Enforcing a Foreign Judgment in the UAE: Translation Guide

Enforcement of foreign judgments sits in Federal Decree-Law No. 42 of 2022 on Civil Procedure, Articles 222 to 225. Under Article 222, the execution judge orders a foreign judgment to be executed only after verifying that:

1. UAE courts do not have exclusive jurisdiction over the dispute, and the foreign court had jurisdiction under its own rules of international jurisdiction.
   
2. The judgment was issued by a court in accordance with the law of the issuing state and is duly authenticated.
   
3. The parties were summoned and properly represented.
   
4. The judgment has the force of res judicata (it is final) under the law of the court that issued it.
   
5. It does not conflict with a judgment or order of a UAE court, and contains nothing contrary to public order or morals in the UAE.

Article 225 gives priority to treaties the UAE has joined. Judgments from Arab League and GCC states can travel under the 1983 Riyadh Arab Convention and the 1996 GCC Convention, and the UAE has bilateral judicial treaties with some states, such as France and China. Article 222 also ties enforcement to the conditions the issuing state applies to UAE judgments, so lawyers look at how that country treats UAE judgments. For English judgments, commentators point to a 2022 Ministry of Justice letter to Dubai Courts accepting reciprocity — ask your lawyer how it applies to your case.

Each treaty has its own list of required documents, and they are not identical to Article 222. Get the list for your route before ordering certified copies abroad, because going back to a foreign court registry for one missing certificate can cost weeks.

1. Obtain certified copies from the foreign court registry.
   
2. Have them legalised by the foreign ministry of the issuing state, then by the UAE embassy or consulate in that state. The UAE is not a party to the Apostille Convention, so an apostille alone is not the end of the chain.
   
3. Attest them at the UAE Ministry of Foreign Affairs once they arrive in the UAE.
   
4. Have the full set translated into Arabic by an MOJ-licensed legal translator, so the translation and the legalised originals are filed together.
   
   For how attestation and certified translation fit together, see our MOFA attestation guide and certified vs notarised vs attested translation.

The execution judge decides on the papers, and the law sets a short timetable: the petition is decided within five days of filing. There is no hearing at which a confusing translation can be explained. Points that cause trouble in practice:

• The operative part. Amounts, currency, interest rate, the date interest starts and costs orders must be rendered exactly; the judge executes what the Arabic says.
  
• Finality language. “Final and conclusive”, “no appeal lodged within time” and “leave to appeal refused” mean different things. The Arabic must not upgrade or downgrade them.
  
• Service wording. Default judgments are examined closely on condition 3, so the translation of service certificates must keep dates, addresses and methods exactly as in the original.
  
• Party names. The Arabic spelling of each party must match their UAE records (trade licence, Emirates ID, passport). See name spelling mismatches between documents.
  
• Common-law terms. Words such as “summary judgment”, “consent order”, “costs to be assessed” or “freezing order” have no single Arabic equivalent; a legal translator explains them rather than inventing a literal phrase.

Article 223 applies the same rules to foreign arbitral awards, but awards are usually enforced under the New York Convention — see our guide to translating commercial arbitration awards for enforcement. The DIFC and ADGM courts work in English under their own recognition rules, so an English judgment filed there may need no Arabic at that stage; Arabic comes back into play when execution reaches onshore assets. Our comparison of onshore courts vs DIFC and ADGM explains the language rules.

For an onshore court, yes. Proceedings are in Arabic, and the judgment and supporting documents are filed with a legal translation by an MOJ-licensed translator, alongside the legalised originals.

Possibly. Article 222 applies without a treaty, subject to its five conditions and to how the issuing state treats UAE judgments. Your lawyer will assess this; the document preparation is the same.

No. The UAE is not a party to the Apostille Convention, so documents go through legalisation by the issuing state and the UAE embassy, then UAE MOFA attestation.

The law requires the execution judge to decide the petition within five days of filing, and the decision can be appealed. That speed is why the file should be complete and correctly translated on day one.

Arabic⇄English legal translation is AED 60 per 200-word page (excl. VAT), with same-day delivery available. For long judgments we agree a delivery date with you and translate the short supporting certificates first.

We translate foreign judgments, finality certificates, service records and powers of attorney into Arabic for UAE execution files, keep the terminology consistent across the whole set, and flag mismatches in names or dates before you file. Our court judgment translation in Dubai and Abu Dhabi pages cover the service itself.

This article is general information about the translation and document side of the matter. It is not legal advice. Laws, procedures and fees change; confirm current requirements with the court or authority concerned and take advice from a lawyer on your own case.

Send us the judgment and the certificates you have, and tell us which court your lawyer will file in. Smart World Legal Translation – Sole Proprietorship L.L.C. (SWLT) is a UAE Ministry of Justice-licensed legal translation company in Abu Dhabi and Dubai, led by Dr. Hani Elimam. Our federal accreditation is accepted across the UAE, including by Dubai Courts, and we hold exclusive interpretation contracts with the UAE Federal Courts and the Federal Public Prosecution. Arabic⇄English legal translation is AED 60 per 200-word page (excl. VAT), with same-day delivery available. Send your documents on WhatsApp (+971 50 864 8439), email info@swlt.ae, or use our contact page.