Civil Transactions Law · Federal Decree-Law 25 of 2025
Article 28
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. If it is determined that a foreign law is the applicable law, only its internal provisions shall be applied, excluding those related to private international law.
2. The law of the United Arab Emirates shall be applied if the provisions of the private international law related to the applicable law refer back thereto.
Official translation, as published by the portal.
Official Arabic text
.1 إذا تقرّر أن قانونًا أجنبيًا هو الواجب التطبيق، فلا يُطبّق منه إلا أحكامه الداخلية دون تلك التي تتعلق بالقانون الدولي الخاص.
.2 يُطبّق قانون دولة الإمارات العربية المتحدة إذا أحالت عليه نصوص القانون الدولي المتعلقة بالقانون الواجب التطبيق.
What it means when you sign
This article deals with what happens once a foreign law has been found to apply. Only that country's internal provisions are applied. Its private international law rules, meaning the rules that decide which country's law applies, are left out. The article adds that the law of the United Arab Emirates is applied if the provisions of private international law on the applicable law refer back to it.
When you are about to sign, this article is relevant to contracts that choose a foreign governing law. It means that choosing a country's law is read as choosing that country's own substantive rules, not its rules about conflicts between laws. So a clause naming a foreign law would not normally send the dispute onward to a third country's law through that country's conflict rules.
The second paragraph is the exception: if the applicable conflict rules point back to UAE law, UAE law is applied.
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 20This 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.
- 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.