UAE judicial committee clarifies signature requirements for arbitration awards

*This update was originally published on Practical Law Arbitration on 18 September 2025 and is reproduced with the permission of Thomson Reuters.

In Application No (1) of 2025, the Federal and Local Judicial Principles Unification Authority issued a landmark ruling, which clarified that arbitral awards issued in the United Arab Emirates need only be signed on the final page. This ruling resolved conflicting case law from different Emirates on whether arbitrators must sign every page of an award or only the final page.

On 4 August 2025, the UAE's Federal and Local Judicial Principles Unification Authority (Authority) issued a landmark ruling that only the final page of an arbitral award must be signed by the tribunal.

Article 41 of the Federal Arbitration Law (Federal Law No 6 of 2018) (FAL) specifies that arbitral awards must be signed by the tribunal. However, it does not specify how they are to be signed and was subject to divergent judicial interpretations.

In Civil Cassation No 403/2020, Dubai's Court of Cassation adopted a strict interpretation of article 41 of the FAL. An order approving an arbitral award for enforcement was challenged on the basis that it breached public policy, as the tribunal had only signed the last page of the award. As the signed page contained neither the tribunal's reasoning, nor the dispositive, the court held the award did not meet the requirements of the FAL, and rejected the enforcement application.

By contrast, the Ras Al Khaimah Court of Cassation ruled, in Civil Cassation No 5/2024, that only a signature on the final page is necessary. It rejected the idea that signing every page is a public policy requirement and confirmed that the absence of such signatures does not prevent recognition under the New York Convention (Convention).

Request No (1) of 2025 was brought before the Authority to resolve these inconsistencies. In a judgment delivered under the chairmanship of His Excellency Judge Mohammed Hamad Al-Badi, the Authority ruled that:

• An arbitral award is valid and enforceable in the UAE where the signatures of the arbitrators appear on the final page.
• There is no statutory requirement for the tribunal's signatures to appear on every page.

The Authority stressed that imposing such a condition on foreign awards cannot be treated as a public policy matter. Neither the FAL nor the Convention requires it, and only clear, serious breaches can constitute public policy violations. To hold otherwise would undermine the Convention's goal of facilitating recognition and enforcement.

The Authority's ruling is binding on all UAE courts, creating a uniform standard for assessing compliance with the form requirements for awards. Arbitral tribunals and parties can now have confidence that signing the final page of an award is sufficient for enforcement. The decision eliminates a technical hurdle, reduces scope for challenges and aligns the UAE with international practice, reinforcing its position as a leading arbitration hub in the region.

Case: Decision No (1) of 2025 (Federal and Local Judicial Principles Unification Authority) (4 August 2025).