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The Future of Arbitration Funding in the United Arab Emirates: A Strategic Analysis for Global Business

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The legal and financial ecosystem of the United Arab Emirates (UAE) is currently undergoing a structural transformation that positions it as a global frontier for third-party arbitration funding (TPF). Historically characterized by a cautious approach to external litigation finance, the jurisdiction has rapidly modernized its regulatory, institutional, and judicial frameworks to accommodate the complexities of international commercial disputes.1 This evolution is driven by a convergence of legislative reform, such as the Federal Arbitration Law of 2018, and the proactive adoption of sophisticated funding rules by the Dubai International Arbitration Centre (DIAC) and the Abu Dhabi International Arbitration Centre (arbitrateAD).3 For businesses operating in capital-intensive sectors like construction, energy, and real estate, understanding the nuances of this landscape is no longer optional but a strategic imperative for risk management and liquidity optimization.1

The Jurisdictional Triality: Mapping the UAE Arbitration Landscape

The UAE presents a unique “tri-partite” legal architecture consisting of the onshore civil law system and two offshore common law jurisdictions: the Dubai International Financial Centre (DIFC) and the Abu Dhabi Global Market (ADGM).6 Each of these jurisdictions maintains distinct rules regarding third-party funding, creating a dynamic environment where the choice of the arbitral seat fundamentally dictates the enforceability and disclosure requirements of a funding arrangement.5

Onshore Civil Law Framework and Federal Law No. 6 of 2018

Onshore arbitration is governed by Federal Decree Law No. 6 of 2018 (the Federal Arbitration Law), which serves as the default procedural law for any arbitration conducted in the UAE, provided the parties have not agreed to a different set of laws.9 While the law does not explicitly regulate third-party funding, its silence is widely interpreted as permissive, provided the funding agreement does not contravene public policy or morals.11 The law emphasizes party autonomy, particularly in Article 4(3), which allows parties to authorize a third party to select arbitral procedures.9 This procedural flexibility suggests that as long as the funder does not exercise “undue control” over the legal process, the funding relationship remains valid under general contract principles.7

The Common Law Enclaves: DIFC and ADGM

The DIFC and ADGM have emerged as the primary engines for TPF growth due to their alignment with international common law standards.8 The DIFC Courts, through Practice Direction No. 2 of 2017, provided a structured definition of “Funding” and “Funded Parties,” emphasizing transparency through mandatory disclosure of the funder’s identity.17 In contrast, the ADGM’s Litigation Funding Rules of 2019 are more prescriptive, requiring funders to possess qualifying assets of at least $5 million and mandating that funding agreements be in writing.6 These offshore regulations provide the predictability required by institutional funders such as Burford Capital and Omni Bridgeway, who seek to mitigate the “uncertainty risk” historically associated with regional courts.6

Jurisdictional FeatureOnshore UAE (Civil Law)DIFC (Common Law)ADGM (Common Law)
Governing Arbitration StatuteFederal Law No. 6 of 2018DIFC Arbitration Law No. 1 of 2008ADGM Arbitration Regulations 2015
Primary TPF RegulationNone (Permitted by Practice)Practice Direction No. 2 of 2017Litigation Funding Rules 2019
Mandatory DisclosureCase-by-case basisExistence and Funder IdentityExistence and Funder Identity
Funder Financial ThresholdNo statutory limitNo statutory limitMinimum $5 Million in Assets
Default Seat (Rules-based)Dubai (per DIAC 2007)DIFC (per DIAC 2022)ADGM (per arbitrateAD)

3

Institutional Maturation: Analyzing DIAC 2022 and arbitrateAD 2024

The institutionalization of TPF in the UAE reached a pivotal moment with the overhaul of arbitral rules in Dubai and Abu Dhabi. These changes reflect a desire to position the UAE as a leading global hub, competitive with Singapore and Hong Kong.4

The Dubai International Arbitration Centre (DIAC) Rules 2022

Article 22 of the DIAC Rules 2022 represents one of the most significant codifications of TPF practice in the region.3 The rule requires a party to “promptly disclose” the existence of a third-party funding arrangement to all other parties and the Centre.25 A nuanced requirement within Article 22.1 is the obligation to disclose whether the funder has committed to an “adverse costs liability”.25 This provides tribunals with critical information for potential security for costs applications, as a funder’s commitment to pay adverse costs can serve as a substitute for a bank guarantee or escrow payment.6

Furthermore, Article 22.2 introduces a safeguard against conflicts of interest.25 It prohibits parties from entering into a funding arrangement after the tribunal’s constitution if the arrangement would create a conflict between the funder and any member of the tribunal.25 This mirrors the IBA Guidelines on Conflicts of Interest and ensures that the eventual award remains insulated from challenges based on arbitrator impartiality.26

The Emergence of arbitrateAD in Abu Dhabi

The transition from the Abu Dhabi Commercial Conciliation and Arbitration Centre (ADCCAC) to the new Abu Dhabi International Arbitration Centre (arbitrateAD) in early 2024 has further clarified the funding landscape.4 Under Article 48 of the arbitrateAD Rules, the duty to disclose funding is ongoing throughout the life of the proceedings.4 This institutional shift is supported by a default seat in the ADGM, which grants parties access to the ADGM’s comprehensive litigation funding framework and its evergreen application of English common law.7

The Strategic Shift: TPF as a Corporate Financial Instrument

For modern businesses, third-party funding has evolved from a “distressed” financing tool into a sophisticated method for managing corporate balance sheets.1 The use of external capital allows companies to pursue high-value claims without diverting funds from their core operations, effectively turning a legal dispute from an expense into a potential revenue-generating asset.1

Access to Justice for SMEs

Small and medium-sized enterprises (SMEs) in the UAE often find themselves in disputes with much larger, better-capitalized entities, such as sovereign-linked developers or global conglomerates.2 The costs of a major arbitration, including tribunal fees, expert costs, and legal representation, can be prohibitive.34 TPF levels the playing field by providing the financial muscle necessary to sustain a long-term legal battle.2 This is increasingly seen as a “strategic value” by boards of directors, who can now evaluate litigation through the same lens as any other investment opportunity.5

Judicial Evolution: The Recoverability of Legal and Funding Costs

A historical barrier to TPF in the UAE was the uncertainty regarding whether a successful party could recover its legal fees.15 However, landmark decisions in 2024 and 2025 have fundamentally altered this calculus, favoring a pro-arbitration and enforcement-oriented approach.12

The Reversal in Case No. 756 of 2024

Prior to 2024, the Dubai Court of Cassation frequently annulled parts of arbitral awards that granted legal fees, citing a lack of explicit authority in the Federal Arbitration Law.12 This culminated in Case No. 821 of 2023, where an ICC award’s cost allocation was quashed despite the parties’ agreement to follow the ICC Rules.37

In a dramatic reversal, the Court of Cassation in Case No. 756 of 2024 (Commercial) held that if parties agree to arbitrate under specific institutional rules (like those of the ICC or DIAC), they are bound by those rules’ provisions on cost recovery.37 The Court recognized that Article 38(1) of the ICC Rules, which includes “reasonable legal and other costs,” constitutes an “express and clear” agreement by the parties to allow the tribunal to allocate such costs.37 This decision provides immense comfort to funders, as it significantly increases the likelihood that their initial investment (the legal fees advanced) will be reimbursed by the losing party.37

Recoverability of Funder’s “Success Fees”

While legal fees are now broadly recoverable, the recoverability of the “success fee” or “uplift” paid to a funder remains a contested area.44 Under standard English law principles, which often influence DIFC and ADGM thinking, funding costs are generally not recoverable as “costs of the arbitration” unless exceptional circumstances exist.46 However, the case of Essar Oilfields v. Norscot demonstrated that if a respondent’s conduct was so egregious that it forced the claimant into the arms of a funder, the tribunal might exercise its discretion to award the funding premium as a form of indemnity.47 In the UAE, while silent on this specific point, the emphasis on the tribunal’s discretion in the DIAC 2022 and arbitrateAD 2024 rules suggests that a well-reasoned claim for funding costs could theoretically be upheld if the parties have expressly included “financing costs” within their arbitration agreement.38

Navigating Legal and Ethical Constraints: Sharia and Professional Conduct

Businesses must also consider the ethical and religious framework of the UAE, which applies Sharia law principles even in commercial contexts.11

Sharia Compliance and Maslaha

TPF is generally considered compliant with Sharia law under the principle of maslaha (public interest).11 By providing access to justice, funders perform a socially beneficial role.11 Furthermore, the Sharia prohibition on gharar (speculative or highly uncertain transactions) is typically avoided because funders do not invest in “gambles”; they invest in claims after a rigorous, evidence-based due diligence process that identifies a high probability of success (usually 60-70%).15

Legal Profession Regulation: Federal Decree Law No. 34 of 2022

The regulation of the legal profession also impacts how funding is structured.12 Under Article 49(4) of Federal Decree Law No. 34 of 2022, lawyers in the UAE are permitted to enter into contingency fee arrangements, but these are strictly capped at 25% of the recovered amount.12 It is crucial to note that this cap applies to the fee agreement between the lawyer and the client; it does not explicitly cap the return to a third-party funder, who is a financial actor rather than a legal practitioner.12 However, practitioners in the DIFC and ADGM must avoid conflicts of interest and ensure that the funder does not exert control over the lawyer’s professional judgment.7

The Impact of Dubai Decree No. 34 of 2021: Institutional Consolidation

Any analysis of the future of funding must account for the structural reorganization triggered by Dubai Decree No. 34 of 2021.52 This decree abolished the Emirates Maritime Arbitration Centre (EMAC) and the DIFC Arbitration Institute (which oversaw the DIFC-LCIA), transferring their assets and caseload to a reformed DIAC.52

For funded parties, this transition initially created significant uncertainty regarding the “unilateral forum change”.39 Some foreign courts, notably in the United States, initially ruled that a DIFC-LCIA clause could not be automatically subsumed by DIAC because the parties had contracted for a specific institutional “forum”.22 However, recent trends and the widespread adoption of the DIAC 2022 Rules have stabilized the market, with most parties opting to “regularize” their clauses to refer directly to the new DIAC to ensure their claims remain fundable and enforceable.22

Procedural Tactics: Security for Costs and Disclosure

In the high-stakes environment of UAE arbitration, security for costs has become a primary defensive tool used by respondents.57 The presence of a funder is frequently used as a catalyst for such applications.60

The Role of TPF in Security for Costs Applications

Tribunals in the UAE, following the lead of ICSID and other major bodies, generally reject the notion that the mere existence of third-party funding justifies an order for security for costs.28 Under Rule 53 of the 2022 ICSID Rules (often cited by regional tribunals), the tribunal must consider the claimant’s “ability and willingness” to pay, but funding is only one factor.57

In the DIFC, the courts have inherent jurisdiction to make costs orders against funders themselves.7 If a funder has already committed to an “adverse costs liability” as part of its LFA, the respondent’s risk is effectively mitigated, often leading to the denial of a security for costs application.6 Conversely, if the funded party refuses to disclose whether the funder covers adverse costs, the tribunal may infer a higher risk of non-payment and order security.25

Privilege and Confidentiality Risks

A critical strategic concern for businesses is the protection of legal professional privilege.5 In the UAE onshore system, which does not have a native concept of “discovery” or “privilege” in the common law sense, sharing a legal opinion with a funder during due diligence could potentially lead to a waiver.5

To mitigate this, sophisticated parties utilize “restricted waiver” agreements and ensure that all communications with the funder are conducted under the umbrella of a “common interest” in the litigation’s outcome.15 The ADGM Funding Rules specifically address this by requiring funding agreements to prohibit funders from seeking disclosure of privileged information without express consent.15

Due Diligence Checklist for Selecting a Funder

Given the influx of new capital into the UAE market, businesses must move beyond “price” and evaluate the operational stability and track record of their funding partners.6

Diligence ItemRationale for UAE ContextRisk Mitigation
Financial StrengthThe funder must meet capital calls over 5+ year durations common in MENA disputes.Review audited financial statements and proof of qualifying assets.
UAE/Regional Track RecordExperience with DIAC rules and local enforcement is vital.Request case studies on UAE-seated arbitrations.
Conflict MatrixInstitutional rules (DIAC Art 22) mandate disclosure to avoid arbitrator conflicts.Perform a conflict check against tribunal members and opposing counsel early.
Settlement ControlTPF must not result in “champerty” or loss of client autonomy.Ensure LFA gives the client the final say on settlement, with a “tie-breaker” clause.
Enforcement StrategyFunders often provide “monetization” or enforcement funding if the debtor is insolvent.Check if the funder has in-house global asset tracing capabilities.

6

Emerging Trends and 2026 Outlook

The landscape of arbitration funding in the UAE by 2026 is projected to be characterized by “institutionalization” and the integration of advanced financial technology.5

The Rise of Sovereign-Linked Funders

A significant development is the entry of sovereign-backed investment vehicles like Lunate into the broader legal finance ecosystem.67 Headquartered in Abu Dhabi and managing over $115 billion, Lunate represents the “next generation” of private capital in the region.67 While not solely focused on TPF, the move of such massive pools of capital into alternative assets signals that legal finance is becoming a core component of the UAE’s broader financial strategy to compete with the world’s leading asset managers.67

AI and Data-Driven Underwriting

As the UAE courts and arbitral centers digitize their records, funders are increasingly using AI to model “outcome probabilities”.5 The Bayan project in Abu Dhabi and the e-litigation systems in Dubai provide a data-rich environment that allows for more accurate pricing of legal risk.13 This is expected to lead to more competitive “success fees” and the availability of funding for smaller claims (below $1 million) that were previously deemed uneconomical for major international funders.5

Integration with Mediation and ADR

The “new chemistry” of settlement in the UAE involves the triad of the claimant, the lawyer, and the funder working alongside mediators.36 Because funders are “rational economic actors,” they often facilitate settlements by providing an objective valuation of the claim, which helps bridge the gap between unrealistic claimant expectations and respondent low-ball offers.5

Synthesizing the Strategic Path Forward

The United Arab Emirates has successfully transitioned from a jurisdiction where third-party funding was a peripheral curiosity to one where it is a cornerstone of the legal and financial services sector.1 For businesses, the key takeaways are rooted in “jurisdictional awareness” and “early planning.”

First, the choice of the arbitral seat—onshore Dubai, DIFC, or ADGM—is the single most important factor in determining the regulatory burden and the likelihood of cost recovery.8 Second, the “disclosure revolution” triggered by the DIAC 2022 and arbitrateAD 2024 rules means that transparency is no longer optional; parties must be prepared to identify their funders early to avoid procedural sanctions or challenges to the tribunal’s constitution.3 Finally, the 2024 judicial shift in the Dubai Court of Cassation has fundamentally improved the ROI for funded claims, making the UAE one of the most attractive markets for legal finance in the world.37

As the UAE continues to modernize its judicial infrastructure and integrate legal finance into its boardroom strategies, businesses that master the mechanics of TPF will gain a significant competitive advantage in resolving complex, high-stakes disputes across the Middle East.1

Works cited

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