Insights & answers
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Winning an arbitration is only half the job. An award has value only if it can be enforced against the losing party’s assets. PAD International Group advises award creditors and debtors on enforcing, resisting and collecting arbitral awards in the UK, the UAE and Iran.
The New York Convention
The 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards is the backbone of cross-border enforcement. More than 170 states are parties, including the United Kingdom, the United Arab Emirates (since 2006) and Iran (since 2001, with reservations limiting it to commercial disputes and to awards made in other contracting states).
Under Article V, enforcement can be refused only on limited grounds, such as:
- an invalid arbitration agreement or a party lacking capacity;
- a party not given proper notice or unable to present its case;
- an award dealing with matters outside the arbitration agreement;
- a tribunal or procedure not in line with the parties’ agreement;
- an award set aside or not yet binding at the seat;
- a subject matter not capable of arbitration, or enforcement contrary to public policy in the enforcing state.
Enforcement country by country
| Country | Legal basis | Practical points |
|---|---|---|
| United Kingdom (England & Wales) | Arbitration Act 1996, sections 66 and 100–104 | Leave of the court is required; an application is usually made without notice. Action on an award is generally subject to a six-year limitation period. |
| United Arab Emirates | New York Convention and the UAE federal arbitration and civil procedure laws | Onshore courts and the DIFC courts both enforce awards; the right route depends on where the assets are. |
| Iran | New York Convention and the Law on International Commercial Arbitration (1997) | Commercial and reciprocity reservations apply; public policy and the status of state parties need careful review. |
Resisting enforcement
If an award has been made against you, the time limits for challenging it at the seat, and for opposing enforcement elsewhere, can be short. We review whether there are genuine grounds under the Convention or the law of the seat and advise on settlement where a challenge is unlikely to succeed.
How we help
- Asset tracing strategy and choice of enforcement jurisdiction.
- Applications to enforce awards in England and coordination with local counsel in the UAE and Iran.
- Advice on resisting or setting aside awards.
- Analysis of Iranian court judgments and awards, through our judgments and awards enforcement analysis service.
Holding an award, or facing enforcement? Ask a question or book a consultation, or return to our arbitration services.
General information only, current as of November 2026. It is not legal advice for a specific matter.