UAE Authority Issues Landmark Decision on Signature of Arbitral Awards

On 4 August 2025, the Federal Local Principles Unification Authority (the "Authority") issued a landmark decision on the signature of arbitral awards in the United Arab Emirates ("UAE"). The decision settles a longstanding debate about whether awards need to be signed on every page. Decision No. (1) of 2025 now confirms that a tribunal is required to sign an award on the final page only.

This decision will be welcomed by arbitrators, practitioners and parties. The differing approaches to signing requirements across the UAE has led to opportunistic annulment applications and a formalistic practice of having arbitrators sign each and every page of an award to avoid annulment on very technical grounds. This decision will therefore reduce the available grounds for annulment, and result in increased efficiency of arbitration.

The debate in context

Article 41 of the UAE Arbitration Law (Federal Law No. 6 of 2018) sets out the formalities for a valid arbitral award. Article 41(3) states, "the award shall be signed by the arbitrators." The UAE courts have since taken conflicting positions on whether this means that a tribunal must sign every page of the award, or the final page only.

For instance, the Dubai Court of Cassation in Case No. 403/2020 refused to enforce a foreign arbitral award on the basis that it was not signed on every page. The Court held that this breached public policy requirements under Article 53 of the UAE Arbitration Law, as it could not be said to demonstrate the tribunal’s "intent." Accordingly, only signed pages could be considered to form part of the operative part of the award. The award was therefore rendered entirely void.

By contrast, the Ras Al-Khaimah Court of Cassation has taken a more liberal approach. In Case No. 5/2024, the Court held that signing the final page only was sufficient. The Court reasoned that to construe signature formalities under Article 41 of the UAE Arbitration Law as requiring a tribunal to sign every page of an award may unreasonably stifle the enforcement process. It would also unnecessarily extend the requirements applicable to civil judgments, in the context of litigation, onto arbitration, without good reason.

Federal Local Principles Unification Authority

The function of the Authority is to resolve conflicting positions on important legal principles within the UAE, on the petition of either the Public Prosecutor, as well as any president of a local court. Accordingly, on 26 March 2025, the Federal Public Prosecutor filed Petition No. (1) of 2025 to seek finality on this question. 

The Decision

Endorsing the Ras Al-Khaimah approach, Decision No. (1) of 2025 confirms that a tribunal needs to sign an award on the final page only.

The Authority reasoned that:

1. There was no provision within the UAE Arbitration Law that required an award to be signed on every page. In the absence of this, it was not for the courts to read in this requirement independently.
2. The absence of an arbitrator’s signature on every page of an award did not violate public policy requirements under Article 53 of the UAE Arbitration Law.
3. Excessive formality would go against public policy as it could frustrate the enforcement process, increase costs and give rise to logistical challenges (for instance, in coordinating signing by three-member tribunals). This is not in accordance with the principles of justice.
4. The New York Convention, ratified by the UAE, does not require an award to be signed on every page. In fact, under the relevant rules of the seats of many jurisdictions that have ratified the New York Convention, signing the final page only is the default position. Decision No. (1) of 2025 therefore brings the UAE in line with that standard.
5. Accordingly, parties cannot rely on Article 5 of the New York Convention in order to resist enforcement on the basis that an award is not signed on every page.

Impact of the Decision

Decision No. (1) of 2025 not only reconciles conflicting jurisprudence in the UAE, but it also reinforces the latter’s position as an enforcement-friendly jurisdiction. By removing what was otherwise a potential ground for annulling an award, Decision No. (1) of 2025 ensures that annulment proceedings are instead focused on substantive violations of the UAE Arbitration Law – rather than mere formalistic ones.