Signing an arbitral award on each and every page can often be a daunting task, and arbitrators generally prefer to sign only the final page. Nevertheless, the absence of a signature on any page has historically been one of the most commonly invoked grounds for setting aside an award or its enforcement in the UAE and this technical omission has frequently been relied upon as a basis to challenge arbitral awards.
On 4 August 2025, the Federal-Local Judicial Principles Unification Authority issued its landmark Decision No. (1) of 2025, clarifying the legal position regarding this requirement in the UAE’s Arbitration landscape. The Authority confirmed that the failure to sign(signature) each and every page of an arbitral award does not constitute a ground for annulment under Article 53 of the Federal Arbitration Law.
Prior to this ruling, there was a high risk that an award rendered by a foreign tribunal or an onshore UAE-seated arbitration could be deemed unenforceable by the courts for the sole reason that the tribunal had not signed each page. As a result, signature-related objections often became the first line of defence for a party seeking to challenge its enforcement. Although UAE has generally taken a pro-enforcement approach, judicial interpretation of Article 41 of the Federal Arbitration Law has not always reflected this stance. The recent judgment addresses this inconsistency, resolves the different practices across emirates, and reinforces the UAE’s commitment to a pro-enforcement framework.
Article 41(3) of the UAE Arbitration Law (Federal Law No. 6 of 2018), states that “The award shall be signed by the arbitrators. If one of the arbitrators refuses to sign the award, the reasons for refusal shall be stated. The award shall be legally valid if it is signed by a majority of the arbitrators. This Article does not expressly require the arbitral tribunal’s signature on every page of the award, or on the pages containing the dispositive section and reasoning for the award.
Although this article nowhere requires that every page of the arbitral award be signed, the Court of Cassation has consistently ruled that the arbitral tribunal must sign both the operative part and the reasoning of the award, and that failure to do so results in the award being invalid.
This blog is a part of our Arbitration: An Introduction with Special Reference to the United Arab Emirates Blogpost.
History of Enforcement Challenges over Signature
Even prior to the promulgation of the new Arbitration Law of 2018 we have seen similar practice. In Dubai Court of Appeal Case No. 371-203, the award was successfully challenged during enforcement proceedings and annulled by the Court of First Instance. Upholding the annulment, the Court of Appeal held that the Tribunal had failed to sign the award in accordance with Article 212(5) of the Civil Procedures Law, which (later replaced by the Federal Law No. 6 of 2018) provided that an arbitral award must be signed but did not expressly specify where on the award the arbitrators’ signatures were required.
On 21 April 2022, the Dubai Court of Cassation delivered its judgment in Case No. 109/2022, which confirmed that under the UAE arbitration procedural law, an arbitral tribunal, whether a sole arbitrator or a panel, must sign the pages of the award that contain both the reasoning and the dispositive section. Failure to do so may result in the award not being enforceable before the onshore UAE courts.
In Case No. 403/2020 (15 April 2020), the UAE Court of Cassation refused to enforce a foreign-seated arbitral award because the arbitrator had signed only the last page and not the reasoning section. The court relied on Article III of the New York Convention (1958), which requires enforcement in accordance with the procedural rules of the enforcing state, and held that the relevant procedural rules were not complied. By interpreting Article 41(3) of the UAE Arbitration Law, the court ruled that an arbitral award must be signed on both the dispositive and reasoning sections, and failure to do so renders it invalid.
The conflicting judicial approach
As seen from above, the judicial practice across the various Emirates of the UAE has not been consistent, leading to a considerable degree of uncertainty for parties relying on arbitration. For instance, certain courts, most notably the Dubai Court of Cassation, have taken a strict stance by holding that arbitrators are required to sign every page of the arbitral award to ensure its validity. In contrast, other courts, such as those in Ras Al Khaimah and Abu Dhabi Court of Cassation, have adopted a more flexible approach, considering a signature on the final page of the award to be sufficient. This divergence in interpretation has left arbitration users unsure of the precise requirements necessary to safeguard enforceability of their awards before UAE courts.
In its judgment in Civil Cassation No. 5/2024 dated 21 May 2024, the Ras Al-Khaimah Court of Cassation held that the requirement of signatures is satisfied even if the arbitrators sign only the final page of the award. The court reasoned that insisting on signatures on every page would improper and would thereby undermine the very legislative intent behind arbitration as a streamlined and efficient alternative to litigation. Such a rigid approach, the court emphasized, could unnecessarily hinder the enforcement of arbitral awards. The Abu Dhabi Court of Cassation has also adopted a somewhat similar stance. In Case No. 834/2010 (Commercial Appeal) decided on 30 December 2010, it ruled that arbitrators need only sign the last page of the award, even if that page does not contain any part of the reasoning section, thereby indicating a more relaxed interpretation of the formal requirement of signatures.
This divergence in judicial interpretations across the Emirates exposes parties to unnecessary risks, leaving otherwise valid arbitral awards open to challenge on purely procedural grounds. Such inconsistencies undermine the efficiency and reliability of arbitration in the UAE.
Analysis of the Judgment No. 1 of 2025
Decision No. (1) of 2025, issued by the Committee for the Unification of Federal and Local Judicial Principles at the Supreme Federal Court, has finally settled the long-standing debate regarding the signature requirement in arbitral awards.
The Committee clarified that a signature on the final page of the award is sufficient to satisfy the statutory mandate. Importantly, the ruling emphasizes that the requirement to sign serves a functional and evidentiary role rather than a rigidly formalistic one. The arbitrators’ signature operates as confirmation that they have deliberated on and adopted the award in its entirety. By signing the concluding page where the dispositive and operative sections are typically mentioned, the arbitrators collectively endorse all of the preceding content. Therefore, there is no legal necessity to sign every individual page of the award.
The Committee further held that non-compliance with this practice does not provide a valid ground under Article V of the New York Convention to resist enforcement or annulment of an award. It also confirmed that the absence of signatures on each page does not constitute a violation of UAE public policy under Article 4 of the Convention. In reference to public policy, the Committee observed that it must be construed narrowly, consistent with international practice favouring enforcement of arbitral awards.
In line with this reasoning, the Committee highlighted that the New York Convention itself does not impose an obligation to sign every page of the award. The essential requirement is that the award must be duly authenticated and bear the arbitrators’ signatures in a manner sufficient to establish its validity and integrity. Accordingly, the Committee concluded that failure to sign each page does not constitute a ground for annulment under Article 53 of the UAE Federal Arbitration Law.
Position in India
Both India and the UAE have demonstrated a firm commitment to arbitration, being signatories to the New York Convention, 1958, and having adopted the UNCITRAL Model Law, thereby reinforcing the enforceability of arbitral awards across their jurisdictions. However, unlike the UAE, India has never faced challenges to arbitral awards on the ground that they were not signed on every page. The Delhi High Court in M/S Pragya Electronics Pvt. Ltd. v. M/S Cosmo Ferrites Ltd. & Anr., AIR ONLINE 2021 DEL 895, clarified that an award is not invalid merely because it does not bear the arbitrator’s signature on each page or is typed in multiple fonts. What matters is the arbitrator’s authentication of the award as a whole.
Pivotal moment in the UAE’s arbitration jurisprudence
Decision No. (1) of 2025 not only marks a pivotal moment in the UAE’s arbitration jurisprudence but also aligns its enforcement framework with global practices. It is more than just a technical clarification and serves as a breath of fresh air for arbitration in the UAE. By putting to rest the long-standing confusion over signature formalities, the ruling restores confidence. Therefore, much like India and other common law jurisdictions, the UAE has now affirmed that what truly matters is the authenticity and integrity of the award, rather than the number of pages bearing the weight of a signature.
