Tom’s Top Ten: Key Developments in International Arbitration in the Gulf in 2025

Looking back at 2025, here are ten notable developments in international arbitration in the Gulf region setting the stage for 2026:

1. Active UAE arbitration users: UAE users were among the top users of arbitration at the ICC (ranking tenth overall), LCIA (ranked fifth overall), and the SIAC (ranking eighth overall) (based on 2024 caseload statistics announced in 2025). 

2. Saudi Arbitration Law: Saudi Arabia published a new draft arbitration law for public consultation, aiming to align even more with the UNCITRAL Model Law and international best practices. 

3. QICCA Rules: The Qatar International Center for Conciliation and Arbitration (QICCA) updated its arbitration rules to provide for expedited procedures, electronic submissions and digital signatures, and consolidation and joinder.

4. Bahrain International Commercial Court: The Bahrain International Commercial Court (BICC) was established, with the possibility of appeals being made to the Singapore International Commercial Court (SICC). The BICC is expected to serve, among other roles, as a specialist forum for arbitration-related litigation. 

5. Signing of awards: The UAE Federal and Local Judicial Principles Unification Authority held that arbitral awards need only be signed on the last page, addressing long-running uncertainty on signature formalities in the UAE. 

6. Anti-suit injunctions issued by tribunals: The Dubai Court of Cassation confirmed that arbitral tribunals can issue binding anti-suit injunctions, overturning an earlier decision by the Dubai Court of Appeal finding that they could not. 

7. Delineating jurisdiction in Qatar: The Qatar Financial Centre (QFC) Court ruled that non-QFC parties can designate the QFC as the seat of the arbitration and the QFC Court as the supervisory court in their arbitration agreement, provided that the agreement is clear and precise. 

8. Delineating jurisdiction in the UAE: Dubai’s Conflicts of Jurisdiction Tribunal ruled that the DIFC Courts lacked jurisdiction to hear an enforcement application concerning an award from an onshore Dubai-seated arbitration where an annulment application was filed in the onshore courts.

9. DIFC-LCIA clauses: The enforceability of DIFC-LCIA arbitration clauses continued to percolate through national court systems with the U.S. Court of Appeal for the Fifth Circuit in the United States and the Ontario Superior Court of Justice in Canada confirming that such clauses remain valid (following similar outcomes in Abu Dhabi and Singapore in 2024).

10. Permanent Court of Arbitration: The Permanent Court of Arbitration (PCA) in The Hague signed a host-country agreement with Bahrain – its first with a Middle Eastern state.