The UAE’s Federal- Local Judicial Principles Unification Authority settles the Signatures Controversy on all the pages of the Arbitral Awards (8/10)

5 min 2 sec February 18, 2026 (Edited) الترجمة العربية

Written by

Dr. Hassan Arab

Partner, Regional Head of Dispute Resolution

h.arab@tamimi.com View LinkedIn Profile

Hend Al Mehairi

Associate

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Dina Assar

Senior Knowledge Lawyer

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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 which is: must an arbitral award be signed by arbitrators on all the pages of the Arbitral Award, or is a signature on the final page sufficient for the award’s validity and enforcement? The decision unified divergent “conflicting principles” of the UAE’s higher courts, aligned practice with international standards, and helped curb purely formal objections that may obstruct enforcement of arbitral awards.

For arbitration users the answer matters enormously. As the requirement to sign all pages of an arbitral award becomes the first procedural ground relied upon when the opposing  party seeks to annul or obstruct/delay its 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 inconsistent with the UAE courts’ general pro-arbitration direction. 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.

Background: Doctrinal Divide

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 every page of the award to be signed.

Despite that lack of clarity and 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. More recently, Dubai courts were granting parties an opportunity to return to the arbitral tribunal after issuance of the award to remedy this procedural issue by signing all pages, so that the award would not be vulnerable to annulment.

The Ras Al-Khaimah Court of Cassation and, in multiple precedents,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.

Jurisdiction 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 (President of the Federal Supreme Court) 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.

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 and reinforces the UAE’s position as a forum attractive for international arbitration.

– 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. There is no place for importing court-judgment formalities into arbitration. An unduly formalistic approach invites dilatory tactics, burdens the judiciary, and erodes confidence in the arbitral process.

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 provides a compelling reference model: interpret the Arbitration Law purposively to achieve its objectives, invoke the spirit of the New York Convention, and avoid formalities that obstruct the swift enforcement of contractual obligations.