Enforcing E-Awards in GCC and MENA

4 min 31 sec January 18, 2026 (Edited)

2025 was a transformational year in the Gulf Cooperation Council (“GCC”) and Middle East and North Africa (“MENA”) regions for digitalisation on the dispute resolution front. The past year saw the courts in Kuwait and Oman going fully digital for commercial cases, including arbitration-related, resulting in significant ease of enforcing arbitral awards; Jordan saw the introduction of an electronic filing system in their courts (though still in pilot); Iraq launched electronic signatures; and a new arbitration law is underway in the Kingdom of Saudi Arabia (“KSA”), expressly allowing electronic signatures of arbitral awards, amongst other major changes. Countries in the region are recognising the growing need for reliable arbitration services in line with modern technology and have put noticeable effort and resources into developing these areas. Central to this development is the region’s growing legal and practical acceptance of electronically signed arbitral awards (“E‑Awards”).

Jurisdictions Which Are Ahead

In the United Arab Emirates (“UAE”), a dual judicial ecosystem with both civil law (onshore) and common law (offshore), E-Awards are looked at positively.

The onshore UAE Arbitration Law (Federal Law No. 6 of 2018, amended 2023) expressly permits electronic signatures on arbitral awards; enforcement applications are filed online via the online court infrastructure, making wet‑ink inspection largely irrelevant in practice. The UAE onshore courts tend to be pro-arbitration, having recently moved away from formalistic award signature requirements on every page of an arbitral award seated in Dubai. The UAE Federal–Local Judicial Principles Unification Authority held in its Decision No.1 of 4 August 2025 that it was sufficient for only the final page of the arbitral award to be signed.  Additionally, the Abu Dhabi Court of Cassation in Case No. 839,885 of 2025, recognised that an “arbitration agreement [i]s deemed to have met the writing requirement if it […] was made by means of an electronic message in accordance with the rules in force in the State regarding electronic transactions”. By extension, the same logic may apply to the recognition and enforcement of E-Awards, although a clear precedent to that effect would be welcome by the UAE courts in 2026.

Offshore, the Abu Dhabi Global Market (“ADGM”) Arbitration Regulations 2015 expressly validate electronic signing of awards. While the Dubai International Financial Centre (“DIFC”) Arbitration Law No. 1 of 2008 retains the traditional “writing and signed” language with no express recognition of electronically signed awards, the DIFC courts are generally arbitration-friendly.

KSA’s broader electronic transactions framework supports electronic signatures (see, KSA’s Electronic Transactions Law (Royal Decree No. M/18 of 2007)). Enforcement of judgments in KSA prioritises digitalisation, reducing the practical weight of wet‑ink. KSA’s draft 2025 arbitration law expressly allows arbitrators to sign arbitral awards from outside KSA and by way of an electronic signature (in Article 52(4)). In the context of a recent United Nations Commission on International Trade Law (“UNCITRAL”) mandated Working Group II work on E-Awards, KSA officially reported openness to compliant electronic signatures, while noting that prior ministerial authentication of a signature may be required before the enforcement of foreign seated E-Awards are allowed. This is largely due to the divergent technical standards currently existing on verification of electronic signatures across the region.

Like the UAE, Qatar is a dual jurisdiction ecosystem, operating the civil law system within the Qatar courts, while the Qatar Financial Centre (“QFC”) is operating in a common law system.

Qatar’s arbitration statutes, which include Qatar Law No. 2 of 2017 on Arbitration in Civil and Commercial Matters and the QFC Arbitration Regulations 2005, are largely silent on electronic signatures of arbitral awards and therefore, the analogy for the enforceability of electronic signatures come from the broader electronic transactions legislation. Overall, the courts infrastructure in Qatar and the QFC have recently undergone a significant digital transformation. In June 2025, new QFC Court Rules were introduced which require, amongst others, that all filings be made by the parties electronically, either by email or through the QFC Courts’ eCourt system. The Qatari onshore court system is following suit – although the infrastructure has not yet transformed into an exclusively digital one.

Where Caution Remains

Other jurisdictions in the region tread their trajectory towards digitalisation cautiously.

In Bahrain, judiciary implemented technology allowing electronic processes to cover the full litigation process. While it is positive that Bahrain reported at the UNCITRAL in 2025 that electronic signature of arbitral awards would not result in their non-enforcement, the Bahraini Arbitration Law No. 9 of 2015 is silent on the issue, leaving room for tactical challenges.

Oman is moving fast towards E-Awards having established modernised e‑transactions law and introduced a new digital‑first Court of Investment and Commerce with mandatory e‑filing in 2025, but caution is advised until more precedents emerge within the newly adopted e-based framework.

Egypt is the clearest conservative outlier in the region: despite electronic signature legislation, paper‑based workflows and reported practice suggest courts may still expect authenticated wet‑ink awards. Similarly, Kuwait, Jordan, Iraq and Morocco are uneven. Notably, while Morocco has expressly recognised electronic arbitral awards in the underlying arbitration law (Law No. 95‑17 of 2022, Article 51), its courts remain paper‑submission only.

As of summer 2025, Kuwait’s judiciary went fully digital in commercial matters, including arbitration-related cases: the Sahel app was introduced, and parties can now opt out for e-filings. Similarly, in Jordan, in summer 2025, new laws were enacted allowing lawyers to file and sign submissions electronically without appearing in person (though in pilot yet). In Iraq, the recent Instructions No. 1 of 2025 officially launched electronic signatures, although their court infrastructure still requires physical documents.