Enforcing a Foreign Judgment in the UAE: Conditions, Reciprocity, and the Execution Route

A foreign judgment has no effect in the UAE until an execution judge orders its enforcement, and the application is decided on conditions rather than on the merits of the original claim. This article explains the statutory conditions, the treaty and reciprocity routes, the documents required, and the grounds on which enforcement is refused.

Can a foreign court judgment be enforced in the UAE?

–Yes, where the judgment satisfies the conditions in Article 222 of the Civil Procedure Law

Enforcement proceeds through the execution judge rather than through a fresh claim. The creditor files an application, the judge examines whether the statutory conditions are met, and an order follows within a short statutory period. The court does not retry the dispute. What it examines is whether the foreign court had jurisdiction, whether the defendant was properly summoned, whether the judgment is final, and whether enforcing it would conflict with UAE public order. Where a treaty covers the issuing country, the treaty takes priority over the domestic conditions.

• The application goes to the execution judge. Article 222 of Federal Decree-Law No. 42 of 2022 requires the judge to decide within five working days, with an appeal available within 30 days.
• Treaties displace the domestic test. The GCC Convention of 1996, the Riyadh Arab Agreement of 1983, and bilateral treaties with states including India, China and France apply in priority where the issuing country is covered.
• Reciprocity with England is now established. The Ministry of Justice confirmed on 13 September 2022 that the English decision in Lenkor Energy Trading DMCC v Puri satisfies the reciprocity condition.
• Arbitral awards follow a different route. Article 223 and the New York Convention govern awards, read with Federal Law No. 6 of 2018, and the grounds for refusal are narrower.
• The merits are closed. A debtor cannot reopen the underlying dispute at the enforcement stage, which is why most refusals turn on jurisdiction, service or public order.

Who this applies to

This article is written for foreign law firms and in-house counsel holding a judgment against a debtor with assets in the UAE, and for judgment debtors facing an enforcement application. It covers judgments of foreign national courts enforced through the onshore UAE courts, and the alternative route through the DIFC Courts.

Foreign counsel instructing UAE lawyers will find the practical requirements in the documents section below, including the power of attorney and translation formalities that frequently delay a filing. Our dispute resolution lawyers in the UAE act as local counsel on enforcement applications and defend them.

Enforcement of an arbitral award is a separate process with its own conditions, covered in our article on enforcing a foreign arbitral award in the UAE.

The legal framework

Three layers govern the question. The order matters, because a treaty displaces the domestic conditions where it applies.

• Federal Decree-Law No. 42 of 2022 on Civil Procedure, Articles 222 to 225, which set the conditions, the procedure, and the priority of international agreements
• Article 212, which classifies foreign judgments ordered for execution among the writs of execution and governs the execution file itself
• The GCC Convention for the Execution of Judgments, Delegations and Judicial Notifications 1996, covering judgments of Gulf Cooperation Council member states
• The Riyadh Arab Agreement for Judicial Cooperation 1983, covering most Arab League states
• Bilateral judicial cooperation treaties, including those with India, China, France, Egypt, Jordan and Kazakhstan
• Federal Decree-Law No. 25 of 2025 on Civil Transactions, which supplies the public order principles the court applies at the refusal stage

The deciding bodies:

• The execution judge at the competent onshore court, who decides the enforcement application
• The Court of Appeal, which hears a challenge to the execution judge's decision
• The DIFC Courts, which can recognise a foreign judgment under their own rules, after which it is transferred to the Dubai Courts for execution

The conditions in Article 222

Where no treaty applies, the execution judge examines a closed list of conditions. Each must be satisfied, and the creditor carries the burden of showing that it is.

Jurisdiction

The UAE courts must not have exclusive jurisdiction over the dispute, and the foreign court must have had jurisdiction under its own rules of international competence. Exclusive UAE jurisdiction attaches to several categories, including disputes over real property situated in the UAE.

Proper summons and representation

The parties must have been duly summoned and properly represented in the foreign proceedings. A default judgment is enforceable, but the creditor has to produce evidence that service was effected in accordance with the law of the issuing state.

Finality

The judgment must have acquired the force of res judicata under the law of the court that issued it. A judgment still open to ordinary appeal does not qualify, and a certificate of finality from the issuing court is the standard proof.

No conflicting UAE decision

The judgment must not conflict with a judgment or order already issued by a UAE court, and must not contain anything contrary to public order or morals in the UAE.

Reciprocity

The issuing country must enforce UAE judgments on equivalent terms. This is the condition that defeats applications from jurisdictions with no treaty and no demonstrated practice of enforcing UAE judgments.

Why the English position changed in 2022

No treaty exists between the UAE and the United Kingdom for the mutual recognition of civil judgments, and the reciprocity condition was for many years the obstacle to enforcing an English judgment onshore.

That changed through a decision of the English courts. In Lenkor Energy Trading DMCC v Puri the English High Court enforced a judgment of the Dubai Courts arising from dishonoured cheques, and the Court of Appeal upheld the decision. The English court held that enforcing the Dubai judgment was not contrary to English public policy.

On 13 September 2022 the Director of International Cooperation at the UAE Ministry of Justice wrote to the Director General of the Dubai Courts. The letter stated that the reciprocity principle was satisfied. The reasoning was that the English courts had enforced a Dubai judgment in a decision binding on all English courts under their system of precedent. It requested the Dubai Courts to act accordingly on applications to enforce English judgments and orders.

Reciprocity alone is not enough. The circular addresses one condition. An English judgment must still satisfy the jurisdiction, service, finality, conflict and public order conditions, and a judgment awarding interest in a form the court treats as contrary to public order remains vulnerable.

The circular is a direction to the Dubai Courts rather than legislation, and it does not bind courts in other emirates. Where a creditor has a choice of emirate, that distinction is worth weighing before filing.

The documents a foreign creditor must produce

Most delays at the filing stage are documentary rather than legal. The application requires:

• A certified copy of the judgment, issued by the foreign court rather than by the creditor's lawyers
• A certificate of finality confirming that the judgment is no longer open to ordinary appeal under the law of the issuing state
• Proof of service where the judgment was given in default, showing that the defendant was notified in accordance with that law
• Legalisation of each document through the foreign ministry of the issuing state and the UAE embassy, or an apostille where the issuing state and the UAE both accept it
• A certified Arabic translation prepared by a translator licensed in the UAE, since the courts accept no other translation
• A notarised and legalised power of attorney in favour of the UAE lawyers, which takes longer to obtain than any other document

Foreign counsel should start the power of attorney and legalisation chain before the judgment is final, because those steps proceed in parallel with nothing else.

The procedure and the timetable

Filing and decision

The creditor files a petition with the execution judge at the competent court, pays the court fee, and the judge examines the conditions. Article 222 requires the decision within five working days of the application. The decision may be challenged before the competent appeal court within 30 days of notification.

An uncontested application concludes within three to six months from instruction in most cases. The legalisation and translation chain accounts for most of that period rather than the court.

Execution

An order for enforcement places the judgment in the ordinary execution system. The execution judge can then attach bank accounts through a single electronic order reaching all licensed banks, attach property and receivables, and impose a travel ban on a corporate debtor's manager. The mechanics are covered in our article on enforcing a UAE court judgment through the Execution Court.

The file can lapse. Where the creditor takes no step for more than a year, the execution judge may close the file temporarily, and a writ left unexecuted for 15 years can no longer be enforced.

The DIFC route

A foreign creditor may instead seek recognition in the DIFC Courts, which apply common law principles and conduct proceedings in English, then transfer the recognised judgment to the Dubai Courts for execution. Our article on enforcing a DIFC judgment in mainland Dubai covers that transfer and its current limits.

Common reasons enforcement is refused

The same objections recur, and a creditor that anticipates them before filing avoids most of the delay.

The judgment was not final. A judgment subject to an outstanding appeal, or one described as provisionally enforceable in its home jurisdiction, does not meet the res judicata condition. The finality certificate is the document that resolves this, and obtaining it late is a frequent cause of adjournment.

Service in the foreign proceedings was defective. Default judgments attract the closest scrutiny. A creditor that cannot evidence service in accordance with the law of the issuing state should expect refusal.

The UAE courts had exclusive jurisdiction. Disputes over UAE real property and certain matters reserved to the UAE courts cannot be decided abroad and then enforced here.

Public order. This is the broadest ground and the least predictable. Awards of interest in a form the court treats as usurious, and judgments inconsistent with principles the courts treat as fundamental, are the recurring examples.

A conflicting UAE judgment exists. Where the debtor obtained a UAE judgment on the same subject matter, the foreign judgment cannot be enforced against it. A debtor anticipating enforcement sometimes files onshore for exactly that reason, which is an argument for moving quickly.

Reciprocity could not be shown. For states with no treaty and no record of enforcing UAE judgments, this remains the hardest condition to satisfy.

What a foreign law firm should prepare

• Confirm the debtor has UAE assets before instructing. Enforcement costs money and a judgment against an entity with no bank balances, property or receivables produces nothing.
• Obtain the finality certificate early. It is the document most frequently missing at the first hearing, and the easiest to secure in advance.
• Start legalisation immediately. The chain through the foreign ministry and the UAE embassy, or the apostille route where available, is the longest element of the timetable.
• Instruct a UAE-licensed translator. Translations prepared abroad are not accepted, and a rejected translation restarts the filing.
• Prepare the power of attorney in the required form. It must be notarised in the home jurisdiction and legalised for use in the UAE, and it must authorise execution proceedings specifically.
• Consider precautionary attachment at the outset. Security obtained before the debtor is on notice is worth more than an enforcement order obtained after the accounts are empty.

Where the underlying contract was governed by English law, the drafting decisions that affect enforceability are covered in our article on English law clauses in UAE contracts after the DIFC reforms. Where the claim remains unlitigated, the onshore recovery routes are compared in our guide to recovering unpaid trade debts in the UAE.

How long does it take to enforce a foreign judgment in the UAE?

Three to six months from instruction where the application is uncontested and the documents are in order, and considerably longer where the debtor challenges the order and appeals it. The court's own part is quick, because Article 222 requires a decision within five working days. The time is spent assembling documents in a form the court accepts.

The single thing that most often goes wrong is the documentary chain. A certified copy without a finality certificate, a translation prepared outside the UAE, or a power of attorney that does not extend to execution proceedings will each cost a filing cycle. Foreign counsel who treat these as administrative and leave them to the end lose more time than any legal argument costs.

The commercial consequence follows from the debtor's position rather than the creditor's paperwork. A debtor who learns that enforcement is coming has time to move funds, and the UAE banking system allows that to happen quickly. Where the facts support it, precautionary attachment before the debtor is notified is worth more than every other step in the process.

For foreign law firms and judgment creditors enforcing against UAE assets, our litigation and dispute resolution team acts as local counsel on enforcement petitions, precautionary attachment and asset identification. We handle execution proceedings across the onshore courts and the DIFC.