Arbitration in the Middle East

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This Overview guides practitioners to core resources on arbitration in the Middle East, with links to primary legislation, institutional rules and practical guidance. The region is a significant seat and place of enforcement for disputes arising out of energy, construction and cross‑border investment, and many jurisdictions have modernised their frameworks in line with the UNCITRAL Model Law.

Key issues include choice of seat and forum (onshore courts versus common law free zones such as the DIFC and ADGM), selection of institutional rules, and extent of court support for interim measures and evidence. Practitioners should understand the UAE Federal Arbitration Law No. 6 of 2018 (as amended), the DIFC Arbitration Law 2008 and ADGM Arbitration Regulations 2015; Saudi Arabia’s Arbitration Law 2012 and Enforcement Law 2012; Qatar’s Arbitration Law 2017; Bahrain’s Arbitration Law 2015; and Egypt’s Arbitration Law 1994.

Institutional developments include the DIAC Rules 2022, the SCCA Rules 2023 and CRCICA’s 2024 Rules. Enforcement remains central: most states are parties to the New York Convention, but public policy, arbitrability, capacity of state or state‑owned entities, and mandatory rules can affect recognition and annulment. The Overview also...

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