Recognition and enforcement of foreign judgments in the UAE in 2026: article 222, the DIFC conduit and the ADGM double lock

A foreign judgment is enforced in the UAE under article 222 of the Civil Procedure Code — by petition to the execution judge, who issues an order within five working days and verifies six conditions without reopening the merits. Two zone routes run alongside it: the DIFC Courts, historically used as a conduit jurisdiction, and the ADGM Courts, which are expressly barred from being used that way. The route you choose determines not how fast you recover, but whether you reach the assets at all.

Alert: the statutory basis of the conduit has been replaced in its entirety. Dubai Law No. 2 of 2025 repealed both Dubai Law No. 12 of 2004 and DIFC Law No. 10 of 2004 — the two provisions on which DNB Bank v Gulf Eyadah was built. And the Conflict of Jurisdiction Tribunal has separated recognition from enforcement: in Application No. 1 of 2026 (20 April 2026) for arbitral awards, and in Application No. 4 of 2026 (6 July 2026) for court judgments. The DIFC Courts may recognise a foreign judgment, but may not enforce it where no “sufficient enforcement connection” with the DIFC exists.

Parameter	Value
Principal statute	Federal Decree-Law No. 42 of 2022 on the Civil Procedure Code
Date of issue	3 October 2022
Official Gazette	No. 737 of 10 October 2022
Date in force	2 January 2023
A­mendme­nts	one — the decree-law of 1 October 2025 (articles 32, 164, 175, 176)
Forei­gn-ju­dgment provisions	articles 222–225, Book Three, Chapter Four
Forum	the execution judge, on petition, not by ordinary action
Time to issue the order	five working days from filing
Appeal	direct appeal under the rules for appealing judgments
Number of conditions	six, verified by the execution judge
Review of the merits	not permitted
Reciprocity requirement	in the chapeau of article 222(1), not as a separate condition
Hague Choice of Court Convention 2005	UAE not a party
Hague Judgments Convention 2019	UAE not a party
Apostille Convention 1961	UAE not a party — consular legalisation required
DIFC: operative statute	Dubai Law No. 2 of 2025, issued 3 March 2025, in force 15 March 2025
DIFC: the conduit	preserved by article 32, but the statute contains no provision on recognising foreign courtjudgments
ADGM: operative statute	ADGM Courts Regulations 2015, Chapter 10 (sections 167–180)
ADGM: the conduit	expressly barred — article 13, para. 14 of Law No. 4/2013 and section 172(2)(c) of the Regulations; the bar operates by refusing the executory formula
ADGM: recognised foreign courts	five, by orders of the Chief Justice under section 171
ADGM: window to register	six years from the date of the judgment (section 173(1))
Abu Dhabi: juri­sdi­ctional conflicts	the Court of Cassation, article 7(2) of Law No. 6 of 2024; no standing tribunal
Dubai: juri­sdi­ctional conflicts	the Conflict of Jurisdiction Tribunal, Decree No. 29 of 2024

Three levels of regulation that must not be conflated

Recognition of foreign judgments in the UAE is regulated on three independent levels — federal, emirate and zone — and a rule at one level does not displace a rule at another. Most errors in this field come from carrying a rule across a level boundary.

The federal level

Federal Decree-Law No. 42 of 2022 on the Civil Procedure Code applies across the UAE and contains articles 222–225, the only general regime for recognising foreign judgments in the country. It came into force on 2 January 2023 and replaced Federal Law No. 11 of 1992.

The structural point about the 2022 reform is that the recognition rules moved out of subordinate legislation and into the statute itself. Before 2023 they sat in articles 85–88 of Cabinet Decision No. 57 of 2018, the Implementing Regulation of Law No. 11/1992. Cabinet Decision No. 57/2018 served a statute that no longer exists, and its articles 85–88 have been superseded by articles 222–225 of the Code.

The emirate level

Each emirate may run its own judicial system, and Dubai and Abu Dhabi both do. The Dubai Courts and the Abu Dhabi Judicial Department apply the federal Civil Procedure Code, but they are constituted under emirate legislation — Dubai Law No. 13 of 2016 and Abu Dhabi Law No. 6 of 2024 respectively.

It is at the emirate level that conflicts of jurisdiction between a zone court and an onshore court are resolved — and the two emirates resolve them differently. Dubai created a standing body; Abu Dhabi left the question with its Court of Cassation.

The zone level

The financial free zones — the DIFC and ADGM — are carved out of federal civil and commercial legislation by article 3(2) of Federal Law No. 8 of 2004 concerning Financial Free Zones. The wording is precise: the zones are subject to all federal laws “with the exception of Federal civil and commercial laws”.

The practical consequence: article 222 of the federal Civil Procedure Code does not apply inside the DIFC or ADGM. Each zone has its own recognition regime — the DIFC’s in Dubai Law No. 2 of 2025, ADGM’s in Chapter 10 of the Courts Regulations 2015. These are two different codes, with different conditions, different time limits and different outcomes.

The mirror image of the same rule is that criminal law applies in the zones in full, because the article 3(2) carve-out reaches only civil and commercial laws. Why the DIFC is badly served by the “free zone” mental model is set out separately in the guide to the DIFC as a legal ecosystem in its own right.

The normative base: what is in force and what has been repealed

The normative base consists of one federal statute, two zone codes and a network of treaties — and both zone codes have been replaced in the last two years. What follows is the full list of instruments in force, with the date of issue and the date of entry into force given separately, because in the UAE they routinely differ.

Instrument	Status	Dates	What it governs
Federal Law No. 8 of 2004 on Financial Free Zones	in force	issued 14 March 2004	article 3(2): the carve-out of the zones from federal civil and commercial law
Federal Decree-Law No. 42 of 2022 (Civil Procedure Code)	in force	issued 3 October 2022, in force 2 January 2023	articles 222–225: recognition of foreign judgments, arbitral awards and notarised instruments
The decree-law of 1 October 2025	in force	takes effect 1 January 2026	the only amendment to the Code: articles 32, 164, 175, 176 — it does not touch articles 222–225
Cabinet Decision No. 57 of 2018	superseded as to articles 85–88	issued 9 December 2018	Implementing Regulation of the repealed Law No. 11/1992
Federal Law No. 11 of 1992	repealed	—	repealed by article 2 of Decree-Law No. 42/2022
Federal Decree No. 15 of 2013	in force	issued 11 February 2013	establishment of ADGM as a financial free zone
Abu Dhabi Law No. 4 of 2013	in force	issued 19 February 2013	the ADGM Founding Law; article 13 — jurisdiction and enforcement
Abu Dhabi Law No. 12 of 2020	in force	issued 23 April 2020, in force on publication	amended article 13: opt-in with no ADGM connection and the conduit bar
ADGM Courts Regulations 2015	in force	enacted 17 December 2015, consolidated 17 October 2025	Chapter 10 (sections 167–180): recognition and enforcement
Abu Dhabi Law No. 6 of 2024	in force	issued 12 June 2024, in force one month after publication	the Abu Dhabi Judicial Department; articles 7(2) and 9
Dubai Law No. 12 of 2004	repealed	—	repealed by article 43(A) of Law No. 2/2025
DIFC Law No. 10 of 2004	repealed	—	repealed by article 43(A) of Law No. 2/2025
Dubai Law No. 2 of 2025	in force	issued 3 March 2025, in force 15 March 2025	the DIFC Courts: jurisdiction (art. 14), interim relief (art. 15), enforcement (arts. 30–33)
Dubai Decree No. 19 of 2016	su­perse­ded	—	superseded by article 13 of Decree No. 29/2024
Dubai Decree No. 29 of 2024	in force	issued 3 April 2024	the Conflict of Jurisdiction Tribunal

The three repeals most often missed

First: Dubai Law No. 12 of 2004 has been repealed. Its article 7 — the provision on which the entire conduit mechanism was built — is no longer law. It cannot be cited in 2026 as a live rule.

Second: DIFC Law No. 10 of 2004 has been repealed. Its article 24, which expressly gave the DIFC Court of First Instance jurisdiction to “ratify any judgment, order or award of any recognised foreign court”, went with it, and Law No. 2/2025 contains no direct successor.

Third: Federal Law No. 11 of 1992 and the Cabinet Decision No. 57 of 2018 that served it. Any material citing “article 85 of the Implementing Regulation” is describing the regime that applied before 2 January 2023.

Article 222: the six conditions the execution judge verifies

Article 222 of the Civil Procedure Code contains a closed list of six conditions, all of them verified formally: the execution judge may not reopen the merits. What follows is the text as published in the official English translation on the UAE Legislation portal, with the divergence from the Arabic original flagged and analysed in the next section.

Clause 1: the conditions-parity rule

“An order may be made for the enforcement in the State of judgments and orders made in a foreign country on the same conditions laid down in the law of that country for the execution of judgments and orders issued in the State.”

This is the reciprocity requirement, and it sits in the chapeau rather than among the six conditions. It is logically prior to them: first the court asks whether the foreign state would enforce a UAE judgment on comparable terms, and only then works through clause 2.

Clause 2: procedure and the six conditions

“An order for execution shall be applied for by means of a petition submitted by the concerned party including the data specified in Article [44] of this Code to the Execution Judge. The Judge shall issue their order within (5) five working days from the date of its submission, and the order shall be subject to appeal by direct appeal in accordance with the rules and procedures prescribed for appealing judgments.”

The conditions then follow:

•          (a) the Courts of the State have no jurisdiction to try the dispute in which the order or judgment was made, and the foreign Courts which issued it have jurisdiction thereover in accordance with the rules governing international judicial jurisdiction laid down in their law;

•          (b) the judgment or order was issued by a Court having jurisdiction in accordance with the law of the country in which it was issued and duly endorsed;

•          (c) the parties to the action in which the foreign judgment was issued were summoned to attend, and were duly represented;

•          (d) the judgment or order has acquired the force of res judicata in accordance with the law of the Court that issued it, provided that the applicant submits a certificate that the judgment has acquired the force of a final order, or the same was stipulated in the judgment itself;

•          (e) it does not conflict with a judgment or order already made by a Court in the State, and contains nothing that conflicts with morals or public order in the State.

Formally there are five lettered conditions, but limb (a) carries two independent tests — the absence of UAE jurisdiction and the presence of foreign jurisdiction — so in practice there are six.

Clause 3: the power to call for documents

“The Execution Judge shall have the right to collect the documents supporting the request before issuing their decision.” This is the only element of discretion in the article, and in practice it is what determines the real timetable: a request for further documents pushes the decision well past the five-day mark, although the Code attaches no express suspension of the period.

Articles 223 to 225

Article 223 extends the article 222 regime to foreign arbitral awards, provided the subject matter is arbitrable under UAE law and the award is enforceable in the country where it was made. In practice this route has been displaced by the New York Convention, to which the UAE is a party.

Article 224 extends the same regime to notarised documents and memoranda of composition certified by foreign courts.

Article 225 subordinates the whole chapter to treaties: “The rules laid down in the Articles of this Chapter shall apply without prejudice to the provisions of conventions and agreements between the State and other countries regarding the execution of foreign judgments, orders and instruments.” A treaty always prevails over article 222.

The defect in the official English of article 222(2)(a), and why it changes outcomes

The official English translation of article 222(2)(a) on the UAE Legislation portal drops the word “exclusively”, which is present in the Arabic original, and the condition consequently reads more strictly than it is. This is not a point of philology: it decides whether a judgment is enforced in a dispute over which the UAE courts also had jurisdiction.

What the Arabic says

The Arabic original of condition (a) reads: “أن محاكم الدولة غير مختصة حصريًّا بالمنازعة التي صدر فيها الحكم أو الأمر” — “that the Courts of the State are not exclusively competent over the dispute in which the judgment or order was issued”. The word حصريًّا, “exclusively”, is in the text.

The official English on the same portal reads: “The Courts of the State have no jurisdiction to try the dispute.” The word “exclusively” is absent.

Why the difference is decisive

On the Arabic, the condition blocks enforcement only where the UAE courts have exclusive jurisdiction; concurrent jurisdiction is no bar. On the English, the condition blocks enforcement whenever the UAE courts had any jurisdiction at all — and under articles 19 to 23 of the same Code, UAE jurisdiction arises, among other things, wherever the defendant is domiciled in the UAE.

The divergence reaches almost every case: nearly every solvent debtor worth pursuing is in the UAE, which means the UAE courts are competent over that debtor. Read literally, the English text would close off enforcement in most commercially significant cases.

Which text governs

The UAE Legislation portal settles the question itself: where the versions conflict, the Arabic prevails. The notice appears on the page of every instrument. The English version is supplied for convenience and is not the authentic text.

The practical conclusion is that condition (a) requires the absence of exclusive UAE jurisdiction, not the absence of any UAE jurisdiction. Material quoting the English translation as if it were the rule is reproducing a stricter test than the one in force.

This is not an isolated anomaly but a known problem across the corpus. The DIFC Court of Appeal in Trafigura(paragraph 135) ran into divergent English translations of Dubai Law No. 2 of 2025 and had to say so: “In the opinion of this Court nothing turns on the different English translations. The controlling words of Article (15)4 are ‘suitable precautionary measures within the DIFC’.” The court resolved it by going to the text of the law rather than to a translation.

How the courts resolved it

The Dubai Court of Cassation in Appeal No. 339/2023 confirmed the Arabic reading and held expressly that concurrent jurisdiction does not by itself prevent an enforcement order. That decision is analysed separately below; the point here is that the case law follows the Arabic text, not the English translation.

The earlier line was stricter. Dubai Court of Cassation Appeal No. 114/1993, Federal Supreme Court Appeals Nos. 311 and 325 of 1994, and Dubai Court of Cassation Appeal No. 240/2017 all proceeded on the footing that any connection between the dispute and the UAE defeated enforcement. That line can no longer be cited as current practice.

Procedure and timing: why this is a petition, not an action

An application to enforce a foreign judgment is made by petition to the execution judge, not by a statement of claim in the Court of First Instance — and that is the central procedural reform of 2018, carried into the 2022 Code. Before it, enforcement required a full action under articles 235 to 238 of Law No. 11 of 1992, working its way up through every instance.

Who files, and where

The petition is filed by the concerned party with the execution judge and must contain the data specified in article 44 of the Code. Article 44 sets the general requisites of a procedural document: the names of the parties, their addresses, the relief sought and the grounds for it.

The forum is the execution judge of the emirate where enforcement is intended. This is neither an appellate nor a cassation court; it is the judge who runs execution proceedings.

The time limit

The execution judge issues the order within five working days of the petition being filed. The predecessor provision — article 85(2) of Cabinet Decision No. 57 of 2018 — allowed three days; the 2022 Code extended it to five working days. It is one of the few substantive changes made when the rules moved from regulation into statute.

Five working days is not five calendar days: in an ordinary working week that is seven calendar days, and more where public holidays intervene.

The real timetable is set by article 222(3). The execution judge’s power to call for supporting documents before deciding means, in practice, that a file with an incomplete document set runs well past five days.

Appeal

The order is challenged by direct appeal, under the rules and procedures prescribed for appealing judgments. The phrase “direct appeal” matters: the applicant does not first make representations to the same judge but goes straight to the appellate court.

Filing an appeal does not of itself stay enforcement automatically — a stay requires a separate order.

What the procedure does not include

There is no review of the merits. The list in article 222(2) is exhaustive and consists of formal checks. A respondent’s argument that the foreign court misassessed the evidence or misapplied the law is inadmissible in this procedure.

The five-day limit is itself an argument against merits review: a procedure designed to run in five working days is structurally incapable of accommodating a rehearing.

Nor does the procedure soften the documentary requirements. The judgment must be duly endorsed (condition (b)) and its finality evidenced either by a separate certificate or on the face of the judgment (condition (d)) — all of it consularly legalised and accompanied by a certified Arabic translation, which has a section of its own below. The practical side of legalisation is covered in the guide to corporate document legalisation and powers of attorney in the UAE.

Reciprocity: how it is built, and what the 2022 Ministry of Justice letter changed

Reciprocity in the UAE is not a separate condition but the architecture of the chapeau in article 222(1): a foreign judgment is enforced “on the same conditions” that the law of the country of origin lays down for enforcing UAE judgments. This is conditional, or negative, reciprocity: what must be shown is not a treaty but a willingness in the foreign system to do the same in return.

Why this worked against English judgments

The Dubai Court of Cassation in Appeal No. 269 of 2006 refused to enforce an English judgment precisely for want of reciprocity. The logic was circular: the English courts did not enforce UAE judgments, so the chapeau condition was unmet, so the UAE courts did not enforce English ones. Only a move by one side could break the circle.

What happened on 13 September 2022

On 13 September 2022 the UAE Ministry of Justice wrote to the Director of the Dubai Courts, over the signature of Judge Abdul Rahman Murad Al-Blooshi, Director of the International Cooperation Department. The letter asked the Dubai Courts to “take the relevant legal actions regarding any requests for enforcement of judgments and orders issued by the English Court, in accordance with the laws in force in both countries, as a confirmation of the principle of reciprocity initiated by the English Courts and assurance of its continuity between the English Courts and the UAE Courts.”

Its premise was that the English courts had by then enforced a Dubai judgment — so the chapeau condition in article 222(1) had in fact been satisfied from the English side.

What the letter is not

The letter is not a treaty and not an exchange of letters between governments. It is an internal UAE Ministry of Justice document addressed to the Dubai Courts. The description “an exchange of letters with the Lord Chancellor” circulates in commentary but is not evidenced by any document.

There is a UK–UAE bilateral treaty — the Treaty on Judicial Assistance in Civil and Commercial Matters, signed in London on 7 December 2006 (Cm 7185) — but it does not touch recognition or enforcement of judgments. Its article 4(2) confines the subject matter expressly: judicial assistance under the treaty “shall apply to: (a) The service of judicial documents; and (b) The taking of evidence by means of Letters of Request or commissions.” A separate treaty on mutual legal assistance in criminal matters was signed on 6 December 2006 and entered into force on 2 April 2008 — the source of the recurring confusion about a “2008” date.

The practical consequence: reciprocity with the United Kingdom rests not on a treaty but on an administrative direction and on the state of English practice. That is a less stable footing than a treaty, and it should be re-checked before each filing.

Reciprocity inside the zones

Neither the DIFC nor ADGM applies the article 222 reciprocity test, because federal civil law does not operate in the zones. ADGM has a reciprocity mechanism of its own — Chief Justice orders under section 171 of the Regulations, analysed below. The DIFC has no formal reciprocity test at all.

Lenkor v Puri: how the English side of reciprocity was established

Lenkor Energy Trading DMCC v Puri is the English decision that in fact supplied the reciprocity on which the UAE Ministry of Justice letter of 2022 relied. The English courts enforced the Dubai judgment with interest at 9% per annum and rejected every public-policy defence raised against it. The Court of Appeal at [1] gives the sum as AED 123,272,048; the first-instance judgments print it as AED 123,727,048 — the discrepancy is in the judgments themselves, so any citation should say which instance the figure comes from.

Three instances

First instance: [2020] EWHC 75 (QB), 23 January 2020, Master Davison. Summary judgment for Lenkor. Three public-policy defences rejected: illegality in the underlying transaction, impermissible piercing of the corporate veil, and interest as a penalty.

Appeal: [2020] EWHC 1432 (QB), 4 June 2020, Murray J. Appeal dismissed, the Master upheld.

Court of Appeal: [2021] EWCA Civ 770, 21 May 2021, Lewison, Arnold and Edis LJJ. Appeal dismissed finally.

What the Court of Appeal actually held

Paragraph 40 opens with the distinction: “First, this is not a question of enforcing a contract. It is a question of enforcing a judgment given by a foreign court of competent jurisdiction. The two are not the same.”

Later in the same paragraph it states the obligation theory of foreign judgments: “The judgment of a foreign court of competent jurisdiction creates an obligation to pay the judgment sum enforceable in this jurisdiction as a debt, irrespective of the underlying cause of action.”

The practical force of that formulation is that illegality affecting the contract underlying a dispute does not automatically infect the judgment given on that dispute. The Dubai judgment rested on article 599/2 — the personal liability of a cheque drawer — not on the gasoil supply contract that the illegality touched.

What the court said about interest

The English courts enforced the Dubai judgment together with interest at 9% per annum and rejected the argument that the interest was a penalty. That is a direct answer to the common assertion that interest as such is incompatible with public policy in cross-border enforcement between these two systems.

Why it matters on the UAE side

Lenkor is not a decision enforcing an English judgment in the UAE; it is a decision enforcing a UAE judgment in England. Its role in the Emirati reciprocity structure is ancillary but decisive: it created the state of affairs in which the chapeau condition of article 222(1) became capable of being satisfied.

A necessary qualification: Lenkor binds no UAE court and is not a precedent in the UAE. An Emirati court still tests reciprocity for itself, case by case, under article 222(1). The Ministry of Justice letter of 13 September 2022 is an administrative direction, not a rule of law.

Dubai Cassation No. 339/2023: concurrent jurisdiction ceased to be a bar

The Dubai Court of Cassation, in Appeal No. 339/2023, decided on 15 August 2024, held that where the UAE courts and the foreign rendering court have concurrent jurisdiction, that does not by itself prevent an enforcement order. The decision overturned a refusal by the Court of Appeal and restored the enforceability of a Polish judgment.

The facts

A Polish claimant sought enforcement in Dubai of a Polish judgment against a Polish national resident in Dubai.The Court of Appeal refused, reasoning that the defendant’s residence in Dubai gave the Emirati courts jurisdiction, so condition (a) of article 222(2) was unmet.

What the Court of Cassation held

“In case of concurrent jurisdiction between UAE courts and the foreign rendering court, this does not, by itself, prevent the granting of the enforcement order.” Refusal is available only where the UAE courts have exclusivejurisdiction.

The Court quoted article 85 of the 2018 Regulation, noting that it was “later confirmed in Article 222 of the 2022 Civil Procedure Law”. The Court thus expressly treated the provision as continuous and applied to it the Arabic reading, with its exclusivity qualifier.

What it changes in practice

Before this decision, the debtor’s residence in the UAE was a self-standing argument against enforcement. After it, it is not: the respondent must show that the subject matter falls within the exclusive jurisdiction of the Emirati courts, and those categories are few.

Exclusive UAE jurisdiction arises principally over disputes concerning real property situated in the UAE, and over certain categories expressly reserved by statute. An ordinary commercial debt is not among them.

The level of confidence

A note on the source: Appeal No. 339/2023 is evidenced by an academic publication quoting the text, not by a primary publication from the court itself. Dubai cassation judgments are not systematically published in open access, which makes primary verification difficult. The rule it states, however, reproduces the Arabic text of article 222(2)(a), which can be verified against the primary source — so there is no gap here between source and norm.

The practical conclusion: a strategy built on the assumption that any UAE connection blocks enforcement is no longer sustainable, but treating a single cassation decision as settled practice is premature.

The UAE treaty network: what actually binds the country

Article 225 of the Code subordinates the whole chapter to treaties, so the first question when preparing an application is whether a treaty exists, not whether reciprocity exists. A treaty removes the need to prove reciprocity and substitutes the treaty’s own conditions for those in article 222.

Multilateral conventions

The Riyadh Arab Agreement for Judicial Cooperation 1983 is the principal multilateral instrument for the Arab states, and the UAE is a party. It was adopted in Riyadh on 6 April 1983 and endorsed by the Council of Arab Ministers of Justice.

Article 30 of the Riyadh Agreement lists the grounds for refusal: contradiction with Islamic Shari’a, with the constitution, with public order or with the rules of conduct of the requested party; a judgment in absentia without proper notification; defective representation of persons lacking capacity; an existing recognised final judgment on the same dispute; and earlier seisin in the requested state.

The GCC Convention for the Execution of Judgments, Delegations and Judicial Notifications 1996 operates between the Gulf Cooperation Council states. Its article 1: “Each of the GCC countries shall execute the final judgments issued by the courts of any member state in civil, commercial and administrative cases.” Article 2 sets out the refusal grounds, including breach of Islamic Shari’a, the constitution or public order.

Bilateral treaties

France: the Convention on judicial assistance, recognition and enforcement of decisions in civil and commercial matters, signed in Paris on 9 September 1991. It was published in France by Décret No. 93-419 of 15 March 1993. Its article 13 sets the conditions for recognition and exequatur, including the absence of anything contrary to the public policy of the requested state.

A point of accuracy: dating this convention to 1992, as some commentary does, is wrong — signature was on 9 September 1991, French publication in March 1993.

India, China and Kazakhstan: bilateral agreements on judicial assistance in civil and commercial matters exist, but their numbers and UAE ratification dates could not be confirmed against primary sources in preparing this guide. Stating those numbers as established fact would be inaccurate; the ratification chain should be verified separately before filing.

Egypt and Russia: no bilateral judgments treaty with the UAE could be found. With Egypt the general regime of the Riyadh Agreement applies, both states being parties to it.

What the UAE does not have

The UAE is not a party to the Hague Convention on Choice of Court Agreements 2005. Verified against the status table of the Hague Conference on Private International Law: the UAE does not appear among the contracting parties.

The UAE is not a party to the Hague Judgments Convention 2019. Same check, same result.

The practical consequence: between the UAE and most Western jurisdictions there is no treaty basis for recognising judgments at all. What remains is reciprocity under article 222(1) — and, inside the zones, mechanisms of their own.

India and notification G.S.R. 38(E): the one instrument that names the DIFC and ADGM

On 17 January 2020 India’s Ministry of Law and Justice declared the UAE a “reciprocating territory” for the purposes of section 44A of the Indian Code of Civil Procedure 1908, and listed the Emirati courts recognised as “superior courts”. The notification is registered as G.S.R. 38(E) and published in the Gazette of India: Extraordinary, Part II—Section 3—Sub-section (i).

What “reciprocating territory” status means

Section 44A of the Indian Code of Civil Procedure allows a judgment of a superior court of a reciprocating territory to be executed directly, as though it had been passed by an Indian district court, without filing a fresh suit. That is a radically shorter route than the ordinary one, in which a foreign judgment merely founds a cause of action.

The list of courts

The notification names two groups. Federal courts: the Federal Supreme Court; the Federal First Instance and Appeals Courts in the emirates of Abu Dhabi, Sharjah, Ajman, Umm Al Quwain and Fujairah. Local courts: the Abu Dhabi Judicial Department; the Dubai Courts; the Ras Al Khaimah Judicial Department; the Courts of Abu Dhabi Global Market; and the Courts of the Dubai International Financial Centre.

This is the only known international instrument in which the DIFC and ADGM Courts are named alongside the ordinary Emirati courts. The practical effect is substantial: a DIFC or ADGM judgment is executed in India through the abbreviated section 44A procedure.

Two features of the text

The notification prints “Abu Dhabi Global Markets” — with a trailing s the zone’s name does not carry — and “Financial Center” in the US spelling. Quote it as printed.

It is signed by Rajveer Singh Verma, Additional Secretary, under file reference F. No. J-14014/1/2015-Judl.

What the notification does not do

G.S.R. 38(E) is a unilateral act of the Indian government and creates no obligation for the Emirati courts. It eases the movement of judgments from the UAE into India, not the reverse. For the opposite direction, article 222 of the federal Code applies, together with the bilateral agreement if its existence can be confirmed.

A caution about symmetry: the existence of the Indian notification does not mean Indian judgments are enforced in the UAE by any abbreviated procedure. The UAE side still applies its own test — either the treaty route under article 225 or reciprocity under article 222(1).

There is no apostille route: consular legalisation as a condition of admissibility

The UAE is not a party to the Hague Convention of 1961 abolishing the requirement of legalisation for foreign public documents, and an apostille is not accepted in the UAE. This is verified against the status table of the Hague Conference on Private International Law: the list of 130 contracting parties, updated on 30 June 2026, does not include the UAE.

Why this matters more than it appears to

Conditions (b) and (d) of article 222(2) require the foreign judgment to be “duly endorsed” and its finality to be evidenced either by a separate certificate or by a statement of finality in the judgment itself. Without proper legalisation neither condition is satisfied, and the execution judge must refuse — not on the merits, but on form.

In practice this is decisive: an application supported by an apostilled but unlegalised judgment will not succeed, whatever the sum involved and however sound the judgment itself.

The legalisation chain

The consular chain normally has four links: notarisation in the country of origin, certification by that country’s ministry of foreign affairs, certification by the UAE embassy or consulate there, and certification by the UAE Ministry of Foreign Affairs. Each link takes time and is charged separately. Several UAE missions now accept applications electronically and the exact sequence is set by the mission concerned, so the current procedure should be confirmed on the website of the UAE mission in the country of origin before the bundle is assembled.

A certified Arabic translation is then added to the legalised document, prepared by a translator accredited with the UAE Ministry of Justice. A translation done abroad is generally not accepted.

What must be legalised

The following require legalisation: the judgment itself, bearing the endorsement that it has entered into force; the certificate of finality, where it is a separate document; the representative’s power of attorney; and the applicant’s corporate documents evidencing the signatory’s authority. Omitting any one of them sends the file back to the document-assembly stage.

The power of attorney is the most common bottleneck, because it must be granted and legalised before filing, and its scope must expressly cover making an enforcement application. The requirements for powers of attorney and corporate documents are set out in the guide to corporate document legalisation in the UAE.

The zones apply different requirements

The DIFC and ADGM Courts conduct proceedings in English, and no Arabic translation is needed to file with them. The Arabic translation requirement arises at the next stage — when the zone court’s judgment is passed to the emirate’s onshore court for execution.

This is one of the practical advantages of the zone route for a foreign creditor: documents in English are accepted as they stand, and translation is needed only on the way out.

The DIFC after Dubai Law No. 2 of 2025: the new architecture

Dubai Law No. 2 of 2025 concerning the Dubai International Financial Centre Courts was issued on 3 March 2025 and came into force on 15 March 2025 — the day after publication in the Official Gazette — replacing two statutes at once. The commencement date is confirmed by the DIFC Court of Appeal in Trafigura at paragraph 7: “the DIFC Courts Law (No. 2) of 2025 … has come into force with effect from 15 March 2025”. Its article 43(A): “This Law shall supersede DIFC Law No. (10) of 2004, and Dubai Law No. (12) of 2004.”

What was replaced and what survives

Article 43(C) preserves the subordinate instruments of the old regime: “The regulations and resolutions issued by DIFC Law No. (10) of 2004 and Dubai Law No. (12) of 2004 shall, to the extent that they do not contradict with the provisions of this Law, continue to be in force until new superseding resolutions and regulations are issued.”

The practical consequence is that the Rules of the DIFC Courts (RDC) remain in force even though Part 45 still cites articles 7(2) and 7(3) of the repealed Dubai Law No. 12 of 2004. The Rules have not been conformed to the new statute. A lawyer preparing an application works with procedural rules that point at provisions which no longer exist, and has to convert the references itself.

Jurisdiction: article 14

Article 14(A) lists seven heads of exclusive jurisdiction: claims against DIFC Bodies and Establishments; claims arising from contracts concluded or performed wholly or partly within the DIFC; claims arising from incidents and transactions related to the activities of DIFC Bodies and Establishments within the DIFC; claims arising from trusts established or registered in the DIFC and non-Muslim wills registered with the DIFC Courts; claims for the ratification or recognition of arbitral awards; claims arising from arbitration proceedings; and claims over which the DIFC Courts have jurisdiction under legislation or international treaties.

Article 14(B) is the opt-in provision: the DIFC Courts have jurisdiction over civil and commercial claims “where the parties expressly agree in writing to the DIFC Courts’ jurisdiction, whether before or after the dispute arises, provided that such agreement is made pursuant to specific, clear and express provisions.”

Article 14(C) is new — it had no counterpart in the old statute: the DIFC Courts may decline** jurisdiction over claims that fall within their jurisdiction but where the parties have agreed in writing to another court, and over claims in which a final judgment has already been given by another court and can be enforced within the DIFC.**

The gap where article 24 used to be

Law No. 2/2025 contains no provision expressly giving the DIFC Courts jurisdiction to recognise foreign court** judgments.** Article 14(A)(5) speaks only of arbitral awards. The repealed article 24 of DIFC Law No. 10 of 2004 conferred that jurisdiction expressly and by name: “the Court of First Instance has jurisdiction to ratify any judgment, order or award of any recognised: (a) Foreign court; (b) Courts of Dubai or the United Arab Emirates; (c) Arbitral Award; (d) Foreign Arbitral Award”.

The functional substitutes are article 14(A)(7) — jurisdiction under legislation and treaties — and article 31, analysed in the next section. But article 24 has no direct successor, and that is a textual fact rather than an opinion. One caveat against confusion: Law No. 2/2025 does contain an article 24, but it is a powers provision — interim orders, injunctions, interlocutory orders — not a head of jurisdiction. How the DIFC is put together as a jurisdiction is covered separately in the guide to the DIFC: structures, authorities and courts.

DNB Bank v Gulf Eyadah: the anatomy of the conduit

DNB Bank ASA v (1) Gulf Eyadah Corporation (2) Gulf Navigation Holding PJSC is the source of the conduit-jurisdiction concept itself, and the two instances split on it. The DIFC Court of Appeal decided it on 25 February 2016, citation [2015] DIFC CA 007, before Chief Justice Michael Hwang, Justice Sir David Steel and Justice Omar Al Muhairi.

What the first instance decided

At first instance — [2014] DIFC CFI 043, Justice Ali Al Madhani, 2 July 2015 — the court accepted that the DIFC Courts may recognise foreign judgments, but refused to refer a recognised judgment on to the Dubai Courts for execution.

The key passage at first instance: “execution shall not go beyond the jurisdiction of this Court which requires this Court not to refer Recognised Foreign Judgments to the Dubai Court for execution.” That was the narrow position: the DIFC as a place of recognition, but not as a channel.

A note on a common error: the first-instance decision in this case is frequently attributed to Justice Sir John Chadwick. It was given by Justice Ali Al Madhani.

What the Court of Appeal held

The Court of Appeal reversed the conduit holding below and held that a foreign judgment recognised in the DIFC becomes a local judgment of the DIFC Courts and must be treated as such by the Dubai Courts.

Paragraph 104: “Using Lord Bridge’s line of reasoning, a foreign judgment, when granted recognition in the DIFC Courts, therefore becomes a local judgment of the DIFC Courts and should therefore be treated as such by the Dubai Courts (amongst others).”

Paragraph 116: “Once it is enforced, it becomes an independent local judgment of this Court.”

Paragraph 129: “From the perspective of the DIFC Courts, it is not wrong to use the DIFC Courts as a conduit jurisdiction to enforce a foreign judgment and then use reciprocal mechanisms to execute against assets in another jurisdiction.”

The assets question

The Court of Appeal expressly rejected any requirement that assets be present in the DIFC. At paragraph 125, enforcement of foreign court judgments within the DIFC “will be allowed whether or not there are assets within the DIFC”. Paragraph 127 adds that “whilst the absence of assets may be a point for consideration by the Court in granting execution of an award, it is not a bar to enforcement”, and paragraph 128 that “the nature and whereabouts of the assets should only be dealt with after the local DIFC Courts judgment on the foreign judgment is obtained”.

That construction — recognition without nexus, plus onward referral for execution — is the conduit. It rested on two now-repealed provisions: article 7 of Dubai Law No. 12 of 2004 and article 24 of DIFC Law No. 10 of 2004.

Confirmed in 2017

Barclays Bank PLC & others v Essar Global Fund Limited, [2016] DIFC CFI 036, Justice Sir Richard Field, 13 April 2017, applied DNB and enforced a New York judgment for USD 171,769,169 — a Judgment by Confession under § 3218 of the New York Civil Practice Law and Rules.

Paragraph 44 of that judgment: “In my judgment, it is not open to EGFL to argue that the DNB Bank case is not binding on the Court of First Instance… it is the duty of this Court to follow and apply the judgment of the Court of Appeal.”

Articles 30 to 33 of Law No. 2/2025: what survives of the conduit

The conduit survives in the new statute through article 32, but the entrance to it has narrowed: article 31 ties the DIFC execution judge’s jurisdiction to the presence of a DIFC connection. That is a fundamental change from DNB, where the Court of Appeal expressly rejected any nexus requirement.

Article 30: what counts as an Enforcement Writ

Article 30(B) lists six categories of Enforcement Writ: judgements, decisions or orders issued by the DIFC Courts; arbitral awards ratified by the DIFC Courts; documents certified in accordance with the Law; signed settlement agreements approved by the DIFC Courts Mediation Centre; settlement agreements ratified by the DIFC Courts in the course of proceedings; and other documents to which any applicable law grants enforcement status.

A foreign court judgment is not named in that list — it enters only through the first category, by becoming a “judgement issued by the DIFC Courts”. That is precisely the reasoning the Court of Appeal applied in DNB: a recognised judgment becomes a local one. But it now rests on an inference from a list rather than on an express ratification provision.

Article 30(D): “All authorities and competent entities in the Emirate shall proceed with the enforcement of the Writ, by force if so required.”

Article 31: the execution judge’s jurisdiction and the link requirement

Article 31(2) gives the DIFC execution judge jurisdiction over “the enforcement of judgements and judicial decisions issued by foreign or local courts, including the Dubai Courts, in the event that the enforcement shall fall onto any of the DIFC Bodies, DIFC Establishments, Licensed DIFC Establishments, or any other entity within the DIFC.”

The phrase “in the event that the enforcement shall fall onto … any other entity within the DIFC” is the enforcement-link requirement. Without it the DIFC Courts have no enforcement jurisdiction.

Article 31(4) separately covers enforcement inside the DIFC of judgments and judicial decisions affixed with the executory formula and issued by local or foreign courts, together with interim and precautionary measures.

Article 31(7): where enforcement rests on a writ issued by an entity other than the DIFC Courts, “the DIFC Courts’ Enforcement Judge may not review the merits of the judgement, order, or decision subject to enforcement, except as provided by in this Law, in regard to enforcement procedures, without prejudice to the origin of the right adjudged.”

Article 32: the conduit itself

Article 32(A): “The Enforcement Judge shall seek the assistance of the Dubai Courts’ Enforcement Judge to enforce Writs of Enforcement issued by the DIFC Courts, where the object of enforcement is situated outside of DIFC.” Five conditions attach: the judgment is final and executory; it is accompanied by an official Arabic translation; the executory formula is affixed; the DIFC Courts issue an official letter to the Dubai Courts requesting deputisation; and the party seeking enforcement settles the fees the Dubai Courts prescribe.

Article 32(B) preserves the central safeguard: “the Enforcement Judge in Dubai Courts may not review the merits of the case, except as stipulated in this Law in regards to enforcement procedures, and without prejudice to the origin of the right adjudged.”

Article 32(C) requires the Dubai execution judge to report back to the DIFC execution judge on the steps taken, to transfer any funds received, and to notify any legal reasons he considers prevent enforcement.

Article 33: treaties

“The provisions of Articles (30), (31), and (32) of this Law shall not prejudice the application of any international treaties and conventions to which the State is a signatory or acceding party relating to enforcement of foreign courts judgements, decisions, and awards.”

The Conflict of Jurisdiction Tribunal: Dubai Decree No. 29 of 2024

The tribunal that resolves conflicts of jurisdiction between the DIFC Courts and the judicial bodies of the Emirate of Dubai has not been abolished — it was renamed and restructured by Dubai Decree No. 29 of 2024, issued on 3 April 2024. Commentary describing it as abolished is wrong: article 2(a) applies the decree to the existing committee, and article 2(b) merely changes its name.

Article 13: “This Decree supersedes the above-mentioned Decree No. (19) of 2016.” The body is live, has its own website at cjt.gov.ae, and publishes its decisions in an electronic registry.

What changed in the composition

There are still seven members, but DIFC representation has been strengthened. The chairman is the Chief Justice of the Court of Cassation of the Dubai Courts; the vice chairman is the Deputy Chief Justice of the DIFC Courts — a new post; then the Secretary General of the Judicial Council; the Chief Justice of the Court of Appeal of the Dubai Courts; the Chief Justice of the Courts of First Instance of the Dubai Courts; and two judges of the DIFC Courtsappointed by the DIFC Chief Justice.

The balance remains four to three in favour of the Dubai side, but the DIFC now holds the vice-chairmanship and a second seat on the bench. That is the composition that sat on Application No. 1 of 2026.

What changed in the grounds for a referral

Article 6(a) now requires a genuine conflict: an application lies where, as between the DIFC Courts and a judicial entity, “neither or both of them relinquish jurisdiction” over a claim, or where they “deliver conflicting judgements” on it. The old decree spoke loosely of “a conflict”, which invited tactical referrals.

Only litigants may apply. The Attorney General’s power of referral under article 4 of Decree No. 19 of 2016 has gone.

Article 8 imposes a security deposit of AED 3,000 as a condition of admissibility: non-payment renders the application inadmissible but does not preclude resubmission; the deposit is refunded where the Tribunal rules in the applicant’s favour, and is paid over to the court found to have jurisdiction where the Tribunal holds that the court the applicant asserted had jurisdiction does not. It is a direct deterrent to tactical referrals.

The effects of a referral

Article 7 lists three effects: stay of proceedings on the claims in respect of which the conflict of jurisdiction exists, pending the Tribunal’s decision; stay of enforcement proceedings, pending determination of which judgment is enforceable; and suspension of limitation periods and time-bar periods — running from the date the application is submitted.

The precedential force of decisions

Article 9(b): the Tribunal’s decisions are “final and not subject to any form of appeal”.

Article 9(c) is the significant innovation: “The rules of law established by the Judicial Committee in the decisions issued pursuant to this Decree will be deemed judicial precedents. All judicial entities at all levels, including the DIFC Courts, will be bound by these precedents. Any conflict of a subsequent judicial ruling with any of these rules will provide grounds for challenging that ruling through any legally prescribed means of appeal.”

The practical significance is that a binding-precedent mechanism has been introduced into the Dubai system, expressly binding on the DIFC Courts. Before 2024 there was no such provision. The Tribunal applied it in its decision of 6 July 2026, stating that “pursuant to Article 9(c) of Decree No. 29 of 2024, the legal principles determined by the Tribunal are binding upon all judicial authorities within the Emirate”.

Practice under the old decree

The Tribunal’s first decision — Cassation No. 1 of 2016, Daman Real Capital Partners Company LLC v Oger Dubai LLC, 19 December 2016 — was decided on a three-three split by the chairman’s casting vote. It remitted the case to the Dubai Courts and directed the DIFC Courts to cease entertaining it.

A note on numbering: this case is often cited as “Cassation No. 6 of 2016”. The correct number is No. 1 of 2016.

The overall pattern of the old case law matters more than the individual numbers: the Tribunal never held the conduit unlawful in principle. It stopped DIFC proceedings where the Dubai Courts were already seised of the same dispute. Absent parallel Dubai proceedings, DIFC recognition stood — including in Cassation No. 5 of 2016, Gulf Navigation Holding PJSC v DNB Bank ASA, the direct sequel to DNB itself.

Application No. 1 of 2026: recognition separated from enforcement

On 20 April 2026 the Conflict of Jurisdiction Tribunal decided Application No. 1 of 2026, Global Marketing Systems DMCC v Guang Zhou Salvage, separating recognition and compulsory enforcement into two distinct jurisdictions. It is the most consequential decision for the conduit route since DNB, and it points the other way.

The facts

An arbitral award had been made by the Singapore Chamber of Maritime Arbitration in SCMA Arbitration No. 25/2020, and then became the subject of two parallel proceedings inside the emirate: ratification and enforcement before the DIFC Courts in case ARB-029-2025, and annulment before the Dubai Courts in case No. 13/2026.

On 1 January 2026 the DIFC Courts issued an enforcement order. A positive conflict of jurisdiction arose: two actions, one award, the same parties, the same legal basis.

What the Tribunal held on recognition

The DIFC Courts’ jurisdiction to recognise an award does not depend on the seat of the arbitration. Paragraph 13: “Since this provision is general and unrestricted by the seat of arbitration, jurisdiction accordingly lies with the DIFC Courts to hear the request for recognition or ratification of the arbitral award in dispute, provided it is submitted in accordance with the legal and procedural framework applicable within the DIFC.”

Paragraph 14 disposes of the procedural counter-argument separately: the fact that the DIFC Courts’ Rules regulate recognition and enforcement through a unified process “does not alter the legal distinction between two separate stages, differing in nature and effect”.

What the Tribunal held on enforcement

Paragraph 15 states the distinction itself: “compulsory execution is an issue distinct from recognition or ratification; a particular court may possess jurisdiction to recognize an arbitral award and confer legal force upon it, without necessarily possessing jurisdiction to undertake compulsory enforcement proceedings thereof.”

Paragraph 17: the legislature “has distinguished between the executory character of an arbitral award following ratification, and the judicial authority that is competent to carry out such enforcement. It restricted the DIFC Execution Judge’s jurisdiction to cases where a sufficient enforcement link exists within the DIFC, namely where execution is directed against a DIFC body, establishment, licensed entity, or other entity located therein; while providing that enforcement outside the DIFC, where applicable, proceeds through the Dubai Courts in accordance with the prescribed legal framework.”

Paragraph 18: because the file disclosed no indication that enforcement was directed against any DIFC body, institution, licensed establishment or entity within the DIFC, “the jurisdictional condition for enforcement under Article 31(3) of the DIFC Courts Law is, therefore, not satisfied in the present matter.”

The operative order

The Tribunal held that the DIFC Courts have jurisdiction to hear the application for recognition and ratification of SCMA Award No. 25/2020, and that the Dubai Courts lack jurisdiction to hear the annulment case; and that the Dubai Courts have jurisdiction to enforce that award, while the DIFC Courts lack jurisdiction to enforce it.

Why this reaches court judgments, not only arbitral awards

Application No. 1 of 2026 was decided on article 31(3), which concerns arbitral awards. But article 31(2), which concerns foreign court judgments, carries word for word the same link requirement: “in the event that the enforcement shall fall onto any of the DIFC Bodies, DIFC Establishments, Licensed DIFC Establishments, or any other entity within the DIFC.”

And the question has already ceased to be one of construction: on 6 July 2026 the Tribunal extended the same principle to the enforcement of a court judgment. Zaya Living Real Estate Development LLC v China State Construction Engineering Corporation (Middle East), Application No. 4 of 2026, concerned enforcement of a judgment of the Dubai Court of First Instance and the use of Parts 49 and 50 of the Rules of the DIFC Courts to trace the debtor’s assets.

Paragraph 14 states the rule for the whole enforcement chapter rather than for one article: “DIFC Courts Law No. 2 of 2025 regulates execution proceedings in Articles 30 and following. Properly construed, those provisions do not confer upon the DIFC Execution Judge a general or unrestricted jurisdiction over all assets of a judgment debtor wherever situated. Rather, the jurisdiction of the DIFC Courts in execution proceedings depends upon the existence of a sufficient enforcement connection with the DIFC, whether by reason of assets situated within the DIFC or another adequate enforcement nexus. Where the subject matter of execution lies outside the DIFC, Article 32 expressly provides a mechanism whereby the assistance of the Dubai Courts may be invoked.”

Paragraph 15 ties it expressly to the earlier decision: “this construction accords with the principles previously established by the Tribunal in Application No. 001/2026, namely that the execution jurisdiction of the DIFC Courts remains confined within its legal and geographical limits and does not extend to compulsory enforcement measures, or ancillary execution procedures, concerning assets situated outside the DIFC or otherwise lacking a sufficient enforcement connection with it.”

The operative order: the DIFC Courts’ jurisdiction under Part 50 is “confined to assets, property or the place of execution situated within the Dubai International Financial Centre, or otherwise having a sufficient enforcement connection with the DIFC, and does not extend to assets, property or the place of execution situated outside the DIFC.”

Note the institutional detail: on 7 April 2026, in Appeal No. CA-001-2026, the DIFC Court of Appeal had held the opposite — that the Part 50 procedure is not confined to assets within the DIFC. The Tribunal stated expressly that it does not sit as an appellate body over the DIFC Court of Appeal but resolves the allocation of jurisdiction, and that its rulings bind all judicial authorities in the Emirate under article 9(c) of Decree No. 29 of 2024.

The practical conclusion: the conduit — recognising a foreign judgment in the DIFC and then reaching Dubai assets — survives, but enforcement outside the DIFC runs through the Dubai Courts under article 32 rather than through the DIFC execution judge. Recognition in the DIFC remains broad and needs no nexus; enforcement inside the DIFC needs a link, and that is now settled for both categories — arbitral awards and court judgments alike.

ADGM: the architecture and the direct application of English law

Abu Dhabi Global Market was established by Federal Decree No. 15 of 2013, issued on 11 February 2013, under Federal Law No. 8 of 2004 concerning Financial Free Zones. Article 1 of the decree: “A financial free zone shall be established under the name ‘Abu Dhabi Global Market’.”

A note on a textual defect: the official English translation of the decree prints the date as “Rabi’ II. 1st, 1431 Corresponding to February 11th, 2013”, which is internally impossible — 1 Rabi’ II 1431 falls in March 2010. The correct correspondence is 1 Rabi’ II 1434, that is 11 February 2013. The Hijri year is a typographical error in the translation.

The founding law and its amendment

Abu Dhabi Law No. 4 of 2013 was issued on 19 February 2013; its article 25 provides that it takes effect from the date of issue. It is the ADGM Founding Law, and its article 13 governs the courts’ jurisdiction and the enforcement of their judgments.

Abu Dhabi Law No. 12 of 2020 was issued on 23 April 2020 and, under its article 3, takes effect from the date of publication in the Official Gazette — so issue and commencement genuinely differ here. The publication date could not be confirmed against a primary source; the date of 27 May 2020 that appears in commentary is probably the commencement date.

The opt-in provision introduced by Law No. 12/2020 reads: “The Global Market’s Courts may hear and adjudicate any civil or commercial claim or dispute where the parties agree in writing to file such claim or dispute with them whether before or after the claim or dispute arises.”

The direct application of English law

The Application of English Law Regulations 2015 make English common law, including the rules and principles of equity, directly applicable in ADGM, together with a schedule of English statutes on civil matters. The Regulations were amended in 2020: ADGM announced the amendment on 15 December 2020, following a consultation that closed on 15 November 2020.

This is a fundamental difference from the DIFC, which has civil and commercial statutes of its own. ADGM does not write a civil code — it plugs into England’s.

But for the recognition of foreign judgments the difference does not work the way it is usually assumed to. Chapter 10 of the ADGM Courts Regulations is a fully codified registration regime, not a reference to the common law. English law fills the gaps around it; it does not replace it.

Enforcing ADGM judgments outside the zone

Article 13, paragraph 13 of Law No. 4/2013 provides that judgments and orders rendered by the Global Market’s Courts and arbitral awards recognised by the Global Market’s Courts shall be enforced by the competent entities outside the Global Market in accordance with the procedures and rules adopted by such entities, as well as any memoranda of understanding between the Board of Directors or the Global Market’s Courts and those entities.

Paragraphs 15 and 16 of article 13 set out two enforcement routes and expressly codify the Memorandum of Understanding with the Abu Dhabi Judicial Department: a judgment creditor’s direct application to any court of the Emirate, and deputisation by the Global Market’s Courts of an enforcement judge of the Emirate’s courts. In both, the Emirate’s enforcement judge applies the procedures of Federal Law No. 11 of 1992 “without re-examining the merits of the judgment, order or recognised arbitral award”.

A note on numbering: after Law No. 12/2020 the former paragraph 11 of article 13 became paragraph 13. Practitioner sources cite both numbers; it is the same provision in two different versions of the law.

And one provision that is almost never discussed: article 13(1), in its current form, expressly classifies the Global Market’s Courts as “courts of the Emirate”. ADGM’s own guidance lists this at paragraph 2(f) as one of the effects of the 2020 reform: the law “confirms ADGM Courts’ status as courts of the Emirate”. What that turns on is set out below, in the section on Abu Dhabi.

The mechanism is implemented by the Memorandum of Understanding between the Abu Dhabi Judicial Department and the ADGM Courts concerning the reciprocal enforcement of judgments, dated 11 February 2018.Parallel reciprocal-enforcement memoranda exist with the Ministry of Justice (4 November 2019), the Ras Al Khaimah Courts (5 May 2019) and — directly relevant to this guide — with the Dubai Courts, dated 14 January 2025.

A note on the status of the texts: ADGM publishes Law No. 4 of 2013 and Law No. 12 of 2020 marked “Unofficial English translation”. The Arabic is the authentic text. How ADGM is put together as a jurisdiction is covered separately in the guide to ADGM: structures, authorities and courts.

Chapter 10 of the ADGM Regulations: the 1933 English scheme

Recognition of foreign judgments at ADGM is governed by Chapter 10 of the ADGM Courts, Civil Evidence, Judgments, Enforcement and Judicial Appointments Regulations 2015 — sections 167 to 180, headed “Reciprocal Recognition and Enforcement of Judgments of other Jurisdictions and Arbitral Awards”. The consolidated text in force is dated 17 October 2025. A note on the enactment date: ADGM’s legislation page gives 17 December 2015, while the rules-and-regulations section of the same site gives 11 December 2015 — the discrepancy is in ADGM’s own publications.

Chapter 10 reproduces the scheme of the English Foreign Judgments (Reciprocal Enforcement) Act 1933: not common-law recognition through an action on the judgment, but registration of the judgment in court. The distinction matters: the applicant registers a judgment rather than litigating it afresh.

What a “recognised court” is

Section 167(1)(g) defines a “recognised court” as three categories: the judicial authorities of the Emirate and of Emirate Members of the UAE; courts of countries which have entered into applicable treaties; and a recognised foreign court.

Section 167(1)(h): a “recognised foreign court” means a court recognised by the Courts in accordance with the procedure set out in section 171.

The practical consequence of the definition: a judgment from a country with no UAE treaty and no section 171 order simply falls outside Chapter 10 altogether. That is not a refusal on the merits — there is nothing capable of being registered.

The conditions for registration

Section 171(2) limits the subject matter: the Courts recognise and enforce judgments “for the payment of a sum of money”, excluding sums payable in respect of taxes or other charges of a like nature, or in respect of a fine or other penalty. Non-money judgments — specific performance, injunctions — fall outside Chapter 10.

Section 172(1): a judgment of a recognised court shall be registered if it is either final and conclusive as between the judgment debtor and the judgment creditor or requires the former to make an interim payment; and, in the case of a judgment of a recognised foreign court, if it is given after the coming into force of the order which made that court a recognised foreign court.

Section 172(3) disposes of a common objection: “A judgment shall be deemed to be final and conclusive notwithstanding that an appeal may be pending against it, or that it may still be subject to appeal, in the courts of the country of the original court.”

The window, and the bar on merits review

Section 173(1) gives the creditor six years** from the date of the judgment — or from the date of the last judgment in appeal proceedings — to apply to the Court of First Instance for registration.**

Section 173(2)(b): in determining such an application the Court of First Instance “will not re-examine the merits of the judgment”.

Section 173(3): a judgment shall not be registered if, at the date of the application, it has been wholly satisfied or could not be enforced by execution in the country of the original court.

Grounds for setting registration aside

Section 175(1)(a) lists six grounds on which registration shall** be set aside**: the judgment is not one to which Chapter 10 applies, or was registered in contravention of Chapter 10; the original court had no jurisdiction in the circumstances of the case; where given in default, the judgment debtor was not duly served with the documents instituting the proceedings in sufficient time to arrange a defence; the judgment was obtained by fraud; the rights under the judgment are not vested in the person who applied for registration; or enforcement would be contrary to public policy in the Emirate or in Abu Dhabi Global Market.

Section 175(1)(b) adds a discretionary ground: registration may** be set aside where the matter in dispute had previously, before the date of the judgment in the original court, been the subject of a final and conclusive judgment by a court having jurisdiction.**

Section 175(2) sets the deemed bases of the original court’s jurisdiction in actions in personam: the debtor submitted by voluntarily appearing; the debtor was claimant or counter-claimant; the debtor had agreed before the proceedings began to submit to that court’s jurisdiction; the debtor was resident in that country when proceedings were instituted, or being a body corporate was registered under its laws; or the debtor had an office or place of business there and the proceedings concerned a transaction effected through it.

The ADGM double lock: why the conduit is impossible there

ADGM is closed to conduit use from both directions at once: article 13(14) of Law No. 4/2013 stops such a judgment getting out, and section 172(2)(c) of the Regulations stops one getting in. This is not a gap and not case law, but two express statutory prohibitions.

The first lock: nothing gets out

Article 13, paragraph 14 of Abu Dhabi Law No. 4 of 2013 as amended by Law No. 12 of 2020, verbatim: “Paragraph 13 of this Article shall not apply to a judgment or order rendered by the Global Market’s Courts in respect of the recognition or enforcement of: (a) a judgment or order issued by a court outside the Emirate; or (b) any arbitral award rendered by a tribunal where the seat is outside the Global Market.”

Note where the line actually falls: exclusion (a) is about courts outside the Emirate of Abu Dhabi, not outside ADGM. A judgment of the onshore Abu Dhabi courts is not caught — that is the limited exception.

ADGM’s own official guidance says so in terms, and the section of the guide is headed “ADGM Courts’ judgments not to be used as an impermissible device for enforcement”. Paragraph 11: “Put simply, parties cannot use ADGM for the enforcement of non-ADGM judgments and awards in other jurisdictions – the limited exception being where the originating judgment comes from another court within the Emirate.”

Paragraph 12 states the principle: “As a matter of principle, it has always been ADGM Courts’ position that parties should go to the place where the relevant assets are located for the purpose of enforcement.”

Paragraph 13 states the price: to take advantage of the favourable enforcement framework ADGM Courts have with other jurisdictions, parties “must submit their original dispute for determination by ADGM Courts or by arbitration in ADGM”.

A chronological detail that reveals the design: Law No. 12/2020 did two things in one instrument. Paragraph 3 of the same guidance: “parties with no connection to ADGM can agree to have their civil or commercial claims or disputes determined by ADGM Courts, or by way of arbitration seated in ADGM.” The front door was opened and the conduit door shut in the same breath.

The practical sense of that pairing: ADGM invites you to have the dispute decided there, and declines to be a staging post for someone else’s judgment.

What the bar actually bites on: not recognition, but the executory formula

Paragraph 14 of the ADGM guidance removes a common misunderstanding: the ADGM Courts can still recognise a foreign decision, and can do so even where there are no assets in the zone at all. Verbatim: “In practice, parties are still able to apply to ADGM Courts for the recognition and enforcement of non-ADGM judgments and awards even if there are no relevant assets in ADGM. But, save for the limited exception referred to in paragraph 11, the Registry of ADGM Courts will not affix the ‘executory formula’ to any subsequent ADGM Courts judgment or order for the purpose of enforcement (including execution) in other jurisdictions.”

So the mechanism of the bar is an administrative refusal to affix the executory formula, not a denial of jurisdiction to recognise. A creditor obtains the recognition and is denied the instrument that carries it out of the zone.

Structurally this is the very division the Conflict of Jurisdiction Tribunal drew for the DIFC in Applications No. 1 of 2026 and No. 4 of 2026: recognition and compulsory enforcement are different jurisdictions. Abu Dhabi arrived there by statute in 2020; Dubai by tribunal practice in 2026.

The second lock: nothing gets in

Section 172(2) of the ADGM Courts Regulations lists three cases in which a judgment of a recognised court that satisfies subsection (1) is nonetheless not to be registered. The third is an express anti-conduit provision.

Section 172(2)(c), verbatim: a judgment shall not be registered if it is “given by that court in proceedings founded on a judgment of a court in another country and having as their object the enforcement of that judgment.”

This is a refusal to recognise other people’s conduit judgments. If a creditor obtains a recognition judgment in jurisdiction A and then brings that judgment to ADGM, section 172(2)(c) shuts registration out. Only the original judgment, given on the merits of the dispute, is registrable.

Section 172(2) carries two further exclusions: a judgment given by that court on appeal from a court which is not a recognised court (paragraph (a)); and a judgment or other instrument which is regarded for enforcement purposes as a judgment of that court but which was given or made in another country (paragraph (b)).

What this means for choosing a route

A creditor whose object is to reach assets in Abu Dhabi on the strength of a foreign judgment cannot use the ADGM Courts as an intermediate step. Two options remain: the ordinary route under article 222 of the federal Code in the Abu Dhabi courts; or, where the judgment comes from one of the recognised courts, registration at ADGM followed by enforcement under article 13, paragraphs 13 and 15 — but only where the judgment was given on the merits and is not itself a recognition of someone else’s.

The asymmetry with the DIFC is at its sharpest here: what Dubai built through case law and preserved in statute, Abu Dhabi prohibits by statute.

ADGM’s five recognised foreign courts — and who is not on the list

The ADGM Chief Justice has used the section 171 power and made orders recognising five foreign courts. The list is published on the ADGM website in the memoranda section, and it is the only available confirmation that the section 171 mechanism operates in practice rather than only on paper.

Recognised foreign court	Date
The Commercial Court, Queen’s Bench Division, England and Wales	18 December 2016
The Supreme Court of the Republic of Singapore	8 March 2017
The High Court of the Hong Kong Special Admi­nistra­tive Region of the PRC	28 May 2017
The Supreme Court of New South Wales	28 May 2017
The Federal Court of Australia	28 May 2017

How the mechanism works

Section 171(1): where a country is not a party to an applicable treaty, the Chief Justice, being satisfied that “substantial reciprocity of treatment will be assured” as regards the recognition and enforcement in that country of ADGM Courts judgments, may — after consulting the Chairman of the ADGM Board — by order direct that the courts of that country be recognised foreign courts.

This is an administrative rather than a judicial procedure, and it is not set in motion by the parties to a dispute. A creditor cannot apply, within its own case, for the courts of its own country to be recognised.

Two material qualifications

First: the English recognition is narrow. The order names the Commercial Court, Queen’s Bench Division, not “the courts of England and Wales” at large. On the literal terms of the list, a judgment of the Chancery Division, of the King’s Bench Division outside the Commercial Court, of the County Court or of the Court of Appeal is not a judgment of a recognised foreign court.

The practical consequence: before filing at ADGM, check which court actually gave the judgment. An English judgment is not the same thing as a Commercial Court judgment.

Second: the United States is not on the list. Nor is there any UAE–US judgments treaty. A US judgment is therefore not a recognised court judgment under section 167(1)(g) on any of the three limbs, and falls outside Chapter 10.

A comparison worth holding on to: the very New York judgment for USD 171,769,169 that the DIFC Courts enforced in Barclays v Essar could not have been registered at ADGM at all.

What is not published

A note on primary-source availability: the Chief Justice’s orders themselves are not published — the page gives the names of the courts and dates, but no order numbers and no texts. Practice Direction 10 on Enforcement, in its 17 October 2025 version, does not mention section 171 and lists no countries.

Cite the ADGM page, therefore, rather than an order number. The page’s “Signed on” phrasing is unusual for a unilateral order, and the title “Queen’s Bench Division” has been superseded since September 2022 — treat the page as evidence that orders were made, not as a transcription of them.

The treaty limb

The second limb of the definition — courts of countries with applicable treaties — operates automatically, without any Chief Justice order. It brings within “recognised court” the courts of the states party to the Riyadh Agreement 1983 and the GCC Convention 1996, and those of France under the 1991 convention.

Abu Dhabi has no standing tribunal, and that is a structural difference

Abu Dhabi has no body equivalent to Dubai’s Conflict of Jurisdiction Tribunal: conflicts of jurisdiction are determined by the emirate’s own Court of Cassation, sitting in its ordinary three-judge composition. The Dubai tribunal created by Decree No. 29 of 2024 is confined by its subject matter to the Emirate of Dubai and does not extend to ADGM.

The provision that does the work

Article 7 of Abu Dhabi Law No. 6 of 2024 concerning the Judicial Department in the Emirate of Abu Dhabi: “The seat of the Court of Cassation is in the city of Abu Dhabi, its judgments are issued by three judges, and it has jurisdiction to determine the following matters: 1. appeals against judgments issued by the appellate courts and the other cases in which the law permits cassation; 2. conflicts of jurisdiction between the courts of the Emirate; 3. the accountability of members of the Executive Council and senior officials of the Emirate appointed by Emiri decrees…”

Law No. 6 of 2024 was issued on 12 June 2024; its article 69 provides for entry into force one month after publication in the Official Gazette.

Does “the courts of the Emirate” capture the ADGM Courts — and why the answer is yes

Article 7(2) speaks of “the courts of the Emirate” — محاكم الإمارة — and does not name the ADGM Courts. But the answer comes from ADGM’s own founding law rather than from that phrase.

Article 13(1) of Abu Dhabi Law No. 4 of 2013 as amended by Law No. 12 of 2020: “Without prejudice to the provisions of this law and the Global Market Regulations, the Global Market’s Courts shall be considered as courts of the Emirate, with jurisdiction over disputes and matters in accordance with the provisions of this law and the Global Market Regulations.” ADGM’s own guidance confirms it at paragraph 2(f): the law “confirms ADGM Courts’ status as courts of the Emirate”.

Read together, the two statutes yield the conclusion: the ADGM Courts are courts of the Emirate by express statutory provision, so conflicts between their jurisdiction and that of the onshore Abu Dhabi courts fall within article 7(2) and are resolved by the Court of Cassation. That is a construction rather than a decided point — but it rests on two express statutory texts, not on silence.

The contrast with Dubai survives, and it is institutional rather than terminological: Dubai created a standing mixed body that includes DIFC judges and issues binding precedent; Abu Dhabi left the question with an ordinary three-judge cassation bench on which no ADGM judge sits.

The mechanism for resolving divergent lines of authority

Article 9 of Law No. 6 of 2024 constitutes two chambers of nine judges each within the Court of Cassation — one for criminal matters, the other for civil, commercial, personal status and other matters. They are constituted by the Court’s General Assembly and presided over by the President of the Court or its most senior judge.

A reference lies only where a division of the Court of Cassation, already seised of a claim or an appeal, considers departing from a legal principle established by earlier judgments, or identifies conflicting principles previously issued by the Court. The matter is then referred to the President for the appeal to be placed before the competent chamber.

A decision to depart requires a majority of at least six members; the President may place the appeal before both chambers sitting jointly, in which case a departure requires a majority of thirteen.

Three points that are routinely lost in summaries. First, the deciding body is not the General Assembly but a nine-judge chamber constituted by it. Second, this is not a free-standing reference procedure — only a division already hearing a specific case can trigger it, and an abstract jurisdictional question cannot be referred. Third, article 9 contains no express provision making its rulings binding on all courts, unlike article 9(c) of Dubai’s Decree No. 29/2024.

Practice in 2026

A note on the unverified: there are reports that on 1 April 2026 a chamber of the Abu Dhabi Court of Cassation gave a ruling setting criteria for the jurisdiction of the ADGM Courts. Neither the ruling’s number nor its text could be confirmed against primary sources: the Abu Dhabi Judicial Department publishes judgments through a search service that is not reachable by automated access, and the emirate’s Official Gazette is not posted in open access.

The content of that ruling cannot be stated as established fact in this guide, and it is not stated here. Current cassation practice should be obtained directly before filing at ADGM or in the Abu Dhabi courts.

The structural conclusion

Dubai resolves jurisdictional conflicts through a standing mixed body with binding precedent; Abu Dhabi through an ordinary cassation court whose competence over the ADGM Courts is textually not beyond argument. For a creditor that translates into different degrees of predictability: in Dubai the route for resolving a conflict is known in advance, in Abu Dhabi it is not.

Interim relief in support of foreign proceedings

Both zone courts now grant interim relief in support of proceedings outside them — but they arrived there by different routes, three months apart, and they treat a connection to the zone differently. For a creditor this is a separate track, independent of recognition: assets can be frozen before there is any judgment to recognise.

The DIFC: three decisions in two years

Sandra Holding: (1) Sandra Holding Ltd (2) Nuri Musaed Al Saleh v (1) Fawzi Musaed Al Saleh and others, [2023] DIFC CA 003, 6 September 2023. The DIFC Court of Appeal set aside a worldwide freezing order and held that the DIFC Courts have no jurisdiction to grant one in support of foreign proceedings where there is no substantive claim within the gateways in article 5(A)(1)(a)–(d) of the former Judicial Authority Law.

Carmon: Carmon Reestrutura-engenharia E Serviços Técnios Especiais, (SU) LDA v Antonio Joao Catete Lopes Cuenda, [2024] DIFC CA 003, 26 November 2024. The Court of Appeal departed from Sandra Holding, putting the correctness of that decision in issue, and derived the jurisdiction from the recognition-and-enforcement power itself.

Carmon at paragraph 155: “Article 24 of the Court Law properly construed confers jurisdiction to entertain proceedings by way of an application for such relief as may be necessary to prevent its pre-emption by a dissipation of the assets of a prospective judgment debtor in proceedings in a foreign court whose judgment can be recognised and enforced in the DIFC Courts.”

Trafigura: (1) Trafigura PTE LTD (2) Trafigura India PTV LTD v (1) Mr Prateek Gupta (2) Mrs Ginni Gupta, [2025] DIFC CA 001, 22 September 2025. This answers the central question posed by Law No. 2/2025: whether the disappearance of article 24 killed the Carmon jurisdiction.

Paragraph 131: “Nothing in the 2025 Court Law affects the correctness of that proposition.” The jurisdiction to grant freezing orders in support of foreign proceedings survives, whether or not the defendant’s assets are in the DIFC.

Paragraph 134: “Article (15)4 will cover applications brought in the DIFC Courts which are related to proceedings ‘outside the DIFC’… This includes interim measures such as freezing orders.”

A note on the text: article 15(4) covers “Applications, claims, or current or future arbitral proceedings brought outside the DIFC” — the words are not confined to arbitration. At paragraph 135 the Court says expressly that it reached its conclusion “by reference to the text of the 2025 Court Law”, so this is a reading of the text rather than a purposive extension. At paragraph 136 it additionally adopts the public-policy reasons enunciated at [155] in Carmon: “Where their jurisdiction and powers are amenable to constructions supporting the rule of law in transnational trade and commerce, such constructions should be preferred.”

The Conflict of Jurisdiction Tribunal has confirmed the same position: in Navigator Middle East DMCC v Viladea Limited, Application No. 3 of 2026 of 29 June 2026, it held that article 15(4) confers on the DIFC Courts an independent jurisdiction to hear applications for interim relief connected with existing or future arbitration proceedings outside the DIFC.

ADGM: one decision, the same position

A17 v B17 & Others, [2025] ADGMCFI 0001, Justice Sir Andrew Smith, 21 February 2025. The ADGM Court of First Instance held that it has jurisdiction to grant worldwide freezing orders in support of foreign arbitral proceedings without personal jurisdiction over, or service on, the defendants: “Service is not a basis of jurisdiction in the ADGM, unlike in England.”

But the court did not discard the connection to the zone — it moved it from jurisdiction to discretion. Paragraph 126: “It is not an invariable requirement for this Court to make a WFO that the Respondent has assets in the ADGM, but it is a material consideration.” On the facts such connections were established, and that should shape how an application is planned.

The jurisdictional basis is section 41 of the ADGM Courts Regulations (interim relief where it is “just and convenient”) together with rule 71 of the Court Procedure Rules 2016; the power was described as “a natural ancillary power to the Court’s jurisdiction (and duty) to recognize and enforce New York Convention arbitration awards”.

A note on the date: commentary variously gives 21 February, 21 May and 7 July 2025. The sealed judgment records a hearing on 28–29 January 2025 and a decision on 21 February 2025; the anonymised version was re-issued on 4 April 2025 — which is where the divergence comes from.

Restraint towards the onshore courts: A22 and B22 v C22, [2025] ADGMCFI 0018, Justice Paul Heath KC, 13 August 2025, confirmed jurisdiction to grant anti-suit injunctions restraining proceedings in the onshore Abu Dhabi courts, but refused relief on the facts, citing comity among other considerations.

Where interim relief leaves matters

The material point: on interim relief the DIFC and ADGM are converging, while on the conduit they diverge. A creditor needing an urgent freeze before judgment has a workable tool in both zones — subject to the qualification that at ADGM the absence of assets in the zone bears on the court’s discretion. A creditor needing to route someone else’s judgment through a zone to onshore assets has such a tool only in Dubai, and in a narrowed form.

The three routes compared

A foreign judgment reaches assets in the UAE by one of three routes, and they differ not in speed but in what they demand and in which judgments they accept at all. The comparison below supplies the grounds for choosing before the first document is filed.

Parameter	Onshore courts (article 222)	DIFC Courts	ADGM Courts
Source of the rule	Federal Decree-Law No. 42/2022, arts. 222–225	Dubai Law No. 2/2025, arts. 30–33	ADGM Courts Regulations 2015, Ch. 10
Type of procedure	petition to the execution judge	application to the Court of First Instance	re­gistra­tion of the judgment
Which judgments are accepted	any foreign judgments and orders	foreign judgments; no express provision on court judgments	only judgments of recognised courts
Mo­ney-ju­dgment limit	none	none	money judgments only, excluding taxes, charges, fines
Reciprocity test	yes, art. 222(1)	no formal test	yes, via a Chief Justice order under s. 171
Treaty or order required	no	no	yes, one or the other
English judgments	yes, through reciprocity since the 2022 letter	yes	Commercial Court, Queen’s Bench Division only
US judgments	through reciprocity, proved case by case	yes — Barclays v Essar	no, outside Chapter 10
Juri­sdictio­nal-link requirement	none	for enforcement, yes (art. 31); for recognition, no	none for registration
Window to apply	not prescribed	not prescribed	six years (s. 173(1))
Time to decide	five working days	ordinary rules	ordinary rules
Language	Arabic, with certified translation	English	English
Le­galisa­tion	consular chain mandatory	not required on entry	not required on entry
Review of the merits	prohibited	prohibited (art. 31(7))	prohibited (s. 173(2)(b))
Conduit outbound	not applicable	preserved (art. 32), but via the Dubai Courts	expressly barred (art. 13, para. 14) — no executory formula
Accepting another conduit judgment	not addressed	not addressed	expressly barred (s. 172(2)(c))
Jurisdi­ctiona­l-conflict body	—	the Tribunal, Decree No. 29/2024, with binding precedent and two DIFC judges on the bench	a three-judge Abu Dhabi Court of Cassation bench, art. 7(2) of Law No. 6/2024, with no ADGM judge

Three conclusions from the table

First: ADGM is the narrowest on entry and the most closed on exit. The recognised-court requirement excludes everything but the five named courts and the treaty states; articles 13(14) and 172(2)(c) shut the conduit from both sides. In return, the rules inside the regime are predictable: a closed list of grounds for setting registration aside, a six-year window, and an express bar on merits review.

Second: the article 222 route is the widest in the judgments it accepts and the most demanding in documents. It takes any foreign judgment, including non-money judgments, but requires the full consular legalisation chain, an Arabic translation and a separate certificate of finality.

Third: the DIFC remains the only route where a foreign judgment can be recognised without a nexus — but reaching assets outside the DIFC now runs through the Dubai Courts under article 32. The saving compared with going straight to article 222 has narrowed.

ADGM fees

ADGM Courts fees are denominated in US dollars, not dirhams. Under the ADGM Courts Forms and Fees Reference Table, revision date 17 October 2025, an application to register the judgment of a recognised court other than a court of the UAE (Form CFI 27) is charged at 1% of the value of the judgment, minimum USD 100, maximum USD 20,000.

The 2025 change is substantial and cuts both ways: under the previous schedule, effective 2 January 2022, the rate was 2% but the cap was USD 3,000. The rate halved while the ceiling rose more than six-fold: registering a large money judgment became several times more expensive, and a small one cheaper.

Judgments of UAE courts go on a separate form, CFI 29, at the same 1% with a USD 100 minimum and USD 20,000 maximum for money judgments, and a flat USD 500 for non-money judgments.

A step-by-step algorithm for the creditor

The order of operations is dictated not by preference but by a sequence of cut-offs: each step either closes a route or leaves it open. Work through them in the order given — reversing them means paying to assemble documents for a route that the first step would have eliminated.

Step 1. Establish where the assets are. Assets inside the DIFC, assets inside ADGM and assets elsewhere in Dubai or Abu Dhabi are three different situations with different enforcement jurisdiction. Under article 31(2) of Law No. 2/2025 the DIFC Courts enforce only where execution is directed against an entity within the DIFC.

Step 2. Check whether a treaty applies. Article 225 of the federal Code and article 33 of Dubai Law No. 2/2025 both give priority to treaties. If the judgment comes from a state party to the Riyadh Agreement 1983, the GCC Convention 1996 or a bilateral agreement, the treaty’s conditions replace those in article 222.

Step 3. For the ADGM route, check whether the court is a recognised court. The test runs through the three limbs of section 167(1)(g): a UAE judicial authority; a court of a state with an applicable treaty; or a court named in a Chief Justice’s order. For an English judgment, what matters is not the country but the specific court: the Commercial Court, Queen’s Bench Division is recognised, the English courts at large are not.

Step 4. Check the nature of the judgment. For ADGM it must be a money judgment and must not be for taxes, charges of a like nature, fines or other penalties. The article 222 route carries no such limitation.

Step 5. Check that the judgment is not itself someone else’s conduit judgment. Section 172(2)(c) of the ADGM Regulations bars registration of a judgment given in proceedings founded on a judgment of a court in another country and having as their object the enforcement of that judgment. If what you hold is a recognition judgment rather than a judgment on the merits, ADGM needs the original.

Step 6. Check the window. For ADGM, six years from the date of the judgment or from the last judgment in appeal proceedings (section 173(1)). The article 222 route prescribes no filing deadline, but the general position on enforceability in the country of origin applies: condition 222(2)(d) requires the judgment to remain in force.

Step 7. Assemble and legalise the bundle. For the onshore route, the four-link consular chain plus a certified Arabic translation, plus a separate certificate of finality where the judgment does not state it. An apostille is not accepted. The representative’s power of attorney must be granted and legalised before filing.

Step 8. Check for parallel onshore proceedings. The Conflict of Jurisdiction Tribunal’s practice is consistent: absent parallel Dubai proceedings, DIFC recognition stands; where they exist, the DIFC proceedings are stopped. Filing in a zone court while a Dubai case is already running creates a conflict that will not be resolved in your favour.

Step 9. Consider interim relief before filing. Interim relief is available in both zones in support of foreign proceedings — Trafigura in the DIFC, A17 v B17 at ADGM. At ADGM the presence of assets in the zone is not a condition of jurisdiction, but under paragraph 126 of A17 v B17 it “is a material consideration” in the exercise of discretion. This step precedes recognition and often decides whether there is anything left to execute against by the time recognition arrives.

Step 10. File, and do not treat the five days as the timetable. The five working days in article 222(2) are the time to issue an order on a complete file. Clause 3 of the same article lets the judge call for documents, and in practice that is what sets the real duration.

Step 11. To take execution outside the zone, satisfy the five conditions in article 32. Final and executory; official Arabic translation; executory formula affixed; an official letter from the DIFC Courts to the Dubai Courts requesting deputisation; and payment of the Dubai Courts’ fees. Missing any one returns the file to the previous stage.

Step 12. Establish where the money physically sits. A recognised judgment with no account to execute against remains paper. Which banks, what they require and where zone structures are actually banked is covered in the guide to opening a corporate bank account in the UAE.

Common mistakes and what they cost

Errors in this field almost always come from a stale source or from carrying a rule across a level boundary, and the cost is measured not in losing on the merits but in refusal on form. Eight recur more than the rest.

Mistake 1. Citing article 7 of Dubai Law No. 12 of 2004 as a live provision

Dubai Law No. 12 of 2004 was repealed by article 43(A) of Dubai Law No. 2 of 2025. Article 7, on which DNB was built, is no longer law.

The cost is an application resting on a provision that does not exist. The problem is compounded because Part 45 of the Rules of the DIFC Courts still cites articles 7(2) and 7(3), and the DIFC Courts’ own “Legal Framework” page had not been updated when this guide was prepared. The stale references have to be converted into articles 30 to 33 of Law No. 2/2025 by the reader.

Mistake 2. Reading article 222(2)(a) from the official English translation

The English text drops the word “exclusively” that appears in the Arabic, so the condition reads as a bar on enforcement wherever the UAE courts have any jurisdiction.

The cost is abandoning a viable case. A creditor whose debtor lives in the UAE concludes from the English text that the route is closed and never files — whereas on the Arabic text, and on Cassation No. 339/2023, concurrent jurisdiction is no bar.

Mistake 3. Apostilling documents instead of consular legalisation

The UAE is not a party to the Hague Convention of 1961, and an apostille does not substitute for consular legalisation.

The cost is weeks lost and the whole bundle redone. An apostille is quick and cheap; the four-link consular chain takes substantially longer. Discovering the error at the filing stage means starting legalisation again while the judgment’s enforceability in its country of origin continues to run.

Mistake 4. Assuming the DIFC Courts will enforce where there are no DIFC assets

The Tribunal’s decision in Application No. 1 of 2026 expressly confined the DIFC execution judge’s jurisdiction to cases where a sufficient enforcement link exists within the DIFC. Recognition needs no nexus; enforcement does.

The cost is fees and months spent on a procedure that ends in a ruling of no jurisdiction. DNB Bank’s “no assets required” holding concerned recognition; it cannot be extended to enforcement after April 2026.

Mistake 5. Using ADGM as a conduit

Article 13, paragraph 14 of Law No. 4/2013 prevents an ADGM judgment recognising a foreign one from being taken out, and section 172(2)(c) of the Regulations prevents someone else’s conduit judgment from being registered in. Recognition itself remains formally available — the Registry simply will not affix the executory formula.

The cost is paying twice. The creditor pays the ADGM registration fee at 1% of the judgment value (up to USD 20,000), is refused, and then runs the article 222 route in the onshore Abu Dhabi courts from the beginning.

Mistake 6. Treating ADGM’s recognition of England as covering all English courts

The Chief Justice’s order names the Commercial Court, Queen’s Bench Division, not the courts of England and Wales at large.

The cost is a judgment that falls outside Chapter 10. A Chancery Division or Court of Appeal judgment is not, on the literal terms of the list, a judgment of a recognised court, so there is nothing to register — not a refusal on the merits, but the absence of any subject matter.

Mistake 7. Filing in a zone court while Dubai proceedings are already running

The Tribunal’s practice is consistent: where parallel Dubai proceedings exist, the DIFC proceedings are stopped.Since 2024, article 9(c) of Decree No. 29/2024 makes the Tribunal’s rulings binding on the DIFC Courts.

The cost is a stay and the loss of momentum. A referral to the Tribunal itself stays both the proceedings and the enforcement (article 7 of Decree No. 29/2024), and on failure the AED 3,000 security deposit is forfeited to the prevailing court.

Mistake 8. Treating reciprocity with the United Kingdom as settled once and for all

Reciprocity rests not on a treaty but on the Ministry of Justice letter of 13 September 2022 and on the state of English practice. The 2006 bilateral treaty (Cm 7185) covers service of documents and the taking of evidence, not the recognition of judgments.

The cost is a strategy built on an administrative direction as though it were a rule of law. An Emirati court still tests reciprocity in each case under article 222(1); the Ministry’s direction eases that test but does not remove it.

Mistake	The provision that prevents it	The point at which it is still free to fix
Citing article 7 of Law No. 12/2004	article 43(A) of Law No. 2/2025	before the application is drafted
Reading article 222(2)(a) from the translation	the Arabic text; Cassation No. 339/2023	when the route is chosen
Apostille instead of legalisation	the UAE is outside the Hague Convention 1961	before legalisation begins
Enforcement in the DIFC with no link	article 31(2); Application No. 1/2026	before filing in the DIFC Courts
ADGM as a conduit	art. 13, para. 14; section 172(2)(c)	when the route is chosen
“All English courts” at ADGM	section 167(1)(g) and the section 171 list	before the Form CFI 27 fee is paid
Filing while a parallel case runs	the Tribunal’s practice; article 9(c) of Decree No. 29/2024	before filing in a zone court
Reciprocity taken for granted	article 222(1); the letter of 13.09.2022	when currency is checked before filing

Which route suits whom, and when professional review is required

The choice of route turns on three variables: which court gave the judgment, where the assets are, and whether the judgment is for money. Three profiles follow, and a list of situations in which deciding alone is not an option.

Whom the article 222 route suits

A creditor holding a judgment from a state that has a treaty with the UAE. Article 225 gives the treaty priority, and the treaty’s conditions replace those in article 222. This is the most predictable option available.

A creditor with a non-money judgment. Section 171(2) of the ADGM Regulations confines that regime to money judgments, which puts the Abu Dhabi zone route out of reach for orders for specific performance or injunctive relief.

A creditor whose assets are in onshore Dubai or Abu Dhabi and who gains nothing from an intermediate stage.Since April 2026, execution outside the DIFC runs through the Dubai Courts in any event — going straight to article 222 is shorter.

It does not suit anyone without the resources to complete consular legalisation to a deadline. The four-link chain plus a certified Arabic translation is the longest part of the preparation.

Whom the DIFC route suits

A creditor who needs recognition without a jurisdictional connection. Recognition in the DIFC requires no nexus, and that remains the route’s distinguishing feature after the 2025 reform.

A creditor with a US judgment. Barclays v Essar confirms directly that a New York judgment is enforceable in the DIFC, whereas at ADGM a US judgment falls outside Chapter 10 altogether.

A creditor whose assets are inside the DIFC. There the recognition jurisdiction and the enforcement jurisdiction coincide, and no intermediate stage arises.

It does not suit where parallel Dubai proceedings are already running. The Tribunal’s practice in that situation is consistent and unfavourable to the zone route.

Whom the ADGM route suits

A creditor with a money judgment from one of the five recognised courts, or from a treaty state, whose assets are in Abu Dhabi. Inside the regime the rules are predictable: a closed list of grounds for setting registration aside, a six-year window and an express bar on merits review.

A creditor who values procedural certainty over breadth. The 1933 scheme gives registration rather than an action, and the deemed bases of jurisdiction in section 175(2) are known in advance.

It does not suit anyone trying to route a foreign judgment towards assets outside ADGM — article 13, paragraph 14 and section 172(2)(c) close that expressly, and a recognition without the executory formula does not travel.

It does not suit US judgments, or judgments of English courts other than the Commercial Court, Queen’s Bench Division.

When professional review is mandatory

Situation	What is reviewed	Why it cannot be settled unaided
The debtor is a zone entity, the assets are outside the zone	enforcement jurisdiction under art. 31(2) and the art. 32 route	since Application No. 1/2026 recognition and enforcement are separated; the error costs months
A judgment of an English court	which court in fact gave it	only the Commercial Court, Queen’s Bench Division is recognised; at ADGM this is a cut-off criterion
A recognition judgment rather than one on the merits	the application of s. 172(2)(c) of the ADGM Regulations	someone else’s conduit judgment is not registrable at ADGM
Parallel proceedings in an onshore court	the risk of a referral to the Conflict of Jurisdiction Tribunal	a referral stays both the proceedings and the enforcement
A treaty state	which treaty, and in which version	the treaty displaces article 222 entirely, reciprocity test included
Reciprocity with a non-treaty jurisdiction	the current state of practice on both sides	the article 222(1) test is applied afresh in each case
A judgment against a group of companies	where the asset to be executed against actually is	enforcement jurisdiction follows the object of execution, not the debtor
A debtor in an insolvency procedure	the priority of the insolvency stay	the DIFC and ADGM insolvency regimes differ from the federal one

That last point deserves separate attention: a recognised judgment competes with other creditors inside an insolvency procedure rather than outside it, and DIFC and ADGM companies do not fall under the federal regime.The federal regime is analysed in the guide to bankruptcy and insolvency in the UAE.

If you are assessing whether a foreign judgment can be enforced in the UAE, or preparing a defence against such an application — start with a review of the structure and the jurisdiction: the route, the timetable and the document set all depend on which court gave the judgment and where the asset to be executed against physically sits, and they should be settled before the first document is filed.

Frequently asked questions

How long does it take to have a foreign judgment recognised in the UAE? The execution judge issues an order within five working days of the petition being filed — that is the limit in article 222(2) of the Civil Procedure Code.The real duration is longer: clause 3 of the same article lets the judge call for supporting documents before deciding, and in practice that is what governs. Time for consular legalisation, which precedes filing, has to be budgeted separately.

Is a treaty between the UAE and the country of origin required? No, a treaty is not required: in its absence the reciprocity test in the chapeau of article 222(1) applies. But a treaty, where one exists, takes priority under article 225 and replaces the article 222 conditions. The UAE is a party to the Riyadh Agreement 1983 and the GCC Convention 1996, and has a bilateral convention with France signed on 9 September 1991.

Are English judgments enforced in the UAE? Yes, and the basis is reciprocity rather than treaty. The 2006 bilateral treaty (Cm 7185) covers the service of documents and the taking of evidence, not the recognition of judgments. The practical shift followed the UAE Ministry of Justice letter of 13 September 2022 to the Director of the Dubai Courts, which relied on the English courts having enforced a Dubai judgment.

Are US judgments recognised? In the DIFC Courts, yes: Barclays Bank PLC & others v Essar Global Fund Limitedconfirmed the enforceability of a New York judgment for USD 171,769,169. At ADGM, no: the United States appears neither on the section 171 list of recognised foreign courts nor among the treaty states, so a US judgment falls outside Chapter 10 of the Regulations. In the onshore courts a US judgment runs through the general reciprocity test in article 222(1).

What is a conduit jurisdiction, and does it still work? A conduit jurisdiction means using the DIFC Courts to recognise a foreign judgment and then passing it to the onshore Dubai courts for execution; the concept was articulated by the DIFC Court of Appeal in DNB Bank ASA v Gulf Eyadah Corporation on 25 February 2016. The mechanism survives in article 32 of Dubai Law No. 2 of 2025, but it has narrowed: under the Conflict of Jurisdiction Tribunal’s decision of 20 April 2026, the DIFC Courts may not enforce where there is no DIFC link, and execution outside the zone runs through the Dubai Courts.

Can the ADGM Courts be used as a conduit jurisdiction? No, and the bar is a double one, operating in both directions. Article 13, paragraph 14 of Abu Dhabi Law No. 4 of 2013 as amended by Law No. 12 of 2020 prevents an ADGM judgment recognising a foreign one from being taken out; ADGM’s own guidance puts it directly: “parties cannot use ADGM for the enforcement of non-ADGM judgments and awards in other jurisdictions.” Section 172(2)(c) of the Courts Regulations closes the opposite direction — registering someone else’s conduit judgment at ADGM. The mechanism matters: the ADGM Courts can still recognise a foreign decision even with no assets in the zone, but the Registry will not affix the executory formula to the resulting judgment for enforcement in other jurisdictions.

Is an apostille enough to file documents with a UAE court? No. The UAE is not a party to the Hague Convention of 1961, and an apostille is not accepted. Full consular legalisation is required: notarisation, certification by the country of origin’s ministry of foreign affairs, certification by the UAE embassy or consulate, and certification by the UAE Ministry of Foreign Affairs, plus a certified Arabic translation. The DIFC and ADGM Courts work in English, and translation is needed there only at the stage of taking execution to an onshore court.

Does the debtor living in the UAE prevent enforcement? No. The Dubai Court of Cassation in Appeal No. 339/2023, decided on 15 August 2024, held that concurrent jurisdiction does not by itself prevent enforcement.Refusal is available only where the UAE courts have exclusive jurisdiction. Note that the official English translation of article 222(2)(a) drops the word “exclusively” that appears in the Arabic original; where the versions conflict, the Arabic prevails.

How long does a creditor have to apply? At ADGM, six years from the date of the judgment or from the last judgment in appeal proceedings, under section 173(1) of the Regulations. The article 222 route in the federal Code prescribes no filing deadline, but condition 2(d) requires the judgment to retain the force of res judicata under the law of the court that gave it.

Does a UAE court review the foreign judgment on the merits? No, and this is stated expressly on all three routes.Article 31(7) of Dubai Law No. 2/2025 bars the DIFC execution judge from reviewing the merits; article 32(B) of the same law bars the Dubai Courts’ execution judge from doing so; section 173(2)(b) of the ADGM Regulations provides that the Court of First Instance “will not re-examine the merits of the judgment”. In the onshore courts the same conclusion follows from the closed list of conditions in article 222(2) and from the five-day timetable.

Key points to carry away

•          The federal instrument in force is Federal Decree-Law No. 42 of 2022 on the Civil Procedure Code, issued 3 October 2022 and in force from 2 January 2023. The recognition provisions are articles 222 to 225. The Code’s only amendment, the decree-law of 1 October 2025, touched articles 32, 164, 175 and 176 and does not reach articles 222 to 225.

•          A foreign judgment is enforced by petition to the execution judge, who issues an order within five working days and verifies six conditions without reopening the merits. The predecessor provision allowed three days; five working days is the 2022 rule.

•          Reciprocity sits in the chapeau of article 222(1) and is a condition logically prior to the six that follow.

•          The official English translation of article 222(2)(a) drops the word “exclusively” that appears in the Arabic original, and where the versions conflict the Arabic prevails. Dubai Cassation No. 339/2023, decided 15 August 2024, confirmed that concurrent jurisdiction is no bar to enforcement.

•          The UAE is a party to neither the Hague Choice of Court Convention 2005, nor the Hague Judgments Convention 2019, nor the Apostille Convention 1961. Full consular legalisation is required.

•          Dubai Law No. 2 of 2025, issued 3 March 2025, repealed both Dubai Law No. 12 of 2004 and DIFC Law No. 10 of 2004 — the two provisions on which DNB Bank v Gulf Eyadah was built. Article 24 has no direct successor in the new statute.

•          The conduit survives in article 32 of Law No. 2/2025, but article 31 requires a DIFC link for enforcement.The Tribunal separated recognition from enforcement twice: in Application No. 1 of 2026 (20 April 2026) for arbitral awards and in Application No. 4 of 2026 (6 July 2026) for court judgments, holding that articles 30 and following “do not confer upon the DIFC Execution Judge a general or unrestricted jurisdiction over all assets of a judgment debtor wherever situated”.

•          The Conflict of Jurisdiction Tribunal was not abolished but renamed and restructured by Dubai Decree No. 29 of 2024; article 9(c) made its rulings binding precedents for all judicial entities, the DIFC Courts included.

•          ADGM is closed to the conduit from both sides: article 13, paragraph 14 of Law No. 4/2013 stops a judgment getting out, and section 172(2)(c) of the Regulations stops someone else’s conduit judgment getting in. The bar works not by refusing recognition but by the Registry refusing to affix the executory formula.

•          Article 13(1) of Law No. 4/2013 expressly classifies the ADGM Courts as “courts of the Emirate” — so conflicts between their jurisdiction and that of the onshore Abu Dhabi courts fall within article 7(2) of Law No. 6 of 2024.

•          Chapter 10 of the ADGM Courts Regulations reproduces the English 1933 scheme: registration of money judgments of recognised courts, a six-year window, a closed list of grounds for setting registration aside, and an express bar on merits review.

•          ADGM has five recognised foreign courts, and the English recognition covers only the Commercial Court, Queen’s Bench Division; the United States is not on the list.

•          Abu Dhabi has no standing jurisdictional-conflicts tribunal: conflicts are resolved by a three-judge Court of Cassation bench under article 7(2) of Law No. 6 of 2024, and divergent lines of authority by a nine-judge chamber under article 9. No ADGM judge sits on either — unlike the Dubai tribunal.

•          Interim relief in support of foreign proceedings is available in both zones without a jurisdictional connection requirement, though at ADGM the absence of assets in the zone bears on discretion — Trafigura [2025] DIFC CA 001 of 22 September 2025 and A17 v B17 [2025] ADGMCFI 0001 of 21 February 2025.

Summary

Recognition and enforcement of foreign judgments in the UAE is regulated on three independent levels. The federal level is articles 222 to 225 of Federal Decree-Law No. 42 of 2022 on the Civil Procedure Code, issued 3 October 2022 and in force from 2 January 2023: the application is made by petition to the execution judge, who issues an order within five working days, verifies six conditions and may not reopen the merits; the reciprocity requirement sits in the chapeau of article 222(1); and article 225 gives priority to treaties. The official English translation of condition (a) drops the word “exclusively” present in the Arabic original, and where the versions conflict the Arabic prevails — as the Dubai Court of Cassation confirmed in Appeal No. 339/2023 on 15 August 2024. The UAE is party to neither the Hague Conventions of 2005 and 2019 nor the Apostille Convention 1961, so full consular legalisation and a certified Arabic translation are required. The zone level has changed entirely: Dubai Law No. 2 of 2025, issued 3 March 2025 and in force from 15 March 2025, repealed Dubai Law No. 12 of 2004 and DIFC Law No. 10 of 2004, preserving the conduit in article 32 but tying the DIFC execution judge’s jurisdiction to a sufficient enforcement connection with the DIFC under article 31; and the Conflict of Jurisdiction Tribunal, in Application No. 1 of 2026 of 20 April 2026 and Application No. 4 of 2026 of 6 July 2026, separated recognition from compulsory enforcement for arbitral awards and court judgments alike. At ADGM the conduit is expressly barred from both sides — by article 13, paragraph 14 of Abu Dhabi Law No. 4 of 2013 as amended by Law No. 12 of 2020, and by section 172(2)(c) of the Courts Regulations 2015, the bar operating through the Registry’s refusal to affix the executory formula rather than through a refusal to recognise — while Chapter 10 permits registration only of money judgments of recognised courts, of which there are five, with a six-year window under section 173(1) and a fee of 1% of the judgment value subject to a minimum of USD 100 and a maximum of USD 20,000 under the fee table revised on 17 October 2025.

Sources

Primary sources — legislation, judgments and official publications of the authorities and courts.

1.        Federal Decree-Law No. 42 of 2022 on the Civil Procedure Code — UAE Legislation portal

2.        Federal Decree-Law No. 42 of 2022, Arabic text — the authentic version

3.        Amendments to the Civil Procedure Code — UAE Legislation portal

4.        Federal Law No. 8 of 2004 concerning Financial Free Zones — UAE Legislation portal

5.        Dubai Law No. 2 of 2025 concerning the Dubai International Financial Centre Courts — Dubai Legislation portal

6.        Dubai Law No. 12 of 2004 concerning the Judicial Authority at DIFC — repealed, cited for the history

7.        Dubai Decree No. 29 of 2024 concerning the Judicial Committee for Resolving Conflicts of Jurisdiction — Dubai Legislation portal

8.        Dubai Decree No. 19 of 2016 — superseded, cited for the history

9.        Conflict of Jurisdiction Tribunal — official website

10.    Electronic registry of the Conflict of Jurisdiction Tribunal’s decisions — source of the decision in Application No. 1 of 2026

11.    Conflict of Jurisdiction Tribunal, Application No. 4 of 2026, Zaya Living Real Estate Development LLC v China State Construction Engineering Corporation (Middle East), 6 July 2026 — Conflict of Jurisdiction Tribunal

12.    DNB Bank ASA v Gulf Eyadah Corporation and Gulf Navigation Holdings PJSC, [2015] DIFC CA 007 — DIFC Courts

13.    Trafigura PTE LTD and others v Gupta, [2025] DIFC CA 001 — DIFC Courts

14.    Rules of the DIFC Courts, Part 45 — enforcement of judgments — DIFC Courts

15.    ADGM Courts Regulations 2015, consolidated 17 October 2025 — ADGM

16.    Abu Dhabi Law No. 4 of 2013 concerning Abu Dhabi Global Market — ADGM

17.    Abu Dhabi Law No. 12 of 2020 amending Law No. 4 of 2013 — ADGM

18.    ADGM Guide to amendments to Article 13 of Abu Dhabi Law No. 4 of 2013 — ADGM, official guidance on the 2020 reform

19.    Federal Decree No. 15 of 2013 — ADGM

20.    ADGM Courts’ memoranda of understanding and the Chief Justice’s directions on recognised foreign courts — ADGM

21.    ADGM Courts Practice Direction 10 on Enforcement, 17 October 2025 — ADGM

22.    ADGM Courts Forms and Fees Reference Table, revised 17 October 2025 — ADGM

23.    ADGM Courts judgments — source of A17 v B17, [2025] ADGMCFI 0001

24.    Lenkor Energy Trading DMCC v Puri, [2021] EWCA Civ 770 — The National Archives

25.    Lenkor Energy Trading DMCC v Puri, [2020] EWHC 75 (QB) — The National Archives

26.    Treaty between the UK and the UAE on Judicial Assistance in Civil and Commercial Matters, Cm 7185 — UK Government

27.    Notification G.S.R. 38(E) of 17 January 2020 — The Gazette of India: Extraordinary

28.    Status table of the Apostille Convention 1961 — Hague Conference on Private International Law

29.    Status table of the Choice of Court Convention 2005 — Hague Conference on Private International Law

30.    Status table of the Judgments Convention 2019 — Hague Conference on Private International Law

31.    Riyadh Arab Agreement for Judicial Cooperation 1983 — text of the agreement

32.    Abu Dhabi Law No. 6 of 2024 concerning the Judicial Department in the Emirate of Abu Dhabi — Official Gazette scan

33.    Abu Dhabi Judicial Department: publication of judgments — ADJD

Disclaimer

This material is provided for information only and does not constitute legal, tax, financial, investment or consulting advice. Before taking any decision you must obtain individual professional advice that takes into account the specific situation, the jurisdiction, the status of the company and the current requirements of the regulators.

Date of publication: September 2026.