-LCIA or ADCCAC clauses still live in your contracts?
To discuss international arbitration in Dubai or Abu Dhabi, contact TRW & Co at info@trw.co or +971 58 942 1012.
Frequently asked questions
01What happened to the DIFC-LCIA Arbitration Centre?
Dubai Decree No. 34 of 2021, in force from 20 September 2021, abolished the DIFC Arbitration Institute that ran the DIFC-LCIA centre and transferred its functions to DIAC. Existing DIFC-LCIA arbitration agreements remain valid. Cases registered with the DIFC-LCIA on or before 20 March 2022 continued under LCIA administration, while new cases under old clauses generally proceed before DIAC under its 2022 Rules unless the parties agree otherwise.
02What is the default seat under the DIAC Rules 2022?
Where the parties have not agreed a seat, the DIAC Rules 2022 provide that the seat is the DIFC, subject to the Arbitration Court's powers. That means the DIFC Arbitration Law applies and the DIFC Courts supervise. If you want an onshore Dubai seat, say so expressly; equally, if you want the DIFC, state it rather than relying on the default.
03Should we choose DIAC or arbitrateAD?
Both are modern institutions. DIAC is Dubai's sole institution, with a default DIFC seat and an expedited track up to AED 1 million. arbitrateAD, launched on 1 February 2024, defaults to an ADGM seat, offers expedited proceedings up to AED 9 million, early dismissal and mandatory funder disclosure. The choice often follows the location of the project, the counterparty's preferences and the likely claim size.
04Can we use ICC or LCIA rules with a Dubai seat?
Yes. Parties commonly combine ICC or LCIA rules with a DIFC or ADGM seat, or with an onshore seat. Decree No. 34 of 2021 did not affect the DIFC as a seat or the parties' freedom to choose foreign institutional rules. What ended was the local DIFC-LCIA centre. Make sure the clause states the institution, the rules and the seat clearly.
05How are foreign awards enforced in the UAE?
The UAE is a party to the New York Convention, so a foreign award can be recognised on Convention grounds, with the federal Civil Procedure Law supplying the procedure. Recognition is sought in the onshore court where assets are located, or in the DIFC or ADGM Courts where appropriate. Certified Arabic translations, an authenticated award and the arbitration agreement are needed. See our guide on enforcing foreign arbitral awards.
06Is the DIFC Arbitration Law changing?
The DIFC Authority published a consultation in June 2026 on a proposed Arbitration and Mediation Law to replace the 2008 law. Proposals include cutting the time to challenge a DIFC-seated award from three months to 30 days, express summary disposal powers, security for costs and enforcement of mediated settlements. Until enacted, the 2008 law applies, so check the current position before relying on any deadline.
07Can a Dubai court grant interim relief for an arbitration seated abroad?
It can, depending on the court and the relief. Dubai Law No. 2 of 2025 confirms the DIFC Courts can grant interim measures in support of proceedings outside the DIFC, including arbitrations, where the relief is sought within the DIFC. Onshore courts can grant precautionary attachments in support of arbitration. Tribunals and emergency arbitrators can also order interim measures between the parties.
Sources and official materials
- Dubai International Arbitration Centre (DIAC) — DIAC Arbitration Rules 2022 and administration
- DIAC rules — Current DIAC arbitration and mediation rules
- Abu Dhabi International Arbitration Centre (arbitrateAD) — arbitrateAD Rules 2024
- ADGM Courts — Supervisory court for ADGM-seated arbitrations
- DIFC Courts — Supervisory court for DIFC-seated arbitrations
- New York Convention — Text and contracting states
General information only, current as at 27 October 2026. It is not legal advice and does not create a lawyer–client relationship. UAE law differs between the onshore jurisdiction, the DIFC, ADGM and the free zones, and changes frequently; check current official sources and take advice on the facts of your matter.
