LEGAL GUIDE

How to Have a Foreign Judgment Recognised in the UAE

Recognising a foreign judgment in the UAE is the separate legal process of having a court judgment issued outside the UAE formally accepted by a UAE court so that it can then be enforced here, whether through the onshore courts or through the DIFC or ADGM Courts.

Winning a case in London, New York, or anywhere else outside the UAE doesn’t give you anything directly enforceable against assets or a debtor here — a foreign judgment needs to go through its own recognition process before UAE enforcement machinery can be used against it. Recognition can be sought from the onshore courts or from the DIFC or ADGM Courts, but the routes are not interchangeable: under Abu Dhabi law, an ADGM Courts order recognising a foreign judgment cannot be enforced outside ADGM. This guide sets out the routes, their limits and what happens after recognition is obtained.

LAST REVIEWED 21 SEPTEMBER 2026

WHO THIS GUIDE IS FOR

A judgment creditor holding a court judgment from outside the UAE who needs it recognised here — because the debtor, or the debtor’s assets, are in the UAE — before enforcement against those assets becomes possible.

Why a Foreign Judgment Doesn’t Automatically Work in the UAE

A judgment from a foreign court has no automatic force in the UAE. It needs to go through a recognition process before a UAE court will treat it as something that can be enforced against a debtor or their assets here — the UAE doesn’t simply defer to a foreign court’s decision without its own courts first accepting it.

This is a common source of confusion for people used to jurisdictions with more straightforward mutual enforcement arrangements — the assumption that a judgment "just works" wherever the debtor happens to be doesn’t hold in the UAE without this additional step.

The Direct Route — Onshore Recognition

It’s possible to seek recognition and execution of a foreign judgment directly through the onshore UAE courts. This route follows the onshore courts’ own civil-law procedure — Arabic-language, with the court examining the foreign judgment against the requirements for recognition under UAE law.

This route is available and used, but it runs through the same civil-law procedural framework as any other onshore matter, which is a material consideration for a creditor weighing it against recognition in the DIFC or ADGM Courts — bearing in mind the limits, set out below, on taking a DIFC or ADGM recognition to onshore assets.

Reciprocity and Treaty Considerations

Whether and how a specific foreign judgment is recognised can depend on treaty arrangements and reciprocity considerations between the UAE and the country where the judgment was issued. This varies by country and is genuinely case-specific — it’s not something this guide states in general terms, since doing so risks a claim that doesn’t hold for a specific pair of jurisdictions. Confirm the current position for the specific foreign jurisdiction involved with a lawyer before assuming a particular treaty or reciprocity arrangement applies.

Recognition in the DIFC or ADGM Courts — and Its Limits

The DIFC Courts and the ADGM Courts can also be asked to recognise or enforce a foreign judgment, under their own English-language, common-law procedure, but what that recognition can do next differs. Under Article 13(14) of Abu Dhabi Law No. 4 of 2013, as amended by Law No. 12 of 2020, an ADGM Courts judgment or order recognising or enforcing a judgment of a court outside the Emirate is excluded from the rule under which ADGM Courts judgments are enforced by the competent entities outside ADGM; ADGM’s guide to the amendment says parties cannot use ADGM to enforce non-ADGM judgments in other jurisdictions. For the DIFC Courts, the DIFC Courts Law (Dubai Law No. (2) of 2025) gives their Enforcement Judge jurisdiction to enforce foreign judgments where the enforcement falls on a DIFC body, a DIFC establishment or another entity within the DIFC (Article 31); whether a foreign judgment recognised in the DIFC can then be enforced against onshore assets should be assessed with a lawyer rather than assumed.

Choosing Where to Seek Recognition

DIFC and ADGM Courts operate in English, under common-law procedure that can be more familiar to a foreign judgment creditor than the onshore civil-law process, particularly one coming from another common-law jurisdiction. Procedure is only part of the choice, though: ADGM’s guide to the 2020 amendments states the ADGM Courts’ position that parties should go to the place where the relevant assets are located for the purpose of enforcement, and a recognition obtained in one UAE court system should not be assumed to reach assets in another.

Step 1 — Preparing the Foreign Judgment for Recognition

Before filing, the foreign judgment generally needs to be properly authenticated and, where required, translated, along with evidence establishing that it’s final and enforceable in its own jurisdiction of origin. The specific documentary and procedural requirements are set by whichever court — onshore, DIFC, or ADGM — you’re seeking recognition from, and are worth confirming directly with that court or a lawyer before filing.

Step 2 — Filing for Recognition

The recognition application is filed with the relevant court — onshore, DIFC or ADGM — setting out the foreign judgment, the basis on which recognition is sought, and evidence supporting that the judgment meets the requirements for recognition (proper jurisdiction of the foreign court, proper service on the defendant, finality of the judgment, and the absence of grounds for refusal, among other things).

Step 3 — From Recognition to Execution

Recognition on its own establishes that the foreign judgment is treated as valid and enforceable within the recognising court’s jurisdiction — it doesn’t itself collect the money or compel compliance. Once recognised, the judgment still needs to go through execution, in the same way any other domestic judgment does. See LEXNOVA’s guide on enforcing a domestic judgment for how that stage generally works, including the tools an execution court has available.

Where recognition was obtained in the DIFC or ADGM Courts and the debtor or assets are onshore, that recognition does not reach onshore assets on its own. For ADGM, Abu Dhabi law excludes an ADGM order recognising a foreign judgment from enforcement outside ADGM, and ADGM’s guide to the amendment says the creditor must bring the enforcement application where the assets are; for the DIFC, whether a DIFC recognition can be taken on to onshore assets needs to be assessed with a lawyer before relying on it.

Grounds on Which Recognition Can Be Refused

Recognition isn’t automatic even where an application is properly filed. Courts generally examine grounds such as whether the foreign court had proper jurisdiction over the matter, whether the defendant was properly served and given an opportunity to be heard, whether the judgment conflicts with an existing UAE judgment on the same matter, and whether recognising the judgment would conflict with UAE public policy.

Because these grounds are assessed by the specific court on the specific facts, and can vary depending on the foreign jurisdiction and treaty position involved, it’s worth getting advice on how they apply to your specific judgment before assuming recognition will be straightforward.

DIFC–Dubai Conflicts of Jurisdiction

Where the DIFC Courts and the Dubai Courts, or another judicial body in Dubai, both claim or both decline the same claim or application, or deliver conflicting judgments on it, a party can apply to the Judicial Tribunal for Resolving Jurisdictional Conflicts between the Dubai International Financial Centre Courts and Judicial Bodies in the Emirate of Dubai, which the DIFC Courts call the Conflicts of Jurisdiction Tribunal. Formed under Dubai Decree No. (29) of 2024, which superseded Decree No. (19) of 2016, it decides which body has jurisdiction or, where conflicting judgments involve the same parties and subject matter, which judgment is enforceable. It is separate from the recognition process itself and does not enforce judgments; LEXNOVA’s guide to which court has jurisdiction covers it in more detail.

Arbitral Awards Are a Different Track

A foreign arbitral award is not the same thing as a foreign court judgment, and is not recognised and enforced through this same process. Foreign arbitral awards generally run under the New York Convention, which the UAE is a party to, giving arbitral awards a different — and in many cases more straightforward — enforcement pathway than a foreign court judgment. See LEXNOVA’s guide on challenging an arbitral award for more on how the arbitration-specific track works.

How LEXNOVA Helps

LEXNOVA is a lawyer-matching service, not a law firm — it doesn’t file your recognition application or advise on which route (onshore, DIFC or ADGM) fits your situation. What it does is help you describe your situation clearly enough — the foreign judgment, where the debtor or assets are located, and what’s been tried so far — to be matched with a lawyer experienced in cross-border recognition and enforcement. Every match is reviewed by a person, and the professional relationship from there is directly between you and the lawyer.

FAQ

No. It needs to go through a recognition process before a UAE court will treat it as enforceable against a debtor or assets here. There’s no automatic mutual recognition regardless of where the judgment was issued.

Recognition through the onshore UAE courts, following their civil-law procedure, or recognition in the DIFC or ADGM Courts, under English-language common-law procedure. The second does not reach onshore assets on its own: an ADGM Courts recognition order cannot be enforced outside ADGM, and a DIFC Courts recognition should not be assumed to reach onshore assets.

No. Under Article 13(14) of Abu Dhabi Law No. 4 of 2013, as amended by Law No. 12 of 2020, an ADGM Courts judgment or order recognising a judgment of a court outside the Emirate is excluded from enforcement by the competent entities outside ADGM. ADGM’s guide to the amendment says the ADGM Courts Registry will not affix the executory formula for enforcement in other jurisdictions, so the creditor must bring the enforcement application where the assets are.

No. Recognition in the DIFC Courts does not by itself reach onshore assets. The DIFC Courts Law gives the DIFC Courts’ Enforcement Judge jurisdiction to enforce a foreign judgment where the enforcement falls on a DIFC body, establishment or other entity within the DIFC (Article 31 of Dubai Law No. (2) of 2025); whether a DIFC recognition can be taken on to onshore assets should be assessed with a lawyer rather than assumed.

Yes. Courts generally examine grounds such as whether the foreign court had proper jurisdiction, whether the defendant was properly served, whether the judgment conflicts with an existing UAE judgment, and whether recognition would conflict with UAE public policy.

Yes — reciprocity and treaty arrangements between the UAE and the foreign country can affect recognition, and this varies genuinely by country. Confirm the current position for the specific foreign jurisdiction with a lawyer rather than assuming a general rule applies.

No — they run on different tracks. Foreign arbitral awards are generally enforced under the New York Convention, which the UAE is a party to, giving them a different pathway than a foreign court judgment.

Generally the judgment itself, properly authenticated and translated where required, along with evidence it’s final and enforceable in its jurisdiction of origin. The specific requirements are set by the recognising court — onshore, DIFC, or ADGM — and are worth confirming directly before filing.

No. Recognition establishes that the foreign judgment is treated as valid and enforceable — it doesn’t itself collect payment. Once recognised, the judgment still needs to go through execution, the same as any other domestic judgment.

The Judicial Tribunal for Resolving Jurisdictional Conflicts between the Dubai International Financial Centre Courts and Judicial Bodies in the Emirate of Dubai, which the DIFC Courts call the Conflicts of Jurisdiction Tribunal, formed under Dubai Decree No. (29) of 2024, which superseded Decree No. (19) of 2016. Where the DIFC Courts and a Dubai judicial body both claim or both decline a case, or deliver conflicting judgments on it, a party can apply to it to decide which body has jurisdiction or which judgment is enforceable. Its role is to settle those conflicts; it is separate from recognising or enforcing a judgment.

Both routes can be available, but they are not interchangeable: an ADGM Courts recognition cannot be enforced outside ADGM, and a DIFC Courts recognition should not be assumed to reach onshore assets. The choice depends on where the debtor and assets are, the nature of the foreign judgment, and procedural considerations — worth discussing with a lawyer experienced in both routes.

Improper service on the defendant in the original foreign proceedings is one of the recognised grounds on which a UAE court can refuse recognition, since it goes to whether the defendant had a fair opportunity to be heard.

A conflicting existing UAE judgment on the same matter is one of the recognised grounds on which recognition of a foreign judgment can be refused.

This varies by court, the specifics of the case, and current caseload. LEXNOVA doesn’t state specific timeframes — confirm current expectations with the relevant court or a lawyer handling your matter.

It’s a related but distinct mechanism — the opt-in gateway lets parties agree in writing to submit an otherwise unconnected dispute to the DIFC Courts, whereas foreign judgment recognition is about a judgment already obtained elsewhere being accepted by a UAE court. Both can be relevant to the same broader cross-border strategy, but they’re different tools.

Once the foreign judgment is recognised and moves into execution — the same process used for any domestic judgment — bank attachment is one of the tools an execution court can use. See LEXNOVA’s guide on enforcing a domestic judgment for how that stage works.

No. LEXNOVA is a lawyer-matching service, not a law firm, and doesn’t file recognition applications or give legal advice. It helps match you with a lawyer experienced in cross-border recognition and enforcement; every match is reviewed by a person.

LEXNOVA is not a law firm and does not provide legal advice, legal opinions, legal representation, or legal services. Any legal advice or representation is provided directly by the independent legal professional engaged by the client.

A connection or introduction does not constitute a guarantee, endorsement, or assurance of outcome. Users should independently confirm the professional's qualifications, authorization, fees, scope of engagement, and suitability.

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