The court structure and jurisdictional regimes of the United Arab Emirates (UAE) are complex. The UAE is a federation of seven emirates, each of which being its own jurisdiction for matters devolved upon the emirates under the UAE Constitution. Three of the emirates operate their own court system (Dubai, Abu Dhabi and Ras Al Khaimah), with the remainder relying on the federal court structure. In addition, two of the emirates – Dubai and Abu Dhabi – have established financial free zones within their territories. These financial free zones, that is, the Dubai International Financial Centre (DIFC) and Abu Dhabi Global Markets (ADGM), are separate jurisdictions from the UAE (and from the emirates, including the one in which they are established). They operate a common-law-based legal system with their own civil and commercial laws.
Different procedures apply to the enforcement of judgments depending on whether the court in which the judgment was rendered was "onshore" in the UAE (by an emirate or federal court of the UAE), or the DIFC or ADGM courts. Judgments of the onshore courts, the DIFC courts, and the ADGM courts are not considered to be domestic judgments as regards each other. However, for the purposes of this Q&A, we consider enforcement of judgments between the onshore courts and the financial free zone courts as domestic, and judgments issued by a court outside of the UAE as foreign.
Onshore courts. The courts of the emirates of the UAE and the federal courts are bound by the federal laws relating to civil procedure in the UAE. The relevant legal framework is contained in Federal Law No. 11 of 1992 on the Civil Procedure Code (Civil Procedure Code), and section 3 of Cabinet Resolution No. 57 of 2018 Concerning the Executive Regulations of the Civil Procedure Code (Executive Regulations), as amended by Cabinet Resolution No. 33 of 2020. The Executive Regulations contain provisions which amend and repeal the similar provisions of the Civil Procedure Code, by virtue of Article 192 of the Executive Regulations.
In particular, the Executive Regulations deal with matters such as:
The role of the execution judge and the enforcement officers (Articles 69 to 74, Executive Regulations).
The form of the writ of execution (Articles 75 to 76, Executive Regulations).
Immediate enforcement (Articles 77 to 84, Executive Regulations).
Enforcement procedures (Articles 97 to 102, Executive Regulations).
Enforcement of judgments between the courts of the different emirates is covered under Federal Law No. 10 of 2019 on Regulating Judicial Relations among the Judicial, Federal and Local Authorities (Judicial Relations Law). Article 10 of the Judicial Relations Law provides that all final or enforceable judgments or orders of the federal or emirate courts are enforceable throughout the UAE, in accordance with relevant legislation (that is, the Civil Procedure Code and the Executive Regulations).