UAE Judicial Committee Confirms Only Final Page of Arbitral Awards Requires Signature

On 4 August 2025, the Federal and Local Judicial Principles Unification Authority (the Authority) of the United Arab Emirates issued a landmark ruling in <span class="news-text_italic-underline">Application No (1) of 2025</span>, clarifying that only the final page of an arbitral award must be signed by the tribunal for the award to be valid and enforceable.

This decision resolves conflicting interpretations by courts in different Emirates regarding Article 41 of the Federal Arbitration Law (Federal Law No. 6 of 2018) (“<span class="news-text_medium">FAL</span>”), which requires arbitral awards to be signed by the tribunal but does not specify how those signatures must appear.

Previously, UAE courts had adopted divergent approaches. In <span class="news-text_italic-underline">Civil Cassation No. 403/2020</span>, the Dubai Court of Cassation interpreted Article 41 strictly. It annulled an order approving enforcement of an arbitral award on the grounds that only the last page was signed, even though that page did not contain the tribunal’s reasoning or dispositive section. The court held that such omission breached the formal requirements of the FAL and amounted to a violation of public policy.

By contrast, in <span class="news-text_italic-underline">Civil Cassation No. 5/2024</span>, the Ras Al Khaimah Court of Cassation held that signing the final page of the award was sufficient. The court found no requirement under UAE law or the New York Convention for arbitrators to sign every page and rejected the view that the absence of such signatures could constitute a public policy breach.

To resolve this inconsistency, the matter was referred to the Federal and Local Judicial Principles Unification Authority through <span class="news-text_italic-underline">Request No. (1) of 2025.</span> In a decision 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 if the signatures of the arbitrators appear on the final page.
• There is no statutory obligation for arbitrators to sign every page of the award.
• Imposing such a requirement on foreign arbitral awards cannot be treated as a public policy issue, as neither the FAL nor the New York Convention imposes it. Only clear and serious procedural breaches may be regarded as public policy violations.

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The Authority emphasised that adopting a stricter approach would undermine the New York Convention’s purpose of promoting the recognition and enforcement of arbitral awards.

This ruling is binding on all UAE courts, establishing a uniform standard for determining compliance with the formal signature requirements for arbitral awards. It provides much-needed clarity for arbitral tribunals and parties operating in the UAE, confirming that signing the final page of an award is sufficient for enforcement.

The decision removes a procedural uncertainty that previously gave rise to enforcement challenges, strengthens the UAE’s reputation as a pro-arbitration jurisdiction and aligns its practice with international standards.

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<span class="news-text_medium">Case Reference:</span> <span class="news-text_italic-underline">Decision No. (1) of 2025 (Federal and Local Judicial Principles Unification Authority, 4 August 2025)</span>.