Civil Transactions Law · Federal Decree-Law 25 of 2025
Article 20
Preliminary Section: General Provisions > Chapter One: Provisions on the Application and Temporal and Spatial Scope of the Law > Part Three: Spatial Application of the Law
English translation
1. Non-contractual obligations shall be governed by the law of the country in which the event giving rise to the obligation occurred.
2. The provision of Paragraph (1) of this Article shall not apply to obligations arising from an unlawful act with respect to events that occur abroad and are lawful in the United Arab Emirates, even if they are deemed unlawful in the country where they occurred.
Official translation, as published by the portal.
Official Arabic text
.1 يسري على الالتزامات غير التعاقدية قانون الدولة التي حدثت فيها الواقعة المنشِئة للالتزام.
.2 لا يسري حكم الفقرة (1) من هذه المادة فيما يتعلق بالالتزامات الناشئة عن الفعل غير المشروع وذلك بالنسبة للوقائع التي تحدث في الخارج وتكون مشروعة في دولة الإمارات العربية المتحدة، وإن عُدت غير مشروعة في البلد الذي وقعت فيه.
What it means when you sign
This article says which country's law governs obligations that do not come from a contract, such as those arising from an act that causes harm. The law of the country where the event giving rise to the obligation took place applies.
There is an exception. That rule does not apply to obligations arising from an unlawful act when the events took place abroad and were lawful in the United Arab Emirates, even if they were unlawful in the country where they happened.
When you are about to sign, this article is relevant to clauses that cover liability outside the contract itself, for example responsibility for harm caused while performing the work. It means that, for such obligations, the place where the event happened is the starting point and not the law named in a general governing-law clause. The exception means that conduct abroad that is lawful in the UAE does not give rise to an unlawful-act obligation under the rule in the first paragraph.
Not yet cited in a Fahm report; shown because it sits in the same chapter as one that is.
Related articles
- Article 18This article says which country's law governs property.
- Article 19Cited in Fahm reportsThis article says which country's law governs a contract's obligations, both its form and its substance.
- Article 28This article deals with what happens once a foreign law has been found to apply.
- Article 29Cited in Fahm reportsThis article sets a limit on applying foreign law.
- Article 30This article says what happens when a foreign law applies but cannot be established.
- Article 105This article states a principle about using a right.