On 4 August 2025, the UAE’s Federal and Local Judicial Principles Unification Authority (the “<span class="news-text_medium">Authority</span>”) issued a significant judgment in Application No (1) of 2025, settling a long-standing debate on the signature requirements for arbitral awards. The Authority confirmed that it is sufficient for the tribunal to sign only the final page of an award, clarifying that there is no statutory obligation to sign every page.
The issue stemmed from divergent interpretations of Article 41 of the Federal Arbitration Law (Federal Law No 6 of 2018). While Article 41 requires arbitral awards to be signed, it does not specify the manner in which signatures must appear. Courts in different Emirates had adopted inconsistent approaches.
In Civil Cassation No 403/2020, the Dubai Court of Cassation took a strict stance, ruling that enforcement of an award breached public policy where only the last page was signed. Conversely, the Ras Al Khaimah Court of Cassation in Civil Cassation No 5/2024 held that a signature on the final page was sufficient and that requiring signatures on every page was not a public policy matter under the New York Convention.
To resolve the conflict, the Authority, chaired by His Excellency Judge Mohammed Hamad Al-Badi, ruled that:
The ruling, which is binding on all UAE courts, creates a uniform standard and removes a technical ground for challenging awards. By aligning with international practice, the decision enhances legal certainty and reinforces the UAE’s standing as a leading arbitration hub in the region.
<span class="news-text_medium">Case:</span> <span class="news-text_italic-underline">Decision No (1) of 2025 (Federal and Local Judicial Principles Unification Authority)</span>, 4 August 2025.
