Recognition and Enforcement of UAE Court Decisions in Russia: A Guide for Businesses

The recognition and enforcement of a foreign court decision in Russia is a strictly regulated legal procedure. For a business that has obtained a commercial judgment in the United Arab Emirates (UAE) and seeks to execute it against a debtor’s assets located in Russia, the process requires a formal application to a Russian court of general jurisdiction or an arbitration (commercial) court, depending on the nature of the dispute. Under the current legal framework, which includes the Arbitration Procedure Code of the Russian Federation, the fundamental principle is reciprocity. The successful enforcement of a UAE judgment in Russia hinges on the existence of an international treaty between the two states or, in its absence, the principle of reciprocity, which the Russian courts have historically interpreted restrictively.

What is the Legal Basis for Recognizing a UAE Court Decision in Russia?

The legal framework governing the recognition and enforcement of foreign judgments in Russia is contained in Chapter 31 of the Arbitration Procedure Code of the Russian Federation. Article 241(1) of the APC RF states that decisions of foreign courts made in disputes arising from entrepreneurial and other economic activities are recognized and enforced in Russia by arbitration courts, provided such recognition is stipulated by an international treaty of the Russian Federation or federal law. Since there is no bilateral treaty between Russia and the UAE concerning the mutual recognition of judicial decisions, the principle of reciprocity must be applied. This principle is derived from the general framework of Article 241 and established judicial practice, which requires the Russian court to be satisfied that a court in the UAE would similarly recognize and enforce a Russian judgment under comparable circumstances.

How Does the Reciprocity Principle Work in Practice?

Under the framework established by Article 241 of the APC RF, a foreign judgment may be recognized and enforced in Russia on the basis of reciprocity, even in the absence of an international treaty. For a business seeking enforcement, this requires presenting compelling evidence that Russian judicial decisions are, in principle, enforceable in the UAE. Russian courts do not automatically presume reciprocity; the applicant bears the burden of proof. This typically involves obtaining a detailed legal opinion from a qualified expert in UAE law, confirming that there are no legal or practical obstacles to enforcing a Russian court judgment in the UAE. The Russian court will examine this evidence to determine whether the principle of reciprocity is satisfied.

Where to File the Application and What are the Deadlines?

The application for recognition and enforcement of a UAE court decision must be filed with the competent arbitration court. According to Article 242(1) of the APC RF, the application is submitted to the arbitration court of a constituent entity of the Russian Federation at the place of residence or location of the debtor, or, if such place is unknown, at the location of the debtor's property.

Article 246(2) of the APC RF establishes a strict deadline: a foreign court decision may be submitted for compulsory enforcement within a period not exceeding three years from the date it enters into legal force. If this deadline is missed, it may be restored by the arbitration court upon the petition of the claimant, following the rules outlined in Chapter 10 of the APC RF, provided the reasons for the delay are considered valid.

What Documents Are Required and What is the Procedure?

The application for recognition and enforcement is governed by Article 242 of the APC RF. The following documents must be attached:

• A duly certified copy of the UAE court decision.
• A document confirming that the decision has entered into legal force (if not indicated in the decision itself).
• A document confirming that the debtor was properly and promptly notified of the proceedings in the UAE court.
• A power of attorney or other document confirming the authority of the person signing the application.
• A document confirming that a copy of the application has been sent to the debtor.
• A duly certified translation of all these documents into Russian.

According to Article 243(1) of the APC RF, the application is considered by a single judge within a period not exceeding one month from the date it is received by the arbitration court. The court holds a hearing and notifies the parties. The debtor has the right to raise objections. The result of the hearing is a ruling on the recognition and enforcement of the foreign decision. 

What are the Common Grounds for Refusal?

Article 244 of the APC RF provides an exhaustive list of grounds for refusing recognition and enforcement. The most common grounds include:

• The decision has not entered into legal force in the state where it was rendered (Article 244(1)(1)).
• The party against whom the decision was made was not properly and promptly notified of the time and place of the hearing or could not present its explanations for other valid reasons (Article 244(1)(2)).
• The case falls under the exclusive jurisdiction of a Russian court in accordance with an international treaty or federal law (Article 244(1)(3)).
• There is a final Russian court judgment on the same matter between the same parties (Article 244(1)(4)).
• The enforcement of the foreign court decision would contradict the public policy of the Russian Federation (Article 244(1)(7)).

How to Appeal a Refusal to Recognize a UAE Judgment?

If an arbitration court issues a ruling refusing to recognize and enforce a UAE court decision, that ruling can be appealed. According to Article 245(3) of the APC RF, the ruling may be appealed through cassation to the arbitration court of the circuit within one month of its issuance. A successful appeal would require demonstrating that the lower court incorrectly applied the law, such as by misinterpreting the reciprocity principle or incorrectly applying one of the grounds for refusal listed in Article 244.

How Can We Help You?

Our firm, Law firm 'Economic Disputes', has specialized exclusively in B2B dispute resolution since 2019. The team includes 15 lawyers with 15–25 years of experience each. Director Sergey Belyavsky brings 20 years in economic courts, including 10 years as a judge; he is a recommended arbitrator at the International Arbitration Court at the BelCCI and author of 5 books and over 2000 publications. We operate our own Arbitration Court "Economic Disputes" and have 4 mediators on staff. Track record: 2000+ clients, over 1.95 billion rubles recovered or saved, 100+ reviews with an average rating of 4.95/5. We provide legal support in Russian, Polish, and English, maintain a partner network in 160+ countries, and have been a member of the Association of European Attorneys (AEA) since June 2025. For client convenience, we operate with an account at PKO Bank Polski.

If your business needs legal support for the recognition and enforcement of a foreign judgment, leave a request — we will offer a realistic plan for resolution.