How to enforce a foreign arbitral award in the UAE
MAY 20 2026
A foreign arbitral award is only as valuable as the assets you can recover against it.
Securing a decision in London, Paris, or Geneva is often the first phase of a dispute. Getting paid is another matter entirely. In the UAE, the gap between a recognised award and actual recovery turns on a set of practical decisions that most businesses address too late.
Where enforcement gets complicated
The UAE is a signatory to the New York Convention. In practice, that is the starting point, not the answer.
UAE courts will refuse enforcement on limited grounds, but those grounds are live. Public policy is the most frequently raised – particularly in disputes involving interest, contractual penalties, or matters that engage UAE regulatory frameworks. Procedural irregularities in the arbitration itself and questions about how the tribunal was constituted each provide additional resistance points. The time to address these is during the arbitration, not after the award is issued.
The decision most businesses get wrong
The UAE operates a dual legal system. Enforcement through the onshore UAE courts and enforcement through the offshore common law jurisdictions of the DIFC or ADGM are fundamentally different exercises. Which route applies depends on where the debtor’s assets sit and how their corporate structure is organised.
Choosing the wrong jurisdiction at the outset creates delay, increases cost, and gives the debtor time to act. A creditor who has not mapped this before the first filing is already behind.
This is the point where international arbitration strategy and local UAE litigation capability need to work together. Most international firms have one. ADG Legal has both.
What this means at the contracting stage
The seat of arbitration, the governing law, and the arbitration clause itself each affect how enforceable an award will ultimately be in the UAE. Businesses that think about this before signing a contract are in a materially different position from those that consider it only once a dispute has emerged.
ADG Legal at London International Disputes Week 2026
The issues this article addresses are the issues ADG Legal’s disputes team handles in practice – enforcement applications, jurisdictional strategy, and the coordination of proceedings across the UAE’s onshore and offshore courts.
Three members of that team will be at LIDW in London from 1 to 5 June.
Mohammed Al Dahbashi, Managing Partner, leads the firm’s litigation practice before the Dubai courts. His practice covers complex commercial disputes and enforcement proceedings in the onshore UAE, where rights of audience and local procedural knowledge determine outcomes.
Jonathan Rodger, Counsel, advises on international disputes and arbitration, working with multinational businesses and coordinating with foreign counsel on claims that run across multiple legal systems.
David McCoy, Partner and Head of ADG Legal’s Abu Dhabi office, advises on cross-border litigation and asset recovery, working with clients on the jurisdictional questions that determine whether an enforcement strategy succeeds or stalls.