UAE Arbitral Award Signature Requirement Settled
For many years there has been an inconsistency between the different Emirates in the UAE as to whether UAE arbitral law or public policy requires an arbitral award to be signed on every page or just the final page. Signing every page is often no small matter, since awards can run to hundreds of pages and at least three copies will have to be issued (more if there are multiple parties), meaning that arbitrators would sometimes have to take many hours signing hundreds of pages to ensure the award would not be invalidated for lack of a signature.
This issue has been referred to the UAE Federal and Local Judicial Principles Unification Authority (the “Unification Authority”) and has now been settled – awards only need to be signed on the last page. This brings UAE arbitral practice in line with international norms and is a practical and welcomed development.
In this article we address how the issue arose in the first place and what the judgment means for the future of arbitration in the UAE.
Background
According to the Federal Arbitral Law (UAE Federal Law 6/2018, as amended by Federal Decree-Law No. 15/2023), an arbitral award must be signed by the arbitral tribunal (or, in case of a split opinion, the majority of the tribunal) in order to be valid. This is not a unique requirement by itself. The UNCITRAL Model Law on International Commercial Arbitration on which the UAE arbitration law is based also includes this requirement.
The interpretation of this signature requirement by local courts in the UAE has, however, been unusual. Courts in Dubai have previously held this requirement to mean that the tribunal must sign more than just the last page of the arbitral award for it to be valid. In Case No. 403/2020, for example, the Dubai Court of Cassation ruled that UAE public policy required that each page of the award must be signed. Similarly, in Case No. 109/2022, the Dubai Court of Cassation ruled that an arbitral award would be void unless the tribunal signed the text of the award and the reasons.
The court’s rationale in these cases was that an arbitral award is comprised of the reasoning section and the final dispositive section. Accordingly, the legislative intent behind requiring that arbitral awards be signed was that both the reasoning and dispositive sections must be signed. A more nuanced application of this rule was seen in Case No. 1083/2019 where the Court of Cassation held that where the reasoning section of an award extends to the same page as the dispositive section of the award, an award signed only on that final page would be valid.
Courts in the other Emirates have taken a different view. Whilst in Case No. 844 of 2022 the Abu Dhabi Court of Cassation found that it was essential that the arbitrators sign the entire arbitral award, in Case No. 411/2022 the same court held that the tribunal’s failure to sign all pages of the award did not invalidate the award, despite this argument being raised by the appellant.
Similarly, in Case No. 5/2024, the Ras Al Khaimah Court of Cassation found that signatures on the final page of the award (i.e., to the exclusion of signatures on other pages of the award) satisfied the signature requirement.
The Federal Supreme Court Ruling
In light of this conflicting judicial treatment, the issue was referred to the Unification Authority. This body, established under UAE Federal Law No. 10/2019, is tasked with, amongst other things, unifying contradictory judicial principles issued by two or more courts of cassation in the UAE. The Unification Authority is composed of two judges from the Federal Supreme Court and each of the courts of cassation of each Emirate with an independent judicial system (Dubai, Abu Dhabi, Ras Al Khaimah, and Sharjah). Decisions are issued by a majority of six of the judges.
On 4 August 2025, the Unification Authority issued its final ruling. The Unification Authority observed that the Federal Arbitration Law did not expressly require signatures on every page of the award. The Unification Authority opined that the purpose of requiring signatures was to confirm the tribunal’s approval of the content of the award and that signatures on the final page of the award would suffice for this purpose. According to the Unification Authority, to require otherwise would be to endorse an overly formalistic approach that would weaken confidence in the arbitral process.
The effect of this decision is that all courts in the UAE must now comply with this interpretation of the signature requirement.
Conclusion
This is a much-needed development. Arbitrations can take years and incur significant costs, so having the award nullified simply because it was not signed on every page seemed disproportionate and undermined confidence in the UAE arbitral process. Removing this risk is therefore to be welcomed. The judgment reaffirms the UAE’s pro-arbitration stance and eliminates scope for uncertainty around judicial treatment of arbitral awards in and across the UAE.
The judgment is part of a series of updates to the UAE arbitration regime that has made the process easier and more robust. There used to be a requirement, for example, that the award had to be physically signed in the UAE (which led arbitrators flying to Dubai and signing the award at the airport to ensure its validity), but this was done away with some years ago. It is good to see that the requirement to sign on every page has similarly been consigned to history.
Challenges do still persist. For example, awards can still be nullified if the person who signed the arbitration agreement did not have the actual authority to do so. However, this recent judgment evidences that progress is continuing to be made and the courts remain supportive of arbitration.
