Arbitration in the UAE: onshore law, DIFC, ADGM, DIAC, costs, enforcement

The short version

• Arbitration in the UAE runs under three regimes: the onshore Federal Law No. 6 of 2018 on Arbitration, the Federal Arbitration Law, in force on 16 June 2018 and based on the Model Law of the United Nations Commission on International Trade Law (UNCITRAL); and two financial free zones with their own laws, the Dubai International Financial Centre (DIFC) and the Abu Dhabi Global Market (ADGM).
• New Dubai cases run under the Dubai International Arbitration Centre (DIAC) Rules 2022; new Abu Dhabi cases under the arbitrateAD Rules 2024, at the renamed Abu Dhabi International Arbitration Centre.
• Dubai Decree No. 34 of 2021 abolished the DIFC Arbitration Institute, which ran the DIFC-LCIA Arbitration Centre, and the Emirates Maritime Arbitration Centre (EMAC), and moved their work to DIAC. A clause that still names an abolished centre stays valid and is read as DIAC.
• The award clock differs by regime: onshore six months from the first hearing, plus six (art 42); DIAC six months from the file reaching the tribunal, three if expedited (arts 35.1, 32.5); arbitrateAD nine months from the first case management conference, four plus two if expedited (arts 38(3), 36).
• An onshore award is challenged by an action in nullity within 30 days of notification (art 54(2)); in the DIFC and the ADGM the limit is three months. Foreign awards are enforced under the New York Convention, which the UAE joined in 2006.
• In the 2025 International Arbitration Survey by Queen Mary University of London, respondents could name up to five seats. London was named by 34% and Singapore and Hong Kong by 31% each, and Dubai completes the global top ten.^{1,2,4,16,17,27,28,30}

What law governs arbitration in the UAE?

Three statutes govern arbitration in the UAE, and which applies turns on the seat, the arbitration’s legal home whose law governs procedure and whose courts supervise the case. Onshore, the Federal Arbitration Law applies to any arbitration seated in the UAE unless the parties choose another arbitration law that does not offend public order and morality (art 2(1)). It came into force on 16 June 2018, a month after publication in Official Gazette No. 630, and repealed the old arbitration articles (203 to 218) of the 1992 Civil Procedure Law (arts 60, 61). The two financial free zones, the DIFC and the ADGM, each run their own arbitration law for cases seated there. Practitioners call the two free zones the offshore regimes, in contrast with the onshore federal system.¹

The Model Law is UNCITRAL’s 1985 template for national arbitration laws, amended in 2006. The UNCITRAL status table lists the UAE’s onshore regime, the DIFC and the ADGM as Model-Law-based, so the three work in much the same way as seats such as London and Singapore. The DIFC Arbitration Law, DIFC Law No. 1 of 2008 as amended in 2013, applies where the seat is the DIFC (art 7(1)); a few provisions, on court-ordered interim measures and recognition, apply even when the seat is elsewhere (art 7(2)). The ADGM runs its Arbitration Regulations 2015; we could not open the consolidated text, so the ADGM points below come from the 2020 consultation draft and are marked as proposed.^4,21,28

The onshore law was amended in 2023 by Federal Decree-Law No. 15 of 2023, named on arbitrateAD’s Laws and Regulations page as amending the 2018 law. We could not open the official text, so we carry no change from it as fact and flag that it may have renumbered the articles this guide cites. The Federal Arbitration Law of 2018, as amended, remains the onshore statute.²⁰

Why do parties choose the UAE as a seat, and which one?

Parties choose the UAE because it offers two systems in one country: a civil-law onshore regime in Dubai and Abu Dhabi, and two common-law free zones, the DIFC and the ADGM, each with its own Model-Law statute and English-language supervisory court. A free-zone seat gives a common-law supervisory court; an onshore seat stays in the federal and local courts. English dominates the institutional caseload: in DIAC’s 2024 arbitrations it was the language in 95% of cases, with parties from 53 countries, 71% of them from the UAE. Dubai was the seat in 135 of the 262 arbitrations and the DIFC in 126, so the choice is live even inside one institution.^4,15

In the 2025 Queen Mary survey, respondents could name up to five seats. London was named by 34% and Singapore and Hong Kong by 31% each. Dubai completes the global top ten of preferred seats, ranks fourth among Middle East respondents and fifth in Africa, and is named for disputes affected by sanctions. For how other seats compare, see arbitration in Saudi Arabia and arbitration in London.³⁰

Which institutions run arbitrations in the UAE, and under what rules?

Two institutions run most UAE arbitrations: the Dubai International Arbitration Centre (DIAC) in Dubai and arbitrateAD in Abu Dhabi. DIAC is a non-governmental, non-profit centre with a Dubai head office and a DIFC branch, which took over the abolished centres’ caseload under Decree 34 of 2021. The DIAC Rules 2022, approved on 25 February 2022 and in effect from 21 March 2022, added an emergency arbitrator, joinder, consolidation and an expedited track. In 2024 DIAC registered 295 cases (262 arbitrations, 33 appointing-authority), with AED 9.7 billion in dispute; 26% were still brought on DIFC-LCIA agreements, and the Centre received five emergency-arbitrator applications.^2,15,16

arbitrateAD is the main Abu Dhabi institution. The Abu Dhabi Chamber of Commerce renamed the former Abu Dhabi Commercial and Conciliation Centre (ADCCAC) as arbitrateAD by a board resolution of 30 November 2023, and the old centre stopped taking new cases on 1 February 2024. In its first biennial report, 1 February 2024 to 1 February 2026, arbitrateAD recorded 105 matters, 76 of them arbitrations, a 38% rise year on year. English was the language in 84% of cases and Arabic in 16%, construction and real estate made up over two-thirds of the caseload, and the Court scrutinised 18 awards.^19,20

What should the arbitration clause say, and what can be arbitrated?

An onshore arbitration agreement must be in writing or it is void (Federal Arbitration Law art 7(1)). Writing is met by a signed document, an exchange of letters or an electronic communication under the UAE’s electronic-transactions rules, so a clause agreed by email can bind (art 7(2)(a)). It can also come in by reference to another document, if the reference is clear enough (art 7(2)(b)). Who signs matters too. The agreement is void unless made by a person with legal capacity, or by a company representative authorised to conclude the arbitration agreement (art 4(1)). That is the article to check for a UAE company or a government entity.¹

Name the seat on purpose, because the rules fill it in otherwise: under the DIAC Rules the initial seat is the DIFC where none is agreed (art 20.1), and under the arbitrateAD Rules it is the ADGM (art 22(2)). So a clause meant for an onshore Dubai or Abu Dhabi seat must say so, and the arbitrateAD Rules publish a model clause that leaves the seat blank for the parties to write in (Annex 2). A clause that still names the old DIFC-LCIA Rules is read, by Decree 34, as an agreement to arbitrate under the DIAC Rules, as the DIFC Courts accepted in Oswin v Otila and Ondray, ARB 032/2025 ([14]). Oswin also held that choosing the DIFC seat made DIFC law, not the UAE law governing the contract, the law of the arbitration agreement.^11,16,17

On arbitrability, the statute bars only matters that cannot be put to conciliation (art 4(2)). The market reads real-estate registration, insurance and commercial-agency disputes as non-arbitrable onshore, but that is practice to confirm, not the words of the Law. Most UAE arbitration is commercial, and construction and real estate make up over two-thirds of arbitrateAD’s caseload (see the figures above).^1,19

How does a DIAC arbitration work, step by step?

A DIAC case starts when the claimant files a Request for Arbitration with the USD 3,000 registration fee (arts 4, 5). The respondent answers within 30 days (art 5.1), the tribunal is appointed and the file is transmitted to it (art 18), and hearings can be held in person or as virtual hearings, by telephone or by video (art 26.1). Before signing an award, the tribunal sends it in draft to the DIAC Arbitration Court for review, a step called scrutiny, at least 30 days before the time limit (art 34.5).^14,16

Onshore, the Federal Arbitration Law supplies the backbone whichever institution runs the case: hearings and deliberations may use modern electronic means (art 28), and the court can order interim or precautionary measures before or during the arbitration (art 18(2)).¹

An arbitrateAD case differs in detail. It starts with a Request and the AED 10,000 filing fee, which counts towards the administrative fee (arts 6, 49). The tribunal may issue Terms of Reference (art 24). It must hold an initial case management conference within 21 days of the file reaching it (art 25(1)), at which the tribunal and parties must consider including data protection and cyber security on the agenda (art 25(3)(x)). It has an emergency arbitrator (art 35), the Court scrutinises the award before it is made (art 40(3)), and the award is due nine months from that first conference (art 38(3)).¹⁷

How long does arbitration in the UAE take, and what does it cost?

How long a UAE arbitration takes depends on the regime and the track, set out in the at-a-glance table above, and what it costs depends mainly on the amount in dispute. Neither DIAC nor arbitrateAD publishes an average duration, so we give none.^16,17

DIAC’s 2025 Table of Fees and Costs applies to cases started after 1 January 2025; it is shown in US dollars for illustration but invoiced in dirhams, plus value added tax (VAT). arbitrateAD’s fees come from Annex 1 to its Rules, set in dirhams and also excluding VAT. Both price in bands by the amount in dispute, and the worked examples below are recomputed from those bands.^14,17

• Both institutions set the administration and arbitrator fees by band on the amount in dispute (DIAC’s USD 43,140 administrative fee is USD 30,000 plus 0.438% of the USD 3,000,000 above USD 2,000,000). arbitrateAD caps its administrative fee at AED 300,000 and charges AED 3,500 to file a notice of challenge and AED 11,500 to act as appointing authority (Annex 1).
• Who pays: each side pays half the advance on costs unless the institution directs otherwise, and the tribunal can order one party to bear another’s costs (arbitrateAD arts 50, 51).^14,17

What role do UAE courts play during an arbitration?

Onshore, the Federal Arbitration Law gives the supporting role to one court: the federal or local Court of Appeal (art 1). It handles appointment, interim measures, jurisdiction, time-limit extensions, ratification and the action to set an award aside. Ordering interim or precautionary measures does not pause the arbitration or waive the agreement (art 18(2) to (4)).¹

In the DIFC, the DIFC Courts’ arbitration jurisdiction now rests on Dubai Law No. 2 of 2025, issued on 3 March 2025, which replaced the 2004 law that set up the Courts (art 43). The Courts hear claims to ratify or recognise awards (art 14(A)(5)) and claims arising from DIFC-seated arbitrations (art 14(A)(6)), and can grant interim measures (art 15). A recognised DIFC award becomes enforceable; where the assets sit outside the DIFC, the DIFC Courts pass the writ to the Dubai Courts, with no re-examination of the merits (art 32). The Arbitration Division, set up in 2020, took 53 claims worth AED 4.95 billion in 2025 and 37 worth AED 3.17 billion in the first half of 2026, up 61% year on year.^3,8,9,10

This is why parties treat the DIFC Courts as a conduit. A DIFC Court can recognise an award whatever its seat (DIFC Arbitration Law arts 42(1), 7(2)) and can order interim measures in support of an arbitration seated elsewhere (art 15). The Court of Appeal confirmed the first point in Neal v Nadir [2024] DIFC CA 001, holding that an interim award is an award enforceable under Part 4 irrespective of seat, in a London-seated arbitration that reached the DIFC through a DIFC-LCIA clause now read as DIAC. The ADGM Courts recognise awards under Practice Direction 10, re-issued on 17 October 2025. But the Registry will not affix an executory formula, the stamp that lets an order be enforced elsewhere, to a recognition order for an award seated outside the ADGM (paragraph 10.16(b)).^4,12,24

Can you appeal or set aside an arbitral award in the UAE?

There is no appeal on the merits. The route is an action to set the award aside, an action in nullity or annulment, by which a court at the seat cancels the award. Onshore the grounds are in Federal Arbitration Law art 53(1): no valid agreement, incapacity, lack of proper notice, a defect in the tribunal’s composition, failure to apply the chosen law, or a decision beyond the scope of the arbitration. The court will also raise on its own that the subject matter cannot be arbitrated, and that the award conflicts with public order and morality (art 53(2)), which the UAE courts read broadly. The International Bar Association’s UAE guide, from before 2021, describes UAE public order as reaching the fundamental principles of Islamic Sharia; it is the ground foreign parties most often meet at enforcement.^1,26

The onshore clock is short. An action in nullity cannot be heard after 30 days from the date the award is notified (art 54(2)), and the court’s decision is final save for a cassation appeal (art 54(1)). The court can pause the annulment for up to 60 days to let the tribunal cure the defect (art 54(6)), and filing an action does not by itself stay enforcement (art 56(1)). In the DIFC the grounds follow the Model Law. The public-policy ground reads as conflict with the public policy of the UAE (DIFC Arbitration Law art 41(2)), and the limit is three months (art 41(3)). The ADGM 2020 draft also set a three-month limit (draft Arbitration Regulations, section 58), which we mark as proposed because the enacted text was not opened. In Muhallam v Muhaf, ARB 021/2022 (19 September 2023), the DIFC Court of First Instance dismissed a jurisdiction challenge to the enforcement of an interim award, holding that a tribunal measure made in the form of an award is an arbitral award enforceable under articles 42 and 43 even where the seat is outside the DIFC. That order was upheld on appeal as Neal v Nadir [2024] DIFC CA 001.^1,4,12,13,22

How are arbitral awards enforced in and from the UAE?

Onshore, an award binds the parties and has the force of a court judgment once a court recognises it (Federal Arbitration Law art 52). The winning party asks the president of the Court to recognise the award and issue an enforcement order, filing the award, the agreement and a certified Arabic translation where the award is in another language. The Court decides within 60 days unless a ground for annulment is made out (art 55). A grievance goes to the appeal court within 30 days (art 57).¹

In the DIFC, an award is recognised and enforced irrespective of where it was made, subject to that Article and Articles 43 and 44 (DIFC Arbitration Law art 42(1)), and recognition by the DIFC Courts counts as ratification for the wider Dubai system (art 42(4)); refusal is possible only on the grounds in art 44. Foreign-award enforcement onshore now sits in a new procedure law, reported to be Federal Decree-Law No. 42 of 2022 replacing the 1992 Civil Procedure Law; we could not open it, so we give no article numbers from it. The ADGM Courts enforce under Practice Direction 10.^4,24

A UAE award is enforced abroad under the New York Convention, the 1958 treaty on recognising and enforcing foreign arbitral awards, which has 172 parties; see New York Convention grounds. The UAE acceded on 21 August 2006, and the UNCITRAL status table shows no reservations for it, so in principle it applies the Convention to awards from any contracting state. It is also party to the 1983 Riyadh Convention and the 1987 Gulf Cooperation Council Convention, as reported in the International Bar Association’s UAE guide (which pre-dates 2021). For enforcing a UAE award into other seats, see arbitration in Singapore and arbitration in London; for AI-specific enforcement questions, see AI and award enforcement.^26,27

What changed recently, and what is pending?

• 2021: Dubai Decree No. 34 of 2021, issued 14 September 2021, abolished the DIFC Arbitration Institute, which with the LCIA had run the DIFC-LCIA Arbitration Centre, and the Emirates Maritime Arbitration Centre, and folded their work into DIAC.
• 2022: the DIAC Rules 2022, in effect 21 March 2022, brought in the emergency arbitrator, joinder and consolidation and the expedited track.
• 2023: Federal Decree-Law No. 15 of 2023 amended the onshore Federal Arbitration Law; we report it from arbitrateAD’s Laws and Regulations page and flag that the official text was not opened.
• 2024 and 2025: arbitrateAD launched on 1 February 2024, its Mediation Rules took effect on 28 January 2026, and Dubai Law No. 2 of 2025 reset the DIFC Courts’ arbitration jurisdiction.
• Pending: the DIFC Authority consulted in June 2026 on a new arbitration and mediation law for the DIFC (security for costs, consolidation, summary awards, emergency arbitrators, remote hearings, a mediation part), with comments due by 10 July 2026. As of 30 October 2026 it is not enacted, the DIFC legal database still lists the 2008 Law as current, and we do not rely on the proposed law number.
• Mediation: the UAE acceded to the Singapore Convention on mediated settlements on 8 October 2026, in force 8 April 2027, subject to declarations.^{2,3,5,6,16,18,20,29}

What does the UAE say about AI in arbitration?

The UAE institutions have no AI rule, and what is specific to the UAE sits with the two free-zone courts. For how AI is treated in arbitration generally, see the AI pillar AI in arbitration and our AI rules tracker. The DIFC Courts’ Practical Guidance Note No. 2 of 2023, in effect from 21 December 2023, asks for transparency about AI-generated content, verification of its accuracy and care against over-reliance, and notes that the Courts can reject AI content under Rule 29.10 of the Rules of the DIFC Courts. It binds parties before the DIFC Courts, not tribunals; in our reading it therefore reaches set-aside and recognition claims in the Arbitration Division. The ADGM Courts’ Practice Direction 2, re-issued on 17 October 2025, says a disclosure search is not unreasonable just because a party used AI such as predictive coding (paragraph 2.84), and a party intending to use AI in a document search must tell the other parties and give the search parameters (paragraph 2.85).^7,23

The DIAC Rules 2022 do not mention AI, and in June 2025 DIAC announced a partnership that brought AI research and workflow tools to its case team; we name no provider and record it in the tracker. The arbitrateAD Arbitration Rules 2024 do not mention AI either, though its Mediation Rules bar recordings of any kind, including through digital, artificial-intelligence or automated-transcription technologies, unless everyone present agrees in writing (art 7(4)).^16,17,18,25

On whether an AI could sit as arbitrator, the onshore law says the arbitrator shall be a physical person (Federal Arbitration Law art 10(1)). We found no UAE case on an AI-assisted award; the general set-aside ground is that the proceedings were so defective that the award is affected (art 53(1)). As the arbitrateAD data-protection agenda item shows (art 25), the practical step is to raise AI tools at the first case management conference and record what is agreed in Procedural Order No. 1. For mediation generally, see AI in mediation.^1,17

What is still open in UAE arbitration?

• The exact text and scope of Federal Decree-Law No. 15 of 2023, which we could not open, and whether it renumbered the Federal Arbitration Law articles this guide cites.
• Whether the DIFC’s proposed 2026 arbitration and mediation law is enacted, and in what form.
• Whether DIAC or arbitrateAD will issue an AI rule. Neither had one as of 30 October 2026.
• Whether the onshore requirement that an arbitrator be a physical person survives the 2023 amendment, and how a UAE court would treat an AI-assisted award.^1,3,5,20,25