With a favourable court ruling at hand, I can finally enforce my claim against my debtor: but how can I do if my debtor resides or operates in the UAE: how can I ensure that my claim will be ultimately satisfied?

Our clients (whether companies or individuals) are often seeking legal guidance on the above.

Our analysis aims to clarify steps (and methods) to be taken into account to recover a debt against one or more debtors who/which reside and/or operate in the UAE, whenever such debt is crystallised in a “foreign” court decision (hereinafter, the “Judgment”).

In particular, we will clarify whether, and how, the Judgment can be recognised by the local UAE authorities and courts, and what enforcement solutions may be available against the debtor.

All of this, bearing in mind that the UAE courts have jurisdiction over the enforcement of the Judgement in so far one or more criteria set under the local civil procedural code (Federal Decree Law No. 42 2022 – the “UAE CPC”) are satisfied[1].

At the outset, it is worth mentioning that UAE is currently party to a limited number of multilateral/bilateral agreements with foreign countries and is not a signatory party to the Hague Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters[2].

Lacking a bilateral treaty or an international convention between the country of issuance of the Judgement and the UAE (which is very often the case), the recognition and enforcement of the Judgment in the UAE is governed by local ordinary rules, particularly those set out in the UAE CPC.

The local system is structured in a two-steps process:

  1. the recognition of the Judgment (petition for a writ of execution order on a foreign judgment); and
  2. upon successful completion of the procedure sub letter a), the actual enforcement proceedings against the debtor, aimed at recovering the amount crystallised in the Judgment (now equipped with the so-called writ of execution, which makes the Judgement enforceable in the UAE).

The recognition of the Judgement

Pursuant to Article 222 of the UAE CPC, a foreign judgment may only be recognised in the UAE if it passes an enforceability screening conducted by a local court – typically the Court of First Instance through its Enforcement Section (this procedure is equivalent to a recognition or exequatur proceeding)[3].

A fundamental pre-condition for filing a recognition request is the existence of the reciprocity condition, set out under Article 222.1 of the UAE CPC:

“Judgments and orders delivered by a foreign country may be ordered to be executed in the State under the same conditions as prescribed in the law of that country for the execution of judgments and orders issued in the State”[4].

Other conditions for the recognition of the Judgment include:

  1. non-existence of exclusive jurisdiction of the UAE courts over the subject matter of the dispute;
  2. compliance with the law of the country where the Judgment was issued;
  3. proper summoning and representation granted to the debtor in the proceeding(s) ended up with the issuance of the Judgment;
  4. impossibility to further appeal the Judgment (which must be considered as res iudicata);
  5. non-conflict with any prior judgment issued in the UAE, and with the UAE public order and morality[5].

Usually, the Court of First Instance takes between ten (10) and fourteen (14) working days to decide upon the recognition of the Judgment.

Once recognised, the Judgement acquires the nature of a writ of execution, allowing enforcement proceedings to commence[6].

The enforcement of the Judgement (execution)

The enforcement proceedings in the UAE are governed by Articles 206 et seq. of the UAE CPC.

According to Article 233, once the proceedings are initiated, the enforcement judge will notify the debtor of the commencement of enforcement and of the writ of execution (the Judgment), granting a period of seven (7) days within which the debtor may:

  1. oppose the enforcement through appeal; or
  2. intervene in the opened execution, requesting approval of an instalment payment plan[7].

If none of such events occur, the enforcement proceedings will officially start.

To this extent, it may be useful remarking a huge difference between the execution under UAE local courts and the correspondent procedures widely in force in other jurisdictions (mostly, European).

  1. UAE applies a common and unique procedure to any enforcement, which does not vary based upon the nature of the asset. Once an enforcement procedure is initiated, it may target and has as object any type of asset (whether movable, immovable), or claims against third parties (such as bank accounts opened under the name of the debtor);
  2. Due to the high level of confidentiality and data protection maintained by UAE authorities, information relating to individuals (such as residence status) and companies (including corporate records and ownership details) are not accessible to third private parties and may be disclosed solely upon a request of the interested party or a local court or authority. Consequently, information on a debtor’s assets typically becomes available only once enforcement proceedings have been formally initiated.

Thus, while private investigations before initiating enforcement are difficult (if not impossible), the creditor is relieved from handling notifications and ancillary acts required in other jurisdictions to this extent, in fact, the local court will drive the enforcement process[8].

The competent judge orders requests for information to the following relevant authorities:

  1. the UAE Central Bank, which liaises with banks operating in the UAE to inquire about the debtor’s accounts;
  2. the Land Department (each Emirate has its own competent department), regarding any real estate registered in the debtor’s name;
  3. the traffic authority (the Road and Transportation Authority in Dubai, the local Traffic Police in Abu Dhabi) regarding any vehicles registered under the name of the debtor; and
  4. the Economic Department, regarding any shareholdings and profit distribution rights of the debtor, or – if the debtor is a company – imposition of a block/attachment on renewal of its commercial licence.

If assets are identified, the judge orders the relative attachment, tailored to the type of asset: bank account funds transfer, sale of securities, auction of real estate or vehicles, up to the value of the debt, including legal costs and interest.

Proceeds from the seizure are first deposited with the court and later transferred to the creditor upon specific request.

Among the measures available under the UAE CPC, for claims of at least AED 10,000.00, is the travel ban.

Pursuant to Article 324 of the UAE CPC, if the creditor fears the debtor may leave the UAE and thereby frustrate debt recovery, the creditor may request issuance of such travel ban.

The competent civil court (i.e., the First Instance Court) must issue a travel ban where the debt is “known, payable and not subject to any condition”.

In the case we are analysing, the debt is typically crystallised in the Judgment (already recognised under Article 222 UAE CPC): nevertheless, the court may decide to conduct a (brief) review of the case.

Once issued, the travel ban prevents the debtor from leaving the UAE[9].

The travel ban shall be lifted where:

  1. the debt has been fully paid;
  2. the creditor withdraws the same (typically, this is the case of a settlement reached among the Parties),
  3. no enforcement action has been promoted or submitted to the relevant court for a period of three (3) years -which may result in travel ban expiring).

Despite its peculiarities, the UAE legal system is mature and well-structured for recognising and enforcing foreign court judgments, even in the absence of applicable international treaties.

The procedural rigour imposed by the UAE CPC offers foreign creditors clear, effective tools for enforcing civil and commercial claims through a formal and structured process.

Relying on experienced local counsel allows creditors to navigate UAE enforcement complexities and maximise opportunities provided by the law from the judicial recognition to the enforcement measures as above detailed.

In a dynamic and rapidly growing market like the UAE, a correct debt recovery strategy is not only a necessity, but also an opportunity.

Contact us for a preliminary assessment of your case: acting promptly today can make the difference tomorrow.

[1] Pursuant to Article 19 of the UAE CPC, UAE courts have jurisdiction to hear civil and commercial claims filed against Emirati nationals and foreign nationals who are resident (or domiciled) within the UAE. Lacking domicile or residence in the UAE, under Article 20 of the UAE CPC jurisdiction may still be asserted on alternative grounds, such as: an elected domicile within the UAE, disputes relating to immovable property located in the UAE, obligations to be performed in the UAE. Moreover, UAE courts shall have jurisdiction where – among multiple defendants – one is domiciled or resident in the UAE. Accordingly, domicile or residence within the UAE constitutes a determinative factor for the assertion of jurisdiction by Emirati courts in civil and commercial matters.

[2] As of April 2025, UAE continues to show its commitment to the mutual recognition and enforcement of foreign judgments, joining various multilateral and bilateral treaties.

  1. a) Multilateral Treaties. The UAE is a contracting party to key multilateral conventions facilitating the recognition and enforcement of foreign judgments, including:
  • the 1983 Riyadh Arab Convention for Judicial Cooperation;
  • the 1996 Gulf Cooperation Council (GCC) Convention for the Enforcement of Judgments, Notifications and Judicial Delegations.
  1. b) Bilateral Treaties. The UAE has also entered into bilateral treaties aimed at promoting the recognition and enforcement of civil and commercial judgments with several countries, including:
  • France (1992 Convention on Judicial Assistance, Recognition and Enforcement of Judgments in Civil and Commercial Matters);
  • China (2004 Convention on Judicial Assistance in Civil and Commercial Matters);
  • Kazakhstan (2009 Agreement on Judicial Assistance in Civil and Commercial Matters); and
  • India (2020 Declaration designating the UAE as a “reciprocating territory” for the enforcement of civil and commercial judgments).

While no new bilateral or multilateral treaties have been concluded since 2020, a noteworthy development has occurred with respect to the United Kingdom. In September 2022, the UAE Ministry of Justice issued a directive to Dubai courts instructing them to enforce English court judgments on the basis of reciprocity. This directive was prompted by the High Court of England’s ruling in Lenkor Energy Trading DMCC v. Puri (2020), which recognised and enforced a Dubai court judgment in the UK. Although no formal bilateral treaty currently exists between the UAE and the UK regarding reciprocal enforcement of judgments, this ministerial directive may speed up recognising and enforcing UK judgments in the UAE.

[3] The documents, Judgment included, issued by the authorities and court operating in the country of issuance, must undergo the following steps to be admissible before UAE courts:

  1. a) legalisation by the competent local public authority;
  2. b) further legalisation by the UAE competent consular section in the country of the Judgement’s issuance;
  3. c) attestation by the UAE Ministry of Foreign Affairs and International Cooperation.

It is important to note that Arabic is the official language of the UAE courts. Accordingly, any document in a foreign language intended for court submission must be accompanied by an official Arabic translation.

[4] To satisfy this requirement before local court, it is advisable submitting the relevant foreign law (often, the civil procedural code in force in the country of Judgment’s issuance) along with a pro-Veritate opinion, issued and signed by a lawyer therein qualified and operating.

[5] UAE courts have adopted a practice requiring that the applicant proves that no enforcement proceedings are pending in the originating jurisdiction at the time of the recognition request. Such a document may have for each jurisdiction a different denomination/title and different authorities of relevance.

[6] According to Article 212 of the UAE CPC, “compulsory enforcement may be carried out only under a writ of execution”.

[7] A judgment debtor seeking a deferred payment arrangement must immediately pay thirty per cent (30%) of the adjudicated amount and may request to settle the remaining balance via monthly instalments. As a matter of local practice, any such deferred payment plan, if granted by the competent enforcement judge, generally does not exceed twenty-four (24) months. Relevant authorities typically issue reports within a period ranging between one (1) to two (2) months.

[8] The creditor will be only required to provide the competent court with all relevant details it has on the debtor.

[9] If the debtor is a company, the travel ban will be issued against the company’s manager named on the company’s commercial licence.