TRW & Co · Disputes & Arbitration
Enforcement of Foreign Judgments in the UAE
Enforcement of foreign judgments in the UAE lets a creditor who has won in London, Mumbai, Riyadh or Singapore reach a debtor's assets in Dubai or Abu Dhabi. The process is now a summary petition to the execution judge, but reciprocity and the UAE courts' own jurisdiction often decide whether a judgment is enforced or refused.
Key pointThe decisive question is often not reciprocity but jurisdiction: if UAE courts also had jurisdiction over the dispute, Dubai's highest court has in 2025 refused enforcement even of an English judgment, so creditors should plan a fallback route from the start.
At a glance
Summary petition procedure
Since 2 January 2023, Article 222 of the Civil Procedure Law lets creditors petition the execution judge, who should decide within five days, instead of filing a full lawsuit.
Five statutory conditions
Enforcement requires no exclusive UAE jurisdiction, a competent foreign court, proper summons, a final judgment, and no conflict with UAE judgments or public order.
Treaties take priority
Under Article 225, treaties such as the Riyadh Convention, GCC arrangements and bilateral treaties with India and China prevail over the domestic conditions.
English judgments and reciprocity
A Ministry of Justice letter of 13 September 2022 told the Dubai Courts reciprocity with England is satisfied, though jurisdiction objections still defeat some applications.
No ADGM conduit
Since 2020, ADGM cannot be used to enforce non-ADGM judgments elsewhere in the UAE; ADGM registration helps mainly where assets are in ADGM.
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What enforcement of foreign judgments in the UAE covers
Enforcement of foreign judgments in the UAE is the process of turning a court judgment obtained abroad, in London, Mumbai, Singapore, Riyadh or Dhaka, into an order that the UAE execution courts will act on. A foreign judgment has no automatic effect in the UAE. It must first receive an enforcement order, after which the creditor can attach bank accounts, real estate, shares and other assets.
The question usually comes up when a creditor wins abroad and discovers the debtor has moved money, property or a business to Dubai or Abu Dhabi. It also arises in family wealth disputes, in fraud and asset-recovery cases, and when a foreign bank pursues a borrower or guarantor who has relocated. Debtors face the mirror image: they need to know whether a foreign judgment can actually be executed here and on what grounds it can be resisted.
The law has moved significantly since 2018. Procedure is now faster and summary, and UAE courts have enforced judgments from countries with no enforcement treaty. But jurisdiction remains a live battleground, and decisions of the Dubai courts in 2024 and 2025 show that the outcome can turn on whether the UAE courts themselves had jurisdiction over the original dispute.
The legal framework and the conditions for enforcement
The main source is Chapter IV of the Civil Procedure Law, Federal Decree-Law No. 42 of 2022, in force since 2 January 2023. Article 222 governs foreign judgments and orders, Article 223 foreign arbitral awards, Article 224 foreign official documents, and Article 225 confirms that treaties prevail. These provisions carried forward Article 85 of the Executive Regulations of the old Civil Procedure Law, as amended by Cabinet Resolution No. 75 of 2021.
Under Article 222, the execution judge orders enforcement on the same conditions that the foreign state applies to UAE judgments (reciprocity), provided that:
- UAE courts do not have exclusive jurisdiction over the dispute, and the foreign court had jurisdiction under its own international jurisdiction rules;
- the judgment was issued by a court competent under the law of the country where it was given and was properly authenticated;
- the parties were summoned and properly represented;
- the judgment is final (res judicata) under the law of the issuing court, shown by a certificate or by the judgment itself; and
- the judgment does not conflict with an earlier UAE judgment and is not contrary to public morals or public order in the UAE.
The application is a petition to the execution judge, who should decide within five days. The judge does not review the merits; the inquiry is limited to the statutory conditions. The decision can be appealed under the ordinary rules. This summary process replaced the old requirement to bring a full lawsuit, which used to add a first-instance trial, an appeal and a cassation stage before any enforcement was possible.
Procedure continues to evolve. A federal decree-law amending the Civil Procedures Code was announced in December 2025, including changes to appeal briefs and allowing cassation appeals against certain appellate decisions. Check the consolidated text before filing, because the changes affect the timetable for contested enforcement.
Reciprocity and treaties with key jurisdictions
Where a treaty applies, it governs. The UAE is party to the Riyadh Arab Agreement for Judicial Cooperation and the GCC arrangements for enforcing judgments, and has bilateral judicial cooperation treaties with several states including India, China and France. Where no treaty applies, the creditor must show reciprocity: that the foreign court would enforce a comparable UAE judgment on conditions no more burdensome than those in the UAE.
Reciprocity has become easier to establish. On 13 September 2022 the UAE Ministry of Justice wrote to the Dubai Courts stating that reciprocity with England should be treated as satisfied, relying on the English Court of Appeal's 2021 decision in Lenkor Energy Trading DMCC v Puri, which enforced a Dubai judgment. In June 2024 the Dubai Court of Cassation upheld enforcement of a Canadian (Ontario) judgment in Case No. 392 of 2024.
| Country | Basis | Practical position |
|---|---|---|
| Saudi Arabia, GCC states | GCC arrangements and the Riyadh Convention | Treaty route; courts in Abu Dhabi have enforced Saudi and Bahraini judgments |
| India | Bilateral judicial cooperation agreement | Treaty route; India also notified the UAE as a reciprocating territory in January 2020 |
| China | Bilateral treaty on judicial assistance in civil and commercial matters | Treaty route; check the treaty's own conditions and documents |
| United Kingdom | No enforcement treaty; reciprocity | Ministry of Justice letter of 2022 supports reciprocity, but jurisdiction challenges remain significant |
| Singapore | No enforcement treaty; reciprocity | UAE execution courts have reportedly enforced Singapore judgments; evidence of reciprocity needed |
| Bangladesh | Reciprocity, unless a treaty is confirmed | Expect to prove reciprocity with expert evidence on Bangladeshi law |
The jurisdiction question that decides many cases
In practice, the most contested condition in the enforcement of foreign judgments in the UAE is that UAE courts must not have exclusive jurisdiction. UAE procedural law gives the UAE courts jurisdiction over defendants domiciled or resident in the UAE and over disputes connected with UAE assets or obligations performed in the UAE. The question is whether that jurisdiction is exclusive, so as to block a foreign judgment, or merely concurrent.
The Dubai courts have not been consistent. In Appeal No. 339 of 2023, decided on 15 August 2024, the Dubai Court of Cassation allowed enforcement unless UAE jurisdiction was exclusive. In Appeal No. 156 of 2025, decided on 24 April 2025, it refused to enforce an English order relating to a Dubai penthouse, treating the existence of UAE jurisdiction as enough to deny the foreign court's jurisdiction, and holding that reciprocity could not overcome that obstacle.
For creditors, the practical lesson is to anticipate the argument. Where the debtor is UAE-domiciled or the dispute concerns UAE real estate, the jurisdiction ground will be raised. Evidence that the debtor submitted to the foreign court, appeared and defended, or agreed to the foreign forum can help, but outcomes are not guaranteed, and an alternative route such as fresh UAE proceedings using the foreign judgment as evidence should be planned in parallel.
Debtors should look at the same facts from the other side. A debtor that was resident in the UAE when the foreign proceedings began, that objected to the foreign court's jurisdiction from the outset and that never agreed to the foreign forum has a credible objection. A debtor that took part in the foreign trial on the merits without reserving its position will find the argument harder to run, even though UAE law does not treat participation as conclusive.
In the UAE, the question is rarely whether the foreign court was right; it is whether the foreign court should have been deciding the case at all.
DIFC and ADGM routes for foreign judgments
The DIFC Courts
The DIFC Courts have long recognised foreign money judgments through a common law action, and the DIFC Court of Appeal confirmed in 2015 that a creditor need not show assets in the DIFC. Dubai Law No. 2 of 2025 replaced the 2004 laws governing the DIFC Courts. Recognition through the DIFC can be broad, but the DIFC execution judge's compulsory powers are limited to debtors connected with the DIFC, so execution against onshore assets passes to the Dubai Courts.
A Dubai tribunal created by Decree No. 29 of 2024, which replaced the earlier Joint Judicial Committee, resolves conflicts between the DIFC and onshore courts and can stay DIFC proceedings where onshore proceedings compete. See our pages on DIFC Courts proceedings and the article on DIFC Courts jurisdiction and enforcement.
The ADGM Courts
In ADGM, foreign judgments are registered under the Courts, Civil Evidence, Judgments, Enforcement and Judicial Appointments Regulations 2015 and the Court Procedure Rules 2016. The foreign court must be a recognised court, usually through a treaty or memorandum plus a direction from the Chief Justice. ADGM has enforcement guidance and memoranda with the Commercial Court of England and Wales, the Supreme Court of Singapore, the High Court of Hong Kong and Australian courts, among others.
Since Abu Dhabi Law No. 12 of 2020 amended Article 13 of the ADGM Founding Law, ADGM cannot be used as a conduit to enforce non-ADGM judgments elsewhere. The ADGM route therefore plays a limited part in the enforcement of foreign judgments in the UAE generally, and is useful mainly where the debtor or its assets are in ADGM. Our page on ADGM Courts proceedings explains the court's structure and procedure.
The enforcement process step by step
- Check finality and service. Confirm that the judgment is final under the issuing country's law, obtain a certificate of finality, and gather proof that the debtor was properly served and represented.
- Map assets and choose the forum. Identify where the debtor's assets are by emirate and free zone. The asset map decides whether to file onshore, in the DIFC or in ADGM.
- Build the reciprocity case. Identify any applicable treaty. If none applies, obtain expert evidence on how the foreign country treats UAE judgments, including reported cases.
- Authenticate and translate. Have the judgment and supporting documents authenticated for use in the UAE and translated into Arabic by a certified legal translator.
- File the petition. File with the execution judge of the competent court, setting out the jurisdictional basis and each Article 222 condition. Consider precautionary attachment at the same time.
- Respond to appeals. Expect the debtor to appeal on jurisdiction, service or public order. Keep the response focused on the statutory conditions, not the merits.
- Execute. Once the enforcement order is in place, open the execution file and apply for attachment of accounts, property and shares, disclosure and, where suitable, a travel ban.
Documents and evidence to prepare
Missing documents are the single most avoidable cause of delay in the enforcement of foreign judgments in the UAE. The execution judge decides on the papers, quickly, so the file must be complete when it is lodged:
- The judgment, sealed or certified by the issuing court, with all pages and any consequential orders on interest and costs.
- A certificate or other evidence that the judgment is final and not subject to ordinary appeal under the issuing country's law.
- Evidence of service of the originating process and of the defendant's participation or default.
- Authentication of the documents for use in the UAE through the applicable consular or apostille route.
- Certified Arabic translations of the judgment and key supporting documents.
- Treaty text or expert evidence on reciprocity, with examples of the foreign courts enforcing UAE judgments.
- An authenticated power of attorney and an asset schedule supporting any attachment application.
Ask the foreign court for the documents you will need in the UAE at the same time as you seek judgment. A certificate of finality, sealed copies and proof of service are much easier to obtain from the court's registry immediately than months later, when files may be archived and the debtor has had time to restructure its assets.
Risks and common mistakes
Assuming a foreign judgment works like a local one
A foreign judgment, however strong, has no direct effect in the UAE. Banks will not freeze accounts and land departments will not register attachments on the strength of an English or Indian judgment alone. Creditors sometimes lose months writing demand letters to UAE banks before starting the enforcement petition. Start the UAE process as soon as the foreign judgment is final, and use precautionary attachment if there is a risk of dissipation.
Ignoring the jurisdiction ground
Many enforcement applications fail because the debtor shows that UAE courts had jurisdiction over the dispute. Where the debtor was UAE-domiciled when proceedings began, or the claim concerned UAE property, the risk is high. Address the point directly in the petition, using evidence of submission or agreement to the foreign forum, and prepare a fallback plan of fresh UAE proceedings if enforcement is refused.
Weak proof of reciprocity
Without a treaty, the creditor carries the burden of proving reciprocity. A bare statement that the foreign country enforces foreign judgments is not enough. Provide expert evidence on the relevant statute or common law rule, examples of enforced UAE judgments where they exist, and any official correspondence such as the Ministry of Justice letter on English judgments. Weak evidence invites a refusal that is hard to reverse on appeal.
Defective service in the original proceedings
UAE courts check that the defendant was properly summoned and represented. Substituted or electronic service permitted abroad may be questioned if the debtor says it never received notice. Keep complete service records from the foreign proceedings and, where possible, serve through methods the UAE courts recognise, especially where you expect to enforce in the UAE from the outset.
Non-money and interim orders
Freezing injunctions, specific performance orders and interim relief are more difficult to enforce than final money judgments. In ADGM, only money judgments are realistically enforceable by registration. Onshore, a non-final order fails the finality condition. Where interim protection is needed, seek UAE precautionary measures directly rather than trying to enforce the foreign order.
Cross-border angle: enforcing in both directions
For creditors coming into the UAE, the strongest positions are judgments from GCC states, India and China, where treaties apply, followed by England, where official support for reciprocity exists but jurisdiction challenges remain. Singaporean and Bangladeshi judgments depend on proof of reciprocity. Where the debtor's assets are spread across the region, enforcement of foreign judgments in the UAE should be coordinated with steps in the other countries so the debtor cannot simply move assets to the least-protected jurisdiction.
Outbound, UAE judgments can be enforced in India under section 44A of the Code of Civil Procedure 1908, because India notified the UAE as a reciprocating territory in January 2020. In England and Singapore, a UAE judgment is generally enforced through a common law action on the judgment debt. Saudi and other GCC enforcement follows the treaty route.
Where the dispute is still at the contract stage, the choice between court jurisdiction and arbitration matters. An arbitral award usually travels more easily than a judgment because of the New York Convention. Our pages on arbitral award enforcement and cross-border contracting explain how to build enforceability into the contract.
How TRW & Co helps
We advise creditors and debtors on enforcement of foreign judgments in the UAE, from pre-judgment planning in the foreign court to execution in the UAE. Where representation before UAE onshore courts or the DIFC/ADGM Courts is required, we work alongside locally licensed advocates and registered practitioners. Our related commercial litigation and debt recovery teams often work on the same matters, and the full range of our work is on the our practices page.
Enforceability assessment
We assess whether a foreign judgment meets the Article 222 conditions, with particular attention to jurisdiction, service and finality, before costs are incurred.
Reciprocity evidence
We identify applicable treaties or assemble expert evidence on reciprocity, drawing on TRW & Co's offices and contacts in Bangladesh, the UK, Singapore and elsewhere.
Forum and asset strategy
We map assets across the emirates and free zones and recommend whether onshore, DIFC or ADGM filings give the best route to recovery.
Petition preparation
We prepare the petition, evidence, translations and authentication bundle for filing by locally licensed advocates, and plan precautionary attachment.
Resisting enforcement
For debtors, we analyse jurisdiction, service, public order and conflicting UAE judgments to identify proper grounds of objection.
Parallel proceedings
Where enforcement is refused or uncertain, we plan fresh UAE proceedings or arbitration, using the foreign judgment and evidence to accelerate the claim.
Checklist for decision-makers
Before committing to the enforcement of foreign judgments in the UAE, work through these questions:
- Is the judgment final, and do you hold a certificate of finality and proof of service?
- Does a treaty apply, or will reciprocity need to be proved with expert evidence?
- Could the debtor argue that UAE courts had jurisdiction over the dispute?
- Where exactly are the assets: onshore, in a free zone, in the DIFC or in ADGM?
- Is there a risk of dissipation that justifies a precautionary attachment application?
- Are the documents authenticated and translated into Arabic?
- What is the fallback if enforcement is refused: fresh proceedings, arbitration or settlement?
- Have you spoken to TRW & Co about coordinating enforcement across countries?
Frequently asked questions
01Can an English judgment be enforced in Dubai?
Yes, in principle. There is no UAE–UK enforcement treaty, but the Ministry of Justice told the Dubai Courts in September 2022 that reciprocity with England should be treated as satisfied, following the English Court of Appeal's decision in Lenkor v Puri. However, the Dubai Court of Cassation refused enforcement of an English order in April 2025 because UAE courts had jurisdiction over the dispute. Each case therefore turns on its facts, particularly the debtor's domicile and the subject matter.
02How long does enforcement of foreign judgments in the UAE take?
The first stage is quick: the execution judge is expected to decide a petition within five days. The debtor can appeal, and contested cases may reach the Court of Cassation, which adds months. Asset realisation then takes further time, especially for real estate. A well-prepared, uncontested application can produce an enforceable order within weeks, while a fully contested one can take considerably longer.
03Does the UAE court re-examine the merits of the foreign judgment?
No. The execution judge checks the conditions in Article 222: jurisdiction, competence of the foreign court, proper summons and representation, finality and compatibility with UAE judgments and public order. It does not retry the facts or reconsider the foreign court's legal reasoning. Debtors sometimes present merits arguments as public order objections, and creditors should keep the court focused on the limited statutory grounds.
04Can an Indian court judgment be enforced in the UAE?
Yes. The UAE and India have a bilateral judicial cooperation agreement covering civil and commercial matters, and Indian judgments are enforced in the UAE on that basis subject to the statutory conditions. In the other direction, India notified the UAE as a reciprocating territory under section 44A of the Code of Civil Procedure in January 2020, so judgments of the listed UAE courts can be executed in India.
05What if the foreign judgment is an injunction rather than a money award?
Non-money and interim orders are harder to enforce. Onshore, an interim order fails the finality requirement, and in ADGM only money judgments are realistically enforceable by registration. Where a freezing order or other interim protection is needed in the UAE, it is usually better to apply directly to the UAE courts for precautionary measures, supported by evidence from the foreign proceedings.
06Is it better to enforce through the DIFC Courts?
It depends on the debtor. The DIFC Courts recognise foreign money judgments without requiring DIFC assets, and proceed in English under common law procedure. But their compulsory execution powers are limited to debtors connected with the DIFC, so execution against onshore assets passes to the Dubai Courts, and onshore challenges can lead to a stay. Where the debtor and its assets are entirely onshore, a direct onshore petition is often simpler.
07What happens if the UAE court refuses enforcement?
The creditor can usually bring fresh proceedings in the UAE on the underlying claim, using the foreign judgment and the evidence from the foreign trial to support it. Limitation periods must be checked carefully, because time may have run while the foreign case was pending. Where the contract contains an arbitration clause, arbitration may also be available. Planning this fallback early avoids losing the claim altogether.
Sources and official materials
- Federal Decree-Law No. 42 of 2022 (Civil Procedure Law) — Articles 222–225 on foreign judgments, awards and treaties
- UAE Ministry of Justice — International judicial cooperation and treaties
- DIFC Courts — Recognition and enforcement in the DIFC
- Mohammed bin Rashid issues law on DIFC Courts (Dubai Law No. 2 of 2025) — New DIFC Courts law and jurisdiction
- ADGM Courts memoranda and enforcement guidance — Reciprocal enforcement arrangements with UAE and foreign courts
- ADGM Courts guide to amendments to Article 13 of the Founding Law — Abu Dhabi Law No. 12 of 2020 and the end of conduit enforcement
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.
