Gulf Arbitration Centres and Bangladesh in 2026: DIAC, ADGM, BCDR, QICCA, OAC, SCCA and Enforcement

Gulf arbitration centres Bangladesh parties use: the 2026 map

For Gulf arbitration centres Bangladesh businesses deal with most often, 2026 is a year of new rules and old traps. Exporters, EPC contractors, shipping lines and manpower agencies sign contracts that send disputes to Dubai, Abu Dhabi, Doha, Manama, Muscat or Riyadh, often with little thought about which institution, which seat or which law. Since 2021 the map has been redrawn: the DIFC-LCIA has gone, Abu Dhabi has a new centre, and Qatar, Bahrain, Oman and Saudi Arabia have all modernised their rules.

This guide is written for the Bangladeshi side of those contracts. It covers each major centre and its current rules, how the choice of seat changes the outcome, how Sharia limits on interest affect what an award can carry, which disputes involving workers can be arbitrated at all, and how awards move in both directions between Bangladesh and the Gulf under the New York Convention. The detailed Bangladeshi enforcement procedure is covered in companion TRW guides, linked below.

Summary: Every Gulf state is a party to the New York Convention, as is Bangladesh, so an award from DIAC, arbitrateAD, BCDR, QICCA, the OAC or the SCCA can be enforced in Dhaka under section 45 of the Arbitration Act 2001, and a Dhaka award can be enforced in the Gulf. The real risks lie earlier: an outdated institution in the clause, an unintended seat, an interest claim that a Sharia-based court will not enforce, or a dispute that local law does not allow to be arbitrated.

Key point: The seat, not the centre, decides the law of the arbitration and the court that supervises it. A DIAC or arbitrateAD clause with no seat now defaults to a common-law free zone, the DIFC or the ADGM, while a Saudi or Omani seat brings civil-law courts and, in Saudi Arabia, a firm refusal to enforce interest.

At a glance

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Table of Contents

Why the Gulf arbitration centres Bangladesh contracts name now matter

The Gulf is where many Bangladeshi commercial relationships end up in dispute. Garment and food exporters sell to Gulf distributors, Bangladeshi contractors and subcontractors work on Gulf projects, shipowners and charterers trade through Gulf ports, and recruiting agencies sign service agreements with Gulf employers. Most of those contracts are drafted by the Gulf counterparty, and the dispute clause is usually theirs.

Three features of the region make the clause matter more than usual. First, several states have two legal systems side by side: a civil-law onshore system and a common-law financial free zone with its own courts. Second, institutions have merged, closed or been renamed, so a clause drafted before 2022 may name a body that no longer exists. Third, Sharia remains a source of law and public policy, which affects interest, penalties and some types of claim.

The good news is that the enforcement framework is complete. Bangladesh acceded to the New York Convention on 6 May 1992 without declarations or reservations, and the United Arab Emirates, Saudi Arabia, Qatar, Bahrain, Oman and Kuwait are all parties.[1] An award from any of the Gulf arbitration centres Bangladesh parties use can therefore travel to Dhaka, and a Dhaka award can travel to the Gulf. The institutions themselves are summarised below.

Seat first, centre second

The first question in any dispute involving the Gulf arbitration centres Bangladesh companies encounter is where the arbitration is seated. An arbitral institution administers the case: it receives the request, appoints or confirms arbitrators, collects fees and, in some centres, scrutinises the award. The seat is different. It fixes the procedural law of the arbitration and the courts that can support it, hear challenges and set the award aside. A Bangladeshi court has no power to annul an award made at a Gulf seat; in July 2026 the High Court Division held that the power of annulment "belongs exclusively to the courts exercising supervisory jurisdiction at the seat of arbitration".[2]

Onshore and free-zone seats

In the UAE, an onshore seat in Dubai or Abu Dhabi brings the Federal Arbitration Law, Federal Law No. 6 of 2018, and the onshore courts. An ADGM seat brings the ADGM's own regulations and courts, with English common law applying directly save for bespoke ADGM legislation.[8] The DIFC in Dubai works on a similar model. Qatar has the same split: the Qatar Financial Centre applies English common law, and the QFC Arbitration Regulations give its courts exclusive jurisdiction over appointments, interim relief, enforcement and set-aside where the QFC is the seat.[10]

Why the difference matters to a Bangladeshi party

The choice changes outcomes. Interest is the clearest example: onshore UAE awards carry simple interest, while ADGM awards can carry compound interest.[8] Time limits also differ. A party wishing to annul an award made under Qatar's Arbitration Law, Law No. 2 of 2017, has only one month, against three months under the Model Law.[10] A Bangladeshi company that loses a Gulf arbitration must act at the seat within those windows, because Dhaka will not hear an annulment application. The table compares the main centres. On a phone, scroll it sideways.

DIAC: the 2022 Rules and the end of the DIFC-LCIA

The Dubai International Arbitration Centre is now the only arbitral institution of the Emirate. Many Bangladeshi parties still hold contracts referring to the DIFC-LCIA Arbitration Centre or the Emirates Maritime Arbitration Centre, so the transition is the first point to check in any Dubai dispute.

Decree No. 34 of 2021 and existing clauses

Dubai Decree No. 34 of 2021, issued in September 2021, replaced the DIFC-LCIA and the Emirates Maritime Arbitration Centre with DIAC.[6] It abolished the DIFC Arbitration Institute, which effectively ended the DIFC-LCIA, and passed the abolished centres' work to DIAC.[5] Arbitration agreements referring to the DIFC-LCIA made before the decree took effect are treated as valid, and DIAC replaces the old centre in administering them unless the parties agree otherwise.[6]

Courts outside Dubai have not all agreed. A Louisiana court refused to compel DIAC arbitration under a DIFC-LCIA clause, while the Abu Dhabi Court of First Instance, in Case No. 1046/2023, upheld such a clause and treated DIAC as the DIFC-LCIA's legal successor.[6] For a Bangladeshi party holding an old clause, the safest course is to agree in writing with the counterparty, before any dispute is filed, that DIAC will administer under its current rules. Where that agreement is not possible, expect jurisdiction to be contested.

What the DIAC 2022 Rules provide

The DIAC Arbitration Rules 2022 came into force on 21 March 2022, the date on which the transitional period under the decree expired.[5] Their main features for Bangladeshi users are these:

• Default seat in the DIFC: under article 20.1, if the parties have not agreed a seat, the initial seat is the Dubai International Financial Centre, and the tribunal makes the final determination.[6] The DIFC Courts then act as the supervisory courts.[5]
• Expedited proceedings: available in certain cases, including claims of AED 1 million or less, exclusive of interest and legal costs.[5]
• Emergency relief: an emergency tribunal is to be constituted within one day of DIAC receiving the application.[6]
• Multi-party tools: article 8 covers claims under multiple contracts and consolidation, and article 9 joinder of a third party.[6]
• Costs and funding: tribunals have an express power to award legal costs, and the rules clarify the use of third-party funding.[5]

Practical points for Bangladeshi parties in Dubai

Of all the Gulf arbitration centres Bangladesh parties meet, DIAC is the one where silence on the seat has the clearest consequence. Most Bangladeshi parties will want to choose the seat expressly rather than accept the DIFC default by silence. A DIFC seat suits a party that wants common-law supervision; an onshore Dubai seat may suit a party whose counterparty's assets are all onshore. Signature formalities also deserve attention. Article 34.6 allows electronic signature of awards subject to the seat's mandatory law, but because UAE courts have historically required wet-ink signatures, tribunals usually still sign in wet ink.[6] A Bangladeshi claimant should ask the tribunal to do so, so that formalities are not raised later at enforcement.

Abu Dhabi: the ADGM framework and arbitrateAD

Abu Dhabi offers two layers that are easily confused. The Abu Dhabi Global Market is a seat, with its own arbitration law and courts. arbitrateAD, the Abu Dhabi International Arbitration Centre, is an institution. Since 2024 the two are linked by default, but they remain legally distinct.

The ADGM as a seat

Parties do not need a business connection with the ADGM to choose it as their seat. An ADGM-seated arbitration is subject to the ADGM Arbitration Regulations and the supervision of the ADGM Courts, and English common law applies directly in the ADGM save for its bespoke legislation.[8] The Regulations, issued on 30 December 2015, closely follow the UNCITRAL Model Law and allow parties to waive or limit the right to seek set-aside by express agreement, although a waiver does not prevent refusal of enforcement elsewhere.[9]

The arbitrateAD Rules 2024

arbitrateAD replaced the Abu Dhabi Commercial Conciliation and Arbitration Centre (ADCCAC) on 1 February 2024, and its rules took effect the same day.[7] ADCCAC continues to administer cases begun before that date under its 2013 rules. For arbitrations filed afterwards under an ADCCAC clause, the new emergency arbitrator and expedited provisions apply only if the parties expressly opt in.[7] If the parties agree neither a seat nor a place, the default seat is the ADGM unless the arbitrateAD Court decides otherwise.[7]

The rules include an expedited procedure that applies automatically where the total amount in dispute, counterclaims included, does not exceed AED 9 million, with a sole arbitrator and a final award within four months. An emergency arbitrator must decide within 10 days of appointment. Third-party funders must be disclosed, manifestly unmeritorious claims can be dismissed early, and the arbitrateAD Court scrutinises every award before it issues.[7] For a Bangladeshi supplier with a mid-sized claim against an Abu Dhabi buyer, the AED 9 million threshold is the most important number in these rules.

Crossing the ADGM boundary

Winning in the ADGM is not the same as being paid in Abu Dhabi. ADGM awards are enforceable within the ADGM as if they were ADGM Court judgments, but enforcement against assets elsewhere in Abu Dhabi requires further steps.[8] There are two routes: a direct application to the Abu Dhabi courts, or an ADGM Court application to deputise the Abu Dhabi courts, available only where the outstanding debt exceeds USD 100,000. The process has been little tested, so a Bangladeshi claimant whose debtor holds only onshore assets should weigh an onshore seat at the drafting stage.[8]

Bahrain: BCDR and its statutory jurisdiction

The Bahrain Chamber for Dispute Resolution is unusual because it has two roles. It administers ordinary consensual arbitrations, and it also has a statutory jurisdiction created by Bahrain Decree-Law No. 30 of 2009.[11] Under that provision, claims above BHD 500,000, roughly USD 1.3 million, fall within it where the dispute is an international commercial dispute or at least one party is a financial institution licensed by the Central Bank of Bahrain. Decree-Law 26 of 2021 extended this to disputes between certain licensed companies.[11] A Bangladeshi bank or trader dealing with a Bahraini bank should check this before assuming it can litigate elsewhere.

The BCDR rules

The BCDR Rules of Arbitration 2022 launched on 1 October 2022 and added provisions on third-party funding and security for costs.[11] In 2022 the BCDR and the American Arbitration Association also ended their formal partnership amicably, so older clauses referring to "BCDR-AAA" should now be read, and redrafted, as references to the BCDR alone.[11] Since 2009 the centre has handled 376 cases with a cumulative value of USD 6.5 billion, with banking and finance as the largest sector and most cases concluding within 12 months.[11]

The legal framework is familiar. Bahrain's Law No. 9 of 2015 adopts the UNCITRAL Model Law in its entirety.[11] On enforcement, Bahrain's New York Convention declarations limit the Convention to awards made in another contracting state and to commercial relationships.[1] Because Bangladesh is a contracting state, a Bangladeshi commercial award meets both conditions.

Qatar: QICCA, the 2024 Rules and the QFC

The Qatar International Center for Conciliation and Arbitration was established in 2006 by a resolution of the board of the Qatar Chamber of Commerce and Industry.[10] It is the main onshore institution in Doha and the one most often named in contracts with Qatari contractors and distributors.

The QICCA rules in force

The 2024 QICCA Rules took effect on 1 January 2025, replacing the 2012 rules. They introduce joinder, consolidation, expedited proceedings, an emergency arbitrator mechanism and mandatory disclosure of third-party funding.[10] Bangladeshi parties should also note that the revised model clause asks parties to agree the seat and the number of arbitrators at the outset; an unedited legacy clause leaves both open.

Qatar's Arbitration Law

Law No. 2 of 2017 governs civil and commercial arbitration in Qatar and is based on the Model Law, with departures that catch out foreign parties. Arbitrators must come from a Ministry-approved registry unless they meet further conditions, an electronic copy of each award must be sent to the Ministry within two weeks, and the annulment deadline is one month.[10] Contracts entered into before 12 April 2017 remain governed by the Civil Procedure Code.[10]

Enforcement in Qatar has become more predictable. Qatar acceded to the New York Convention in 2002, and the Court of Cassation has held that the requirement that an award be issued "in the name of the Emir" applies only to domestic awards. Law No. 4 of 2024, the Judicial Enforcement Law, adds rules on refusal of enforcement, arbitrability and appeals.[10] For a Bangladeshi party, the alternative is a QFC seat, where English common law applies and the QFC courts supervise.[10]

Oman: the OAC arbitration rules

Oman's Arbitration Law, issued by Royal Decree 47/1997 and amended by Royal Decree 03/2007, is largely based on the UNCITRAL Model Law. The Oman Commercial Arbitration Centre was established by Royal Decree No. 26/2018.[12] It is affiliated with the Oman Chamber of Commerce and Industry.[14]

The 2020 OAC rules

The OAC's first rules took effect on 6 December 2020.[12] Under them, an expedited procedure applies where the amount in dispute is under OMR 500,000, where the parties agree, or where the centre's Executive Committee considers the matter urgent, with a sole arbitrator and a final award within three months. Emergency arbitrators are appointed within two days once an application is accepted and decide within 14 days. The tribunal must have an odd number of members, the award is due within six months of the Terms of Reference unless extended, and proceedings are private.[13]

The 2026 amended rules

On 10 June 2026 the centre launched amended Arbitration Rules 2026, alongside a new corporate identity and a digital case-management platform.[14] The stated aims are faster procedure, greater use of technology, stronger governance and transparency, and equality between the parties. Public reports of the launch did not set out the detailed changes or an effective date.[14] Any Bangladeshi party starting or defending an OAC case in late 2026 should obtain the current text from the centre and confirm which version applies to its arbitration before relying on the 2020 timetable.

Foreign awards in Oman

Oman acceded to the New York Convention in 1999 without declarations.[1] The Arbitration Law does not apply to foreign awards; their enforcement is governed by the Civil and Commercial Procedure Law, Royal Decree No. 29/2002, which includes a condition that the country where the award was made would enforce an Omani award.[12] Bangladesh's own regime, which enforces foreign awards under the Convention-based sections 45 and 46, helps a Bangladeshi award-holder satisfy that condition.[2]

Saudi Arabia: the SCCA and a law in transition

Saudi Arabia is a major market for Bangladeshi contractors, suppliers and recruiting agencies, and its arbitration landscape is changing quickly. The Saudi Center for Commercial Arbitration's current rules came into force on 1 May 2023 and apply to all arbitrations filed on or after that date.[15]

The SCCA 2023 Rules

The 2023 Rules provide an online procedure where the parties agree in writing and the amount is below SAR 200,000, emergency arbitrators who must issue their decision within 14 days of receiving the file, and early disposition of jurisdiction, admissibility and legal-merit issues. The SCCA Court determines the place of arbitration where the parties have not, and it reviews and approves awards. Each party must disclose any non-party with an economic interest in the outcome.[15]

The centre is growing quickly. It recorded 182 new filings in 2025, up 63 per cent from 120 in 2024, with construction and engineering the largest sector at 47.3 per cent.[16] Saudi courts also uphold most awards: of 194 annulment motions in judgments from January 2023 to June 2025, 174 failed, and Sharia-based annulment was granted only once.[16] Saudi courts treat the annulment grounds in article 50 of the Arbitration Law as exhaustive.[17]

The draft Arbitration Law

A draft new Arbitration Law was published on the Istitlaa' platform on 24 September 2025, with consultation closing on 25 October 2025; no enactment date has been reported.[16] The draft would remove the requirement to deposit awards with the court, require an Arabic translation only at enforcement, codify the res judicata effect of awards and make the Supreme Court the forum for appeals against enforcement decisions.[17] Until it is enacted, Bangladeshi parties should plan on the current law and treat the draft as a signal of direction, not a rule.

Interest and Sharia: what an award from Gulf arbitration centres Bangladesh claimants use can carry

Interest is the single most important difference between the Gulf arbitration centres Bangladesh claimants use and the seats they know from London or Singapore. The issue rarely affects the tribunal's jurisdiction. It arises when the award must be enforced, and it turns on the law and public policy of the place of enforcement.

Saudi Arabia: interest is not enforced

The restriction on interest, riba, is the most commercially significant public policy issue in Saudi enforcement. On 14 January 2025 the Jeddah Court of Appeal enforced the principal parts of an award, including rescission and outstanding rent, but refused to enforce a delay penalty as prohibited interest.[17] That decision shows that a Saudi court may sever the interest and enforce the rest. It also shows that a claimant who has built its case around interest may recover far less than the award states.

The practical answer is in the contract. Instead of a late-payment clause that accrues as debt, Saudi practice favours liquidated damages linked to actual, quantifiable harm.[17] A Bangladeshi exporter selling into Saudi Arabia should price for payment risk, take security such as a letter of credit, and frame any compensation for delay as damages for loss actually suffered.

The UAE: simple interest onshore

Interest is enforceable in the UAE, but the seat matters. Onshore awards carry simple interest, while awards made in the ADGM can carry compound interest.[8] Where the debtor's assets are onshore, a compound-interest claim may face resistance at enforcement even if an ADGM tribunal grants it. Claimants should present interest as a separate, clearly calculated head of relief so that it can be severed rather than taint the whole award.

Qatar: from refusal to compensation

Qatari courts traditionally refused interest, either as prohibited under Sharia or by replacing it with a lump sum fixed by the court. The Court of Cassation shifted that approach in Case No. 24 of 2018, decided on 27 February 2018, upholding an award that included interest on the basis that interest awarded by a tribunal amounts to compensation for breach of contract and is not contrary to public policy.[18] Article 1 of the Constitution still makes Sharia a main source of legislation, so the safer course is to agree in the contract that interest is compensation for late payment.[18]

Bangladesh: interest at the statutory rate

Bangladesh does not share the Sharia objection. Its Arbitration Act 2001 provides in section 38(6)(kha) for interest at 2 per cent above the bank rate set by Bangladesh Bank, unless the award directs otherwise.[4] The High Court Division nonetheless upheld the setting aside of a domestic award in December 2024 partly because it imposed 15 per cent interest with no stated basis, calling that part "totally perverse".[4] The lesson for a Gulf award to be enforced in Dhaka is the same: interest should be reasoned, with the rate and period stated.

Workers, recruiting agencies and contractors: what can be arbitrated

Many Bangladeshi dealings with the Gulf concern labour: recruiting agencies placing workers, contractors supplying crews, and employers engaging Bangladeshi staff directly. The commercial contracts in that chain, such as recruitment service agreements, labour-supply subcontracts and EPC packages, can be arbitrated like any other business contract. Individual employment claims are different.

Employment disputes in the UAE

In Clyde & Co LLP v Jalan [2026] EWHC 403 (Comm), the English Commercial Court considered a London arbitration clause in a Dubai-based employee's contract. It accepted uncontested expert evidence that employment disputes are not arbitrable under UAE law and that a clause that excludes UAE Labour Law or bypasses the Ministry of Human Resources and Emiratisation process would be considered void.[19] The court refused to find a valid arbitration agreement and indicated that it would in any event have refused an anti-suit injunction to protect the employee.[19]

What this means for Bangladeshi employers and agencies

For a Bangladeshi agency or contractor, the result has two sides. An arbitration clause in a worker's contract will not keep a wage or end-of-service claim out of the Gulf labour system, so compliance with local labour rules is the real protection. The agency's commercial claims against the Gulf employer, such as unpaid recruitment fees, deployment costs or indemnities, sit in the business-to-business contract and should carry their own carefully drafted clause. Workers' own rights and remedies, including claims in Bangladesh against recruiting agencies, are covered in our guide to migrant worker rights in Bangladesh.

Enforcing awards from Gulf arbitration centres Bangladesh courts receive

An award from DIAC, arbitrateAD, the BCDR, QICCA, the OAC or the SCCA is a foreign award in Bangladesh because the test is the seat. Sections 45 and 46 of the Arbitration Act 2001, which the High Court Division describes as provisions that "substantially incorporate the enforcement regime of the New York Convention, 1958", provide the whole route.[2] The award is enforced by execution before the District Judge, Dhaka, as if it were a decree of the court.[3]

The deadline is the trap. In February 2026 the High Court Division held that an application to execute a foreign award must be filed within three years from the date of the award, and that there is no power to condone delay.[3] A Bangladeshi party holding a Gulf award should begin authentication and translation as soon as the award issues and file in Dhaka without waiting for settlement talks to end. The documents, section 46 grounds and recent case law are set out in our guide to foreign arbitral award enforcement in Bangladesh.

Resisting a Gulf award in Bangladesh

A Bangladeshi debtor cannot ask a Dhaka court to annul a Gulf award; the remedy is to challenge at the seat within its deadline, which may be as short as one month in Qatar, or to object under section 46 when enforcement is sought.[2] [10] Ignoring the arbitration is the worst option. Where the award was made in Bangladesh instead, the challenge route is the section 42 application explained in our guide to setting aside an arbitral award in Bangladesh.

Enforcing a Bangladeshi award in the Gulf

Bangladeshi exporters and contractors increasingly hold awards from Dhaka-seated arbitrations, including under BIAC rules, against Gulf buyers and employers. Because Bangladesh is a New York Convention state, those awards qualify for Convention enforcement throughout the region, including in Saudi Arabia and Bahrain, whose declarations limit the Convention to awards made in contracting states.[1]

In the UAE

Onshore UAE enforcement now runs under the Civil Procedures Law, Federal Law No. 42/2022. The application goes to the execution judge, who must decide within five days, and the decision can be appealed within 30 days.[20] Article 223 requires the dispute to be arbitrable under UAE law and the award to be enforceable in the country of the seat, while article 225 gives treaties to which the UAE is party, including the New York Convention, precedence.[20] A Bangladeshi award-holder should therefore bring evidence that the award is final and enforceable in Bangladesh, such as confirmation that no section 42 challenge was filed within time or that one failed.

In Saudi Arabia, Qatar and Oman

Saudi Arabia's New York Convention declaration is no obstacle, because Bangladesh is a contracting state.[1] In Saudi Arabia the interest point dominates: a Bangladeshi award that includes interest, including section 38(6) post-award interest, may be enforced only as to principal.[17] In Qatar, the Convention applies and the Judicial Enforcement Law of 2024 governs refusals and appeals.[10] In Oman, the enforcing court will check that Bangladesh would enforce an Omani award, which the Convention-based Bangladeshi regime supports.[12] [2] In each case, translation into Arabic and proper legalisation of the award should be arranged in Bangladesh before filing.

Recovering the proceeds is the last step. Funds remitted from the Gulf must come in through banking channels that comply with Bangladeshi foreign exchange rules; our note on foreign exchange regulations in Bangladesh covers the inward side.

Choosing between Gulf arbitration centres Bangladesh parties use

Bangladeshi parties rarely draft the first version of a Gulf contract, but they can negotiate the clause. Our experience is that a short list of decisions, taken in order, produces a clause that works in both jurisdictions. The sequence we follow is set out below.

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When a Gulf centre is not the right choice

A Gulf institution is not always the best answer. Where the counterparty's assets are outside the region, or both sides want a neutral venue, ICC or SIAC arbitration may suit better; see our guides to ICC arbitration and SIAC arbitration for Bangladeshi parties. Where the Gulf party will accept Dhaka as the seat, the framework is explained in our guide to international commercial arbitration in Bangladesh, and the court-side changes under the new commercial courts are covered in our note on the Commercial Courts Act.

What to watch in 2026 and 2027

Three developments will shape how the Gulf arbitration centres Bangladesh businesses rely on operate over the next year. First, the OAC's amended Arbitration Rules 2026: their detailed provisions and transitional rules will decide whether existing Omani clauses pick up the new procedure.[14] Second, Saudi Arabia's draft Arbitration Law, which would move the Kingdom closer to the Model Law and change enforcement appeals.[16] [17] Third, the continuing growth of the SCCA, which makes a Riyadh seat an increasingly likely term in Saudi contracts.[16]

The common thread is that every one of the Gulf arbitration centres Bangladesh contracts now name has modern rules and every state enforces Convention awards. Disputes are lost on the points around the rules: the seat, the interest claim, the arbitrability of labour issues and the deadlines in Dhaka and at the seat. TRW advises Bangladeshi exporters, contractors, banks and agencies on Gulf clauses, arbitrations and enforcement through our international arbitration practice and construction and project disputes team, or you can contact TRW directly.

Frequently asked questions

Is a DIFC-LCIA arbitration clause still valid?

Under Dubai Decree No. 34 of 2021, agreements referring to the DIFC-LCIA are treated as valid and DIAC administers them unless the parties agree otherwise. Some foreign courts have taken a different view, so it is safer to confirm DIAC in writing with the counterparty.[6]

When did the DIAC 2022 Rules take effect?

On 21 March 2022, when the transitional period under the decree expired.[5]

What is the default seat under DIAC and arbitrateAD rules?

The DIFC for DIAC and the ADGM for arbitrateAD, in each case where the parties have not agreed a seat.[6] [7]

Is the ADGM the same as arbitrateAD?

No. The ADGM is a seat with its own Model Law-based Arbitration Regulations and courts; arbitrateAD is an institution that replaced ADCCAC on 1 February 2024.[7] [9]

Which QICCA rules apply to a new case?

The 2024 QICCA Rules, in force since 1 January 2025, with joinder, expedited proceedings, an emergency arbitrator and funding disclosure.[10]

Has the OAC changed its arbitration rules?

Yes. The centre launched amended Arbitration Rules 2026 on 10 June 2026, updating the rules in force since December 2020. Confirm the current text and its effective date with the centre.[12] [14]

Can a Gulf award include interest?

It depends on where it is enforced. Saudi courts refuse to enforce interest, onshore UAE awards carry simple interest, and Qatar's Court of Cassation has upheld interest as compensation for breach.[8] [17] [18]

Can a Gulf worker's employment claim be sent to arbitration?

Generally not in the UAE. In 2026 the English High Court accepted expert evidence that employment disputes are not arbitrable under UAE law.[19]

How do I enforce a Dubai or Riyadh award in Bangladesh?

By an execution application under section 45 of the Arbitration Act 2001, which reflects the New York Convention, before the District Judge, Dhaka, filed within three years of the award.[3]

Will Gulf courts enforce a Bangladeshi arbitral award?

Yes in principle, because Bangladesh and every Gulf state are New York Convention parties. Local conditions apply, such as the UAE's arbitrability and seat-enforceability checks and the Saudi bar on interest.[1] [20]