Cross-border enforcement

Enforcing a United Arab Emirates judgment in Germany

No treaty and no EU regulation cover this direction. The United Arab Emirates has not signed the 2019 Hague Judgments Convention, so recognition in Germany runs through Germany's own procedure: automatic recognition under §328 ZPO, followed by a separate action to make the judgment enforceable. This falls inside non-enforcement as a refusal type, and the route works, but it is slower and more exposed to review than any treaty-based one.

Applicable regime

There is no bilateral treaty between the United Arab Emirates and Germany governing recognition of civil judgments. The 2019 Hague Judgments Convention does not reach this pair either: it entered into force on 1 September 2023 [N001], and the European Union joined for all member states except Denmark on 29 August 2022, with effect from that same date, including for Germany specifically [N003][N154]. The United Arab Emirates is neither among the seven contracting parties nor among the six states that signed without ratifying [N002][N011]. No EU regulation reaches this pair either: Brussels Ia's automatic recognition applies only between EU member states, and the intra-EU route Germany otherwise relies on does not extend to a non-member state [N018][N144].

The applicable regime is Germany's own procedural law. Recognition of the foreign judgment happens automatically under §328 ZPO, but that recognition produces no enforceable title on its own; a separate exequatur action before the competent Landgericht is required before enforcement measures can follow [N519]. On the United Arab Emirates side, foreign judgments are only enforced there on the same terms UAE judgments are enforced abroad, a reciprocity test running in the opposite direction from the one described here [N103]. How that test plays out is examined on the reverse route, enforcing a German judgment in the United Arab Emirates.

What the destination court will check

Before enforcement measures can start, the exequatur claim goes through a checklist that is cumulative, not alternative:

• A separate exequatur claim must be filed and served according to German procedure, since recognition under §328 ZPO does not by itself create an enforceable title [N519].
• The claim is filed before the Landgericht with jurisdiction over the debtor, carrying a fixed court fee under item 1510 of the German fee schedule [N553].
• Supporting documents must be legalised for use before a German court, and translated where necessary (see Documents below).

Beyond this procedural layer, the court also reviews the substance of the foreign judgment. That substantive review is not reduced to a fixed public checklist in the verified record available here; it is assessed case by case. See the Germany jurisdiction profile for how this fits the wider domestic enforcement landscape.

What will not go through

Two categories will not travel down this route.

• Arbitral awards. If the underlying decision is an arbitral award rather than a court judgment, it moves under the 1958 New York Convention, a separate and wider route that does not depend on any Hague instrument or German autonomous procedure [N016]. Filing it as if it were a court judgment is a common and avoidable error.
• Decisions outside private civil and commercial matters. Tax assessments, customs rulings and administrative orders issued by United Arab Emirates authorities do not qualify for exequatur in Germany under this civil procedure route, regardless of how the underlying claim is framed.

A further trap concerns settlements. A UAE court-approved settlement is not automatically treated the same way as a contested judgment once it reaches a German court; how it is characterised affects which conditions apply, and that characterisation is made case by case. See how this refusal pattern is analysed generally under non-enforcement as a refusal type.

Documents

Documents issued in the United Arab Emirates for use before a German court cannot be apostilled. The UAE is not a party to the 1961 Apostille Convention, so legalisation runs through the consular chain rather than a single certificate: authentication in the UAE followed by legalisation at the German mission with jurisdiction over the document. Once legalised, documents in Arabic need a certified translation into German before they can be filed. Filing mechanics for this destination sit at the Germany enforcement hub.

Timing

Once a German court grants exequatur, the underlying right is subject to Germany's general thirty-year limitation period, running from the point the original judgment became legally final; the same thirty-year period applies if the underlying decision is an arbitral award rather than a court judgment [N516][N517]. Filing the exequatur action itself suspends this period, so a creditor who acts before it lapses does not lose the underlying claim while the German proceeding is pending [N518].

The exequatur claim carries a fixed court fee under item 1510 of the German fee schedule, payable on filing [N553]. On the United Arab Emirates side, whether any limitation period has already run against the underlying claim before it reaches Germany is not settled by a verified registry entry here; it is determined by the applicable law and needs checking against the specific judgment. General limitation mechanics across jurisdictions are compared at limitation periods in cross-border enforcement.

If the primary route is closed

If the underlying dispute was resolved by arbitration rather than litigation, the award moves under the New York Convention instead of this route, and that path does not depend on any bilateral or Hague instrument between the UAE and Germany [N016]. This is normally faster to raise than restarting analysis under German autonomous law.

Where no arbitration clause exists and the underlying decision is a court judgment, a conduit strategy is sometimes considered: obtaining recognition in a jurisdiction with a more direct treaty relationship to the United Arab Emirates, then relying on that decision as the basis for a further claim elsewhere. Whether that shortens anything depends entirely on the treaty network of the intermediate jurisdiction and is not assumed to work here. For contracts still being drafted, an arbitration clause avoids this problem going forward rather than solving it retroactively. Enforcement running from the United Arab Emirates is mapped more broadly at enforcement originating in the UAE.

What to do before filing

Filing an exequatur action without knowing where the debtor's assets sit in Germany risks a judgment that recognises the right but enforces nothing. Map asset location, corporate structure and recent transfers before filing, not after. Whether an interim measure can hold assets in place while the exequatur action runs depends on the file; it is not a general yes or no and needs checking against the specific facts. Filing also carries a cost exposure if the court finds the underlying decision does not meet its conditions, so the case should be assessed before the fee is paid. This sits under cross-border recognition and enforcement. The firm does not work on success-only fees, and its registration can be checked in the public register.