On 14 January 2025, the Dubai Courts and the Abu Dhabi Global Market (ADGM) Courts signed a Memorandum of Understanding (MoU) designed to simplify and accelerate reciprocal enforcement of judgments. Far from a technical footnote, the MoU speaks to a growing demand for certainty, efficiency, and trust in how judgments are recognised within the UAE’s dual judicial ecosystem.
The MoU’s key features are both practical and strategic:
Clear enforcement routes: Judgments may be enforced either through a direct application to the enforcing court or by deputisation, where one enforcement judge authorises their counterpart.
Respect for finality: The enforcing court cannot revisit the merits of the dispute; it limits itself to ensuring the judgment meets the procedural requirements.
Parallel Enforcement Mechanisms: Dubai Judgments in ADGM and ADGM Judgments in Dubai
The mechanism for enforcement of Dubai Court judgments by ADGM Courts underscores a commitment to harmonisation within the UAE’s multi-jurisdictional system. The procedures, as outlined in the MoU, stipulate that where the subject of enforcement lies within the ADGM, Dubai judgments may be enforced directly—provided that certain conditions are satisfied. Notably, the ADGM Courts require the Dubai judgment to bear the executory formula authorising enforcement, accompanied by a certified English translation. Once these formalities are met, the ADGM Courts proceed with enforcement in accordance with the ADGM Court Procedure Rules and Practice Directions, without re-examining the merits of the underlying judgment.
Notably, the MoU expressly provides that when executing ADGM judgments, the Execution Court of Dubai shall apply the enforcement procedures prescribed under Federal Law No. (42) of 2022 (Civil Procedure Law), without re-examining the merits of the underlying ADGM judgment. This mirrors the approach adopted by ADGM Courts when enforcing Dubai Court judgments, ensuring procedural uniformity and mutual respect between the two jurisdictions.
Taken together, these features create a leaner enforcement process that reduces duplication, speeds outcomes, and strengthens confidence in UAE courts as predictable partners in commercial dispute resolution.
Institutional Cooperation and Mutual Obligations
The MoU also sets out mutual obligations aimed at ensuring effective coordination between the Dubai Courts and the ADGM Courts. Under Clause 15, both courts agree to assign an officer who will liaise and collaborate with the counterpart officer to ensure that enforcement actions are not duplicated, and to assist judgment creditors in matters referred for enforcement under the MoU.
Each court is further required to keep and provide the other with information and statistics concerning referrals and direct applications made pursuant to the MoU, including the publication of such data
What It Means in Practice
The timing of this MoU is significant. The UAE’s economy continues to expand globally, with Dubai and Abu Dhabi both positioning themselves as leading financial and investment centres. In this context, the true value of a judgment lies not only in the decision itself but in the ease with which it can be enforced.
The MoU provides a direct solution. It demonstrates that the UAE judiciary is willing to innovate procedurally to align with international standards. In a commercial environment where certainty and speed are often as valuable as the judgment itself, the agreement underscores a strategic commitment: to make the UAE not only a jurisdiction where disputes can be resolved, but one where enforceability is practical, efficient, and reliable.
How It Fits into the Broader Legal Framework
The UAE’s efforts to modernize enforcement are not new. The Federal Decree-Law No. 42 of 2022 (Civil Procedure Code) clarified conditions for enforcing domestic and foreign judgments, including reciprocity, jurisdiction, due process, and finality. Alongside this, The UAE is a signatory to several multilateral and bilateral treaties facilitating the reciprocal recognition and enforcement of foreign judgments. These include the Riyadh Arab Agreement for Judicial Co-operation, the GCC Convention on the Execution of Judgments, and bilateral treaties with France, India, China, Kazakhstan and the United Kingdom.
What makes the MoU distinct is its intra-UAE focus. Rather than simply relying on legislative reforms, it establishes a forward-looking framework of judicial cooperation built on coordination, efficiency, and mutual trust.
Should you have any questions or wish to explore the implications of the Dubai–ADGM MoU on reciprocal enforcement of judgments, please feel free to reach out to the firm’s experts Mohammed Alsuwaidi at alsuwaidi@alsuwaidi.ae and Merline Dsouza at merline@alsuwaidi.ae