The UAE’s bilateral judicial treaties, and which of them reach arbitral awards

The answer, in one table

Every row we mark verified was read in an official text of the treaty itself, in the language given. Rows marked unverified mean we could not obtain the text — not that the treaty does not cover awards.

One point of context before the detail. The UAE acceded to the New York Convention on 21 August 2006, and every counterparty above is a Convention party except Somalia. So for eight of the nine, the bilateral treaty is an alternative rather than a necessity — and in two of them it is a markedly worse alternative.

France — Article 17

The instrument is the Convention relative à l’entraide judiciaire, la reconnaissance et l’exécution des décisions en matière civile et commerciale, signed at Paris on 9 September 1991 — not 1992, which is the year of the French authorising statute, and which is the date most summaries give. It entered into force on 1 March 1993 and the French Ministry of Justice still cites it as the governing framework.

Arbitral awards are not an afterthought here: Chapter V is titled la reconnaissance et l’exécution des décisions judiciaires et des sentences arbitrales. Article 17 provides that awards made in either state are recognised and enforced if, in addition to the chapter’s conditions so far as applicable to arbitration, three further conditions are met: a written arbitration agreement; a subject matter arbitrable under the law of the state where enforcement is sought; and production of a certified copy of the agreement empowering the arbitrators.

There is no express requirement of a certificate of enforceability from the seat. That is the significant difference from Jordan and India. But the architecture leaves a real question open: Article 17 applies the chapter’s conditions “dans la mesure où celles-ci sont applicables à l’arbitrage”, and Article 16 requires, for judgments, documents establishing that the decision is enforceable in the state of origin. Whether Article 16 reaches awards is unresolved on the text, and we found no decision. We do not state it either way.

One condition deserves a warning because it has no analogue in the New York Convention. Article 13(1)(b) imposes the French contrôle de la loi appliquée: the law applied must be the one designated by the requested state’s conflict rules, unless both laws yield the same result. If that is held applicable to awards, it is a far more intrusive condition than anything in Article V. Against that, Article 15 bars any review of the merits and permits partial enforcement.

The convention contains no compatibility clause and no more-favourable-regime clause. We read the whole of the final chapter; that is a verified absence rather than a gap.

Jordan — Article 25, and double exequatur

The Agreement on Legal and Judicial Cooperation was signed at Amman on 24 April 1999 and ratified by Jordan by Law No. 12 of 2000, published in the Official Gazette on 4 February 2000.

Article 25 recognises arbitral awards and enforces them in the same manner as judgments, bars the enforcing authority from examining the subject matter of the arbitration, and lists five closed refusal grounds: non-arbitrability under the law of the enforcing state; a void arbitration clause or contract, or an award that has not become final; arbitrators lacking competence; parties not duly notified; and anything contrary to public order or public morals.

Then the sting. The party seeking enforcement must produce a certified copy of the award accompanied by a certificate issued by the judicial authority confirming that it has acquired the executory formula («شهادة صادرة من الجهة القضائية تفيد اكتسابه للصيغة التنفيذية»). That is a UAE court step before the Jordanian application — structurally the same trap as Riyadh Article 37, and here it is on the face of the text rather than a matter of construction.

The treaty contains no clause preserving other treaties and no more-favourable-regime clause. So the relationship between this bilateral and the Riyadh Convention — both of which bind the UAE and Jordan — is unresolved on the bilateral text. That matters, because as we explain on the Riyadh page, Jordan never accepted the 1997 amendment to Article 69, so the original Article 69 governs between the two states, and the original prohibits parties agreeing contrary to the Convention.

The practical conclusion for a Jordanian debtor is unattractive but clear: both treaty routes demand a UAE court act, and the New York Convention does not. Which instrument a Jordanian court will insist on is a question for Jordanian counsel.

India — Article XXV, and three things not to conflate

The India agreement puts arbitral awards in its own title: … for the Service of Summons, Judicial Documents, Commissions, Execution of Judgements and Arbitral Awards. Signed at New Delhi on 25 October 1999, in Hindi, Arabic and English, with English prevailing on divergence.

Article XXV requires a written arbitration agreement and a subject matter arbitrable under the law of the requested state and not contrary to its public policy. And at Article XXV(2), expressly: the party seeking enforcement “shall produce a copy of the award accompanied by a certificate of the competent judicial authority in the Requesting State to the effect that the award is executable”. Double exequatur, in terms.

Note also how thin the refusal grounds are. Article XXV does not incorporate the ten grounds that apply to decrees under Article XX. There is no due-process ground, no excess-of-mandate ground, and no set-aside-at-the-seat ground — nothing resembling Article V.

Now the part that is most often got wrong. There are three separate India-side questions and they are routinely run together:

• Section 44A of the Code of Civil Procedure. India declared the UAE a reciprocating territory by notification in the Gazette of India of 17 January 2020, listing the UAE superior courts including the ADGM and DIFC courts. This is about judgments and decrees. It says nothing whatever about arbitral awards.
• Section 44(b) of the Arbitration and Conciliation Act 1996. An award is a “foreign award” in India only if made in a territory the Central Government has notified as one to which the New York Convention applies. We could not locate such a notification for the UAE. We also cannot prove its absence by searching, and we do not assert it.
• Article XXV of the bilateral treaty — a third thing again.

If the commentary is right that no section 44(b) notification exists for the UAE, then Article XXV, with its double exequatur, is the only India-side treaty route for a UAE-seated award. That is material enough that we would put it to Indian counsel as the first question on any India file, rather than assume either way.

Morocco — Article 21, and a live supersession risk

The instrument we were able to read is the agreement on judicial cooperation, notifications, letters rogatory, enforcement of judgments and extradition, signed at Abu Dhabi on 18 January 1978, published in the Moroccan Bulletin Officiel of 4 August 1993, and in force from 17 February 1987. Not 2006, which is the date commonly given.

Article 21 makes arbitral awards enforceable in either state, bars examination of the subject matter, and gives six refusal grounds: non-arbitrability under the law of the enforcing state; a void arbitration clause or agreement; arbitrators lacking competence; parties not properly summoned; anything contrary to public order or morals; and an award that is not final under the law of the state where it was rendered.

That last ground is a finality requirement, which is not the same as a prior declaration of enforceability. On its own terms Article 21 is materially lighter than Jordan’s Article 25 or India’s Article XXV(2). As with France, there is an unresolved question whether a neighbouring provision — here Article 19, on documents for judgments — reaches awards. We do not state it either way.

Article 22 is sometimes described as a more-favourable-treaty clause. It is not. It is a negative compatibility clause: the chapter does not apply to judgments against the government of the enforcing state or its officials acting by reason of office, nor to judgments whose enforcement would be incompatible with treaties in force in that state.

China — a verified negative, and why it helps

Secondary sources list a UAE–China treaty among those covering award enforcement. It does not cover arbitral awards. We read the official Chinese text of the Agreement on Judicial Assistance in Civil and Commercial Matters, signed at Beijing on 21 April 2004 and in force from 12 April 2005, and the conclusion rests on three independent features of the instrument:

• Article 4(2) is an exhaustive list of three items — service of summonses and judicial documents, taking of evidence on request, and recognition and enforcement of court decisions and court-mediated settlements. Awards are not among them.
• Article 17(2) defines the operative term court-only: a decision means, whatever its designation, any decision rendered by the competent courts of the two parties in judicial proceedings. An arbitral tribunal is neither.
• The word 仲裁 (arbitration) appears in no article of the treaty.

Far from being a problem, this produces the cleanest position of any treaty on this page. Article 4(3) provides that the agreement does not affect the parties’ rights or obligations under other treaties or arrangements. So as between the UAE and China, a UAE-seated award travels under the New York Convention, expressly undisturbed, with no bilateral instrument adding conditions to it.

The four we could not verify

We confirmed from the UAE Ministry of Foreign Affairs register that judicial cooperation agreements with Egypt, Syria, Sudan and Somalia exist. We could not obtain a usable text of the award provisions of any of them, so this page states nothing about whether they reach arbitral awards.

• Egypt — signed Cairo 5 February 2000; approved by Presidential Decree No. 464 of 2000 and published in the Egyptian Official Gazette of 3 May 2001. We verified the general provisions, service at Articles 9 to 14 and letters rogatory at Articles 15 to 22. The gazette scan we could obtain stops at Article 24, before the chapters on judgments and arbitration. Egypt was the destination we most wanted to answer, and we cannot.
• Syria — the Syrian Ministry of Justice hosts the text, but the site presents an expired TLS certificate. We did not disable certificate validation to read a government source we intended to publish on, and the archive fallback was unavailable.
• Sudan — the registered title covers mutual legal assistance in criminal matters, extradition, and cooperation in civil, commercial and personal status matters. It conspicuously does not mention enforcement of judgments. That is a reason for suspicion that it is principally an assistance and extradition treaty, but suspicion is not a finding.
• Somalia — the commonly cited date of 1972 is wrong. It is contradicted by the UAE Ministry of Justice’s own international cooperation register, and it appears to be a conflation with a UAE federal decree of 1972 concerning a multilateral Arab League judgments convention rather than a Somalia bilateral. We give no date at all, because the register is criminal-side and its dates do not establish one for the civil instrument. Note separately that Somalia is not a New York Convention party, which makes it the one destination here where a bilateral treaty might be the only route — and the one where we know least.

A problem on the UAE side

Something worth recording, because it affects how any of these treaties is cited in a filing. We could not verify a UAE Federal Decree number for a single one of the nine treaties.

That is not for want of looking. The UAE legislation portal’s justice and judiciary sector holds domestic legislation only — civil transactions, civil procedure, evidence, the federal judiciary — and no bilateral treaty ratification instruments at all, with treaty coverage effectively beginning in 2017. The Ministry of Justice legislation database was unreachable. Decree numbers do circulate for most of these treaties, but every one we found rests on a blog, a law journal or a press report, and some conflict with each other. One number that recurs in searches, “Decree No. 41 of 1999”, is in fact Bahrain’s instrument ratifying the Riyadh Convention, not a UAE instrument at all.

So we cite these treaties by their signature date and by the counterparty’s own publishing instrument, which we have read, rather than by a UAE decree number we have not. If a filing requires the UAE instrument, it is obtainable from the Ministry of Justice or the Official Gazette archive, and we would get it rather than cite a number from the internet.

Two further treaties exist that the usual list omits: judicial cooperation agreements with Nigeria and Serbia, whose UAE ratification instruments are on the legislation portal. Whether either reaches arbitral awards we have not examined.

And a caution about reading negatives from official registers. The UAE Ministry of Justice publishes an international cooperation register of 66 agreements, each with the treaty attached — but it is entirely criminal-side: mutual legal assistance in criminal matters, extradition, and transfer of sentenced persons. It has no civil or commercial bilateral category at all. Egypt, Syria and Sudan are absent from it, and that absence means nothing about whether a civil treaty with them exists. It is exactly the kind of official-looking negative that invites over-reading.

Finally, these bilaterals do not operate in isolation. The same register holds the Riyadh Convention, the GCC Convention, and the 1952 Arab League Convention on the Enforcement of Judgments. For an Arab League or GCC counterparty, a bilateral treaty is one layer among several, and which of them a destination’s court will apply is not answered by the bilateral text.

What we produce in the UAE

The answer differs by destination more sharply here than anywhere else in this series, and that is the point of the page.

For Jordan and India, a bilateral filing needs a UAE court act first — a ratification action under Article 55 of the Federal Arbitration Law, to the President of the competent Court of Appeal, and then a certificate in the form the destination demands. India wants a certificate “that the award is executable”; Jordan wants one that it has acquired the executory formula. Those are not obviously the same document, and we would settle the wording with local counsel before applying.

For France and Morocco, the award articles do not demand that certificate, so the ordinary UAE-side pack applies: certified award, certified arbitration agreement, consular legalisation through MOFAIC and the destination’s mission in the UAE, and the UAE-law evidence on finality.

For China, ignore the bilateral entirely and go under the Convention.

And in every case the prior question is whether to use the bilateral at all. A bilateral treaty is worth using only where it is better than the Convention. On these texts, France and Morocco might be; Jordan and India plainly are not, because both demand a court step the Convention does not.

What this page does not state, and why

• That the 1978 Morocco convention is the operative instrument today. The 2006 Rabat convention exists and its effect is unresolved. This is the single issue most capable of making an otherwise-correct page wrong, and we would rather say so than paper over it.
• Anything about the Egypt treaty and arbitral awards. We verified Articles 1 to 24 and the text we could obtain stops there. Secondary sources describe an Article 38 on arbitral awards; we have not read it, and there is a demonstrated risk of confusion with other Egyptian bilateral agreements and with Article 38 of the UAE Federal Arbitration Law.
• Any UAE Federal Decree number, for any of these treaties. See above.
• Entry-into-force dates for India, Jordan, Egypt, Syria, Sudan or Somalia. Each turns on an exchange of instruments we could not date. France (1 March 1993), Morocco (17 February 1987) and China (12 April 2005) we can give.
• Any signature date for Syria, Sudan or Somalia, and in particular not “Somalia 1972”.
• That there is no section 44(b) notification for the UAE in India. We could not find one, and an absence of this kind cannot be established by searching.
• Whether Article 16 of the France convention, or Article 19 of the Morocco convention, reaches arbitral awards. Both are open questions of construction on which we found no decision, and both would add a document requirement if answered against the creditor.
• Which instrument an Arab destination’s courts will insist on where a bilateral treaty and the Riyadh Convention both bind. Jordan’s bilateral has no compatibility clause at all, so its own text gives no answer.

Sources

• France — Convention signed Paris 9 September 1991, authentic in French and Arabic; French text read in the United Nations Treaty Series, vol. 1721, No. I-29991. French approval by law of 18 December 1992, published by decree of 15 March 1993 in the Journal officiel of 24 March 1993. Entry into force 1 March 1993 per the UNTS registration data. Scope confirmed against the French Senate’s report on the approval bill and the French Ministry of Justice country sheet in its current 2026 version.
• Jordan — Agreement signed Amman 24 April 1999; full Arabic text read on the portal of the Jordanian Prime Ministry’s Legislation and Opinion Bureau. Ratification Law No. 12 of 2000, Official Gazette No. 4423 of 4 February 2000.
• India — Agreement signed New Delhi 25 October 1999; scanned signed original read on the Indian Ministry of External Affairs treaties database, English text prevailing. Section 44A notification: Gazette of India, Extraordinary, Part II Section 3 Sub-section (i), 17 January 2020, G.S.R. 38(E).
• Morocco — Agreement signed Abu Dhabi 18 January 1978; Arabic text read in the Bulletin Officiel No. 4214 of 4 August 1993, as published by dahir of 28 May 1993, from the Moroccan Ministry of Justice copy. The 2006 Rabat convention, published by dahir in 2011, was not read.
• China — Agreement signed Beijing 21 April 2004; official Chinese text read on the PRC Ministry of Justice site; entry into force 12 April 2005 per the PRC Ministry of Foreign Affairs. Chinese, Arabic and English equally authentic, English prevailing on divergence; the English original was not obtained, though the finding does not turn on translation.
• Egypt — Presidential Decree No. 464 of 2000 and the treaty text from the Egyptian Official Gazette No. 18 of 3 May 2001, pages 611 onwards; the obtainable scan ends at Article 24.
• Existence of the Syria, Sudan and Somalia agreements — the UAE Ministry of Foreign Affairs bilateral agreements register.
• New York Convention status — United Nations depositary record. UAE accession 21 August 2006. All counterparties above are parties except Somalia.
• Federal Law 6 of 2018 on Arbitration, as amended by Federal Decree-Law 15 of 2023 — Article 55, the ratification action, and Articles 53 and 54(2).

Checked 4 November 2026. Treaty texts were read in French, Arabic, English and Chinese as stated; English renderings of the French, Arabic and Chinese are ours. Destination procedure and the current standing of each instrument are confirmed with correspondent counsel before filing; we act on the UAE side.

UAE award, and a bilateral treaty in the picture?

The first question is usually whether to use the bilateral at all, because for Jordan and India it costs you a UAE court step that the New York Convention does not. Send us the award and the destination and we will tell you which instruments are open, which is better on its text, and what the UAE side has to produce.

Instruct us   Back to the series