Cross-border enforcement
Enforcing a Malta judgment in the United Arab Emirates
A Malta judgment does not travel into the UAE under any EU-based instrument. Enforcement is decided under Federal Decree-Law No. 42/2022, applying the UAE's own cumulative conditions, including reciprocity. DIFC and ADGM run separate, non-interchangeable tracks alongside the mainland route.
Applicable regime
The applicable statute is Federal Decree-Law No. 42/2022, article 222, in force since 2 January 2023, which replaced the earlier Federal Law No. 11 of 1992 and Cabinet Resolution No. 57 of 2018. No Hague or EU-based convention connects Malta and the UAE for this route; recognition runs on domestic UAE statute applied to a foreign judgment, not on a treaty. On the Malta side, the judgment must have become res judicata, since UAE courts treat finality as a separate, mandatory condition. DIFC and ADGM operate outside this mainland statute and are addressed as separate tracks further down this page. The broader picture, including the reverse direction, sits in the routes for enforcement originating in Malta and enforcement running from the UAE back to Malta.
What the destination court will check
UAE courts apply a set of conditions that are cumulative: all of them must be satisfied, not merely one. The court of origin must have been competent under its own procedural law. The judgment must comply with the law of the country where it was rendered. The parties must have been properly served and represented. The judgment must be final. It must not conflict with an existing UAE judgment on the same matter. It must not contain anything contrary to UAE public policy or morals. And reciprocity must exist: the UAE judgment must be enforceable in Malta on the same basis on which the Maltese judgment is sought to be enforced in the UAE.
What will not go through
Public policy is read broadly by UAE courts, particularly where a case touches Sharia principles, family law or inheritance; a commercial Maltese judgment that brushes against these areas carries a real risk of being blocked on this ground alone, even where every other condition is met. Foreign interim and injunctive orders generally do not travel at all, because UAE courts treat them as not final. A judgment that conflicts with an existing UAE ruling on the same dispute is excluded outright. Reciprocity failure is not abstract: if Malta would not enforce the equivalent UAE judgment, the UAE side can refuse on that basis alone. None of this is specific to non-enforcement refusals generally, but it explains why this category of refusal recurs on this particular route.
Documents
The UAE is not a party to the Apostille Convention, so an apostille placed on a Maltese document is not accepted by UAE authorities, courts, banks or licensing bodies. The document instead needs the full consular chain: notarisation in Malta, certification by Malta's Ministry of Foreign Affairs, legalisation by the UAE embassy or consulate in Malta, and finally attestation by MOFAIC once the document reaches the UAE. Every document must also be translated into Arabic by a translator licensed by the UAE Ministry of Justice; translations from unlicensed sources are not accepted. Background on UAE court practice sits on the UAE jurisdiction page.
Timing
On the UAE side, the enforcement application goes to the enforcement judge, who is directed to issue an order within five working days of filing. Execution before Dubai courts carries a fee of two percent of the sum enforced; a challenge by review costs twenty-five percent of the first-instance fee, an appeal fifty percent, with an appellant's deposit of 1,000 AED. No confirmed limitation period for bringing this application in the UAE is in the registry, so it is determined by applicable law and needs to be checked against the specific claim. On the Malta side, the judgment carries a general fifteen-year period for enforcement and must have reached res judicata; the registry does not fix the exact triggering event for that period, so this also needs verification against the judgment's own terms. General limitation mechanics across jurisdictions are set out on the limitation periods page.
If the primary route is closed
DIFC runs a separate conduit route: the DIFC Courts are competent to ratify a judgment, order or award from any recognised foreign court, and the DIFC Court of Appeal has confirmed that this conduit function can be used to bring a foreign judgment onshore before enforcing it through the wider UAE court system. ADGM offers a comparable registration mechanism for foreign money judgments, but in practice ADGM expects a genuine connection to ADGM itself and does not operate as an open conduit the way DIFC does. Where neither route fits cleanly, the wider set of enforcement paths into the UAE, including how DIFC and ADGM compare on a given claim, is mapped on the enforcement into the UAE hub.
What to do before filing
Before filing, check what the judgment debtor actually holds in or through the UAE, and how fast it can be moved. Whether a UAE court will grant a fresh interim measure to hold assets in place while enforcement proceeds depends on the facts of the case, not a general rule, and needs to be established on the papers. If the assets sit in crypto or on a trading platform, the mechanics differ; that is covered separately on the crypto and platform account refusals page. A structured view of what is actually recoverable against what the route will cost is what a cross-border recognition and enforcement engagement is built to answer. This firm does not work on a result-only fee, and its registration can be checked against the public register.