Cross-border enforcement
Enforcing a Germany judgment in the United Arab Emirates
A German judgment carries no treaty support into the UAE. Neither the 2019 Hague Judgments Convention nor Brussels Ia reaches here: the UAE is party to neither. What governs is the reciprocity analysis under Federal Decree-Law 42/2022, and a document chain that is heavier than most German claimants expect.
Applicable regime
Onshore recognition runs under Federal Decree-Law 42/2022, in force since 2 January 2023, which replaced Federal Law 11/1992 and Cabinet Resolution 57/2018. There is no critical date to watch here in the way there is for UK-origin judgments, because no convention switched on: the regime has been the same throughout.
The instrument a German creditor might expect to use, Brussels Ia, stops at the EU border. It does not assist against assets held outside the Union.
What the destination court will check
Article 222 sets cumulative conditions. Failure on one defeats the application entirely.
- The German court had jurisdiction under German law
- The judgment complies with the law of the country of origin
- Parties were properly summoned and represented
- The judgment is final and binding
- No conflicting UAE judgment
- No conflict with UAE public order
- Reciprocity between Germany and the UAE
What will not go through
German provisional instruments do not travel. Protective relief obtained in Germany before judgment is not a final and conclusive decision, and UAE courts do not generally enforce foreign provisional measures. Security must be sought in the UAE itself.
The reciprocity limb is the one that most often defeats German applications, because it is assessed as a factual question about how UAE judgments fare in Germany, not resolved by pointing at a list.
Documents
This is where a German claimant loses time. The UAE is not a party to the 1961 Apostille Convention, so the apostille that suffices across the EU is worthless here. The chain is full consular legalisation: certification in Germany, legalisation at the UAE mission, then attestation by the UAE Ministry of Foreign Affairs after arrival. Documents are then translated into Arabic by a translator licensed by the UAE Ministry of Justice. Note also that the public order limb of Article 222(2)(e) is interpreted broadly by UAE courts.
Timing
The execution judge is directed to issue an order within five working days once a complete petition is before them. The legalisation chain sits before that clock starts and is typically the longer part.
German claimants have unusual room here. Section 197(1)(3) of the Civil Code applies a thirty-year period to claims established by a judgment that has become final, and the same period is applied to claims arising from an arbitral award. Filing an action for a declaration of enforceability suspends the running of that period under section 204(1)(1). Thirty years is the longest period among the twelve core jurisdictions, alongside Luxembourg.
If the primary route is closed
Where the onshore route stalls, the DIFC Courts may ratify a judgment of a recognised foreign court under Article 24(1)(a) of DIFC Law 10 of 2004, with enforcement then passing to the Dubai execution courts. DIFC Law 2 of 2025 widened that jurisdiction to disputes without a DIFC connection where both parties agree in writing.
The ADGM is not interchangeable: it expects a genuine connection and does not act as a pure conduit.
What to do before filing
Confirm the asset position before starting the document chain, not after. The legalisation sequence is the single largest sunk cost in a German-origin application and is wasted if nothing remains to execute against.