The UAE’s Federal-Local Judicial Principles Unification Authority Settles the Signature Controversy in Arbitration Awards

On 4 August 2025 the Federal-Local Judicial Principles Unification Authority issued its landmark Decision No. (1) of 2025, finally harmonising conflicting precedents emanating from the higher courts of the United Arab Emirates on a deceptively simple—yet frequently fatal—procedural question: must an arbitral award be signed by all arbitrators on every page, or is a signature on the final page sufficient for the award’s validity and enforcement?

For arbitration users and counsel the answer matters enormously. The formality of signatures often becomes the first line of attack when a resisting party seeks to annul or resist enforcement. Divergent rulings from the Dubai Court of Cassation, the Abu Dhabi Court of Cassation, and the Ras Al-Khaimah Court of Cassation produced genuine legal uncertainty and encouraged tactical challenges that undermined the UAE’s pro-arbitration policy. The Authority’s carefully reasoned decision restores predictability, aligns UAE practice with international norms, and underscores the commercial imperative of limiting technical objections that delay the finality of arbitral determinations.

1. Background: A Tale of Two Doctrines

Article 41 of the Federal Arbitration Law No. 6 of 2018 sets out the formal contents of an arbitral award. It refers to the “signature of the arbitrator who rendered the award” but does not prescribe that each page be separately signed.

Despite that textual economy, the Dubai Court of Cassation developed a strict formalist doctrine, most recently crystallised in Civil Cassation No. 403/2020 (judgment of 13 November 2020). Dubai held that the absence of the arbitrators’ signatures on every page rendered the award void ab initio: the tribunal’s signature constituted “the sole documentary foundation that proves the arbitrators’ intent.” In Dubai’s view, an unsigned page could not be deemed part of the dispositive award and therefore failed the public-order threshold for enforcement.

The Ras Al-Khaimah Court of Cassation and, in several instances, the Abu Dhabi Court of Cassation, adopted the opposite stance. In Civil Cassation No. 5/2024 (judgment of 21 May 2024) Ras Al-Khaimah concluded that a signature on the final page satisfied the statute. Requiring signatures on every page would, it reasoned, import into arbitration the formalities of ordinary civil judgments, contradict the legislative purpose of providing an expedited alternative to court litigation, and risk unreasonably frustrating enforcement.

Because neither doctrine was clearly predominant, parties found themselves trapped in a forum-dependent lottery. A Dubai-seated award could be routinely invalidated for a perceived technical defect, whereas the same award would survive in another Emirate. The inconsistencies jeopardised the attractiveness of the UAE as a regional arbitration hub and ran counter to the uniform obligations the State undertook when acceding to the 1958 New York Convention.

2. Jurisdiction and Composition of the Unification Authority

Article 15 of Federal Law No. 10 of 2019 on the Organisation of Judicial Relations between Federal and Local Judiciaries empowers the Federal-Local Judicial Principles Unification Authority to resolve conflicts between “final principles” issued by any of the State’s higher courts. The Public Prosecutor, as well as the presidents of those courts, may trigger the Authority’s jurisdiction.

Acting on that mandate, the Federal Public Prosecutor filed Petition No. (1) of 2025 on 26 March 2025. The panel, chaired by His Excellency Judge Mohammed Hamad Al-Badi and comprising eight senior judges from across the federation, convened at the Federal Supreme Court’s seat in Abu Dhabi and deliberated extensively on the competing doctrines before delivering its judgment on 4 August 2025.

3. The Authority’s Ruling

The Authority endorsed the more liberal Ras Al-Khaimah line of authority and overruled the Dubai doctrine. In unequivocal terms, it held:

1. An arbitral award is valid, enforceable, and compliant with Article 41 of the Federal Arbitration Law when it bears the signatures of all arbitrators (or the majority, where applicable) on the final page of the written award.

2. There is no statutory requirement that the signatures appear on each individual page.

3. A failure to sign every page does not amount to a ground for annulment under Article 53 of the Federal Arbitration Law, nor does it constitute a breach of UAE public order within the meaning of Article 4 of the New York Convention.

In reaching this conclusion the Authority reasoned as follows:

• Legislative Text and Purpose – Neither Article 41 of the Federal Arbitration Law nor any provision of the Civil Procedures Law expressly demands multiple signatures. Imposing such a requirement would violate the principle that no formalities may be invented by judicial interpretation in the absence of explicit legislative command.

• International Harmonisation – The New York Convention, incorporated into UAE domestic law by Federal Decree No. 43 of 2006, does not mandate multi-page signatures. Most leading arbitral seats recognise a single signature block. Aligning the UAE standard with that practice furthers the Convention’s pro-enforcement bias.

• Public-Order Considerations – A missing signature on internal pages does not impair the parties’ procedural rights, the transparency of the award, or the verifiability of the tribunal’s conclusions. Accordingly, it cannot implicate the narrow concept of UAE public order.

• Principle of Pro-Arbitration Efficiency – Arbitration was designed to avoid the technical traps that characterise ordinary civil procedure. An unduly formalistic approach invites dilatory tactics, burdens the judiciary, and erodes confidence in the arbitral process.

4. Consequences for Practitioners and Parties

1. Uniform Standard Across All Emirates
   The decision binds every court in the federation, federal and local alike. Practitioners may now rely on a consistent rule: signatures on the award’s final page suffice.

2. Reduced Annulment Risk
   Parties can no longer invoke multi-page signature defects as grounds for setting aside or resisting enforcement. Challenges must focus on substantive violations enumerated in Article 53 of the Federal Arbitration Law.

3. Drafting and Procedural Guidance
   Tribunals seated in the UAE should continue to comply with best practice—ensuring clarity in the dispositive section, dating the award, and affixing arbitrators’ signatures in a conspicuous location on the concluding page. However, they need not incur the cost or logistical difficulty of initialling hundreds of pages.

4. International Enforcement Strategy
   Because the UAE’s internal standard now mirrors global norms, UAE awards are less likely to face formalistic obstacles abroad, and foreign awards are less vulnerable to public-order objections domestically.

5. Judicial Economy
   The Authority’s ruling removes a fertile ground for procedural skirmishes, freeing court resources for disputes that implicate substantive justice rather than clerical formalities.

5. Looking Ahead

The Authority’s intervention exemplifies the utility of a central mechanism to reconcile divergent judicial views in a federal system that houses multiple autonomous cassation courts. Its choice to privilege efficiency over excessive formalism signals a judiciary increasingly attuned to commercial realities and international expectations.

While the signature dispute has been settled, practitioners should anticipate further petitions where federal and local precedents collide—particularly in areas such as the limitation periods for award enforcement, the scope of arbitrability, and the standards for impartiality challenges. The Authority’s latest decision sets a persuasive template: interpret the Arbitration Law purposively, heed the New York Convention’s spirit, and resist formalities that obstruct the swift vindication of contractual bargains.

For now, the message is simple and welcome: in the UAE, a well-reasoned arbitral award signed on its final page stands on solid legal ground.