ADGM Practice

In short — The ADGM Courts are an independent, English-language common-law court in Abu Dhabi that apply English law directly. They hear civil, commercial and employment disputes through a Court of First Instance (with Civil & Commercial, Employment and Small Claims divisions) and a Court of Appeal; they can be chosen by opt-in even with no ADGM connection; they grant urgent relief including worldwide freezing orders; and since the January 2025 ADGM–Dubai Courts memorandum their judgments are reciprocally enforceable onshore. Since 2023 their jurisdiction also covers Al Reem Island. This page is the hub for our ADGM practice — disputes, regulation (FSRA), structuring and employment.

At a glance

• Forums: Court of First Instance (Civil & Commercial, Employment, Small Claims) · Court of Appeal
• Law applied: English law applied directly (Application of English Law Regulations 2015)
• Jurisdiction: A connection to ADGM or opt-in by agreement; no criminal, family or inheritance matters
• Geography: Al Maryah Island and, since 2023, Al Reem Island
• Costs: Costs follow the event (the loser generally pays)
• Enforcement: Reciprocal onshore under the 14 January 2025 ADGM–Dubai Courts memorandum

1. The ADGM Courts: structure and divisions

The Court of First Instance (CFI) sits in three divisions: a Civil & Commercial Division for general disputes; an Employment Division, which hears employment claims regardless of value; and a Small Claims Division for qualifying lower-value non-employment claims, currently those of US$100,000 or less. The Court of Appeal sits above the CFI, and its decisions are generally final. The Courts operate on a fully digital (“eCourts”) platform — electronic filing, e-bundles and remote hearings — which keeps cases efficient and genuinely accessible to parties abroad, an advantage for the cross-border matters that dominate the ADGM’s list. A practical consequence of the divisional structure is that the right division, and the right track within it, is itself a first strategic decision: an employment claim, a US$80,000 debt and a US$30 million shareholder dispute each enter the Court differently.

2. What law the ADGM applies

This is the ADGM’s defining feature. Under the Application of English Law Regulations 2015, the common law of England (including the rules of equity) and a schedule of English statutes are applied directly as the law of the ADGM, taking effect as it stands from time to time. On top of that sit the ADGM’s own enactments — the Companies Regulations, the Employment Regulations, the Arbitration Regulations and so on. English court precedent is therefore highly persuasive and, as the ADGM Court of Appeal has confirmed, binding in defined respects — which gives international parties a familiar and predictable body of law to contract into. The contrast with the DIFC matters: the DIFC applies its own codified civil and commercial statutes, with English common law filling gaps, whereas the ADGM takes English law wholesale. For a party choosing between the two, that difference in the source of the law is often the deciding factor, and we set it out on ADGM vs DIFC vs onshore.

3. When the ADGM Courts have jurisdiction

The Courts take jurisdiction on two broad gateways under the Founding Law (Abu Dhabi Law No. 4 of 2013) and the ADGM Courts, Civil Evidence, Judgments, Enforcement and Judicial Appointments Regulations 2015: either a connection to the ADGM (an ADGM entity, a contract performed in or from the ADGM, or an event occurring in the ADGM), or an opt-in by agreement — parties with no ADGM nexus can choose the ADGM Courts in their contract, before or after a dispute arises. There are express carve-outs: the ADGM Courts do not hear criminal, family or inheritance and estate matters, which remain with the onshore Abu Dhabi courts. Because the opt-in gateway is so wide, the jurisdiction clause in the contract does real work — a well-drafted ADGM clause delivers a neutral, common-law forum to parties who have nothing else to do with Abu Dhabi.

4. The Al Reem Island expansion

The ADGM’s geographic jurisdiction was extended beyond Al Maryah Island to include Al Reem Island by Cabinet Resolution No. 41 of 2023, effective 24 April 2023, with a transitional period to 31 December 2024 for Al Reem businesses to align with the ADGM framework. The Abu Dhabi courts have, in a number of decisions, treated the expansion as having retroactive effect — so for an Al Reem-connected dispute the ADGM Courts may well be the correct forum even where the underlying matter pre-dates the resolution. Where a claim should be filed has, as a result, become a question worth checking carefully at the outset; getting it wrong risks a jurisdiction challenge that can cost months.

5. Bringing a claim: procedure, rights of audience and costs

Proceedings run electronically end-to-end, under common-law procedure familiar from England — statements of case, disclosure, witness statements and (in larger matters) expert evidence. Registered ADGM practitioners have rights of audience before the Courts; there is no separate mandatory UAE-licensing requirement to appear, which lets international counsel run a matter directly. On costs, the ADGM Courts apply the “costs follow the event” principle: the unsuccessful party generally pays the winner’s reasonable costs, subject to assessment by the Court. That costs-recovery regime — alien to onshore UAE litigation, where each side usually bears its own legal fees — is a real and often-overlooked strategic advantage, and it shapes the economics of whether and how hard to fight.

6. Interim and urgent relief

The ADGM Courts grant the full range of urgent protective measures — freezing injunctions (including worldwide freezing orders), search and disclosure orders, and other interim relief — and will do so without notice in a proper case, on the applicant’s undertaking in damages. In A17 v B17 & Others [2025] ADGMCFI 0001 the Court confirmed its jurisdiction to grant a worldwide freezing order, including in support of enforcing a foreign (LCIA) arbitral award, deriving that power from the Founding Law and the ADGM Regulations rather than any institutional rules. The speed and reach of that relief — freezing assets across borders before a defendant can dissipate them — is one of the strongest practical reasons to litigate or seat an arbitration in the ADGM. We cover the evidential threshold and the applicant’s duties in detail on ADGM freezing orders & injunctions.

7. Arbitration and enforcing ADGM judgments

The ADGM is a pro-arbitration seat under the ADGM Arbitration Regulations 2015 (UNCITRAL-modelled), with an ICC representative office on-site, and the Courts have accepted supervisory jurisdiction over an onshore Abu Dhabi-seated arbitration in the A6 v B6 line — a notable extension of their support role. On enforcement, ADGM judgments are enforced within the ADGM and, crucially, reciprocally onshore: under the 14 January 2025 ADGM–Dubai Courts memorandum (alongside the 2018 ADGM–Abu Dhabi Courts memorandum), an ADGM money judgment can be executed by the onshore courts without re-examining the merits. One limit to know: under the 2020 amendment to the Founding Law, the ADGM Courts are not a general “conduit” for enforcing non-ADGM judgments or awards (with a narrow exception for judgments of another Abu Dhabi court) — a deliberate contrast with the DIFC’s conduit. The mechanics, and how this plays into enforcement in India under the 2020 reciprocating-territory notification, are on enforcing an ADGM judgment and enforcing arbitral awards in the ADGM.

8. Beyond the courtroom: regulation, structuring and employment in the ADGM

The ADGM Courts sit at the centre of a wider legal practice, and the same English-law-and-ADGM-enactments framework runs through all of it. Our ADGM work spans four further clusters, each with its own detailed note:

Two currency notes for this layer: the ADGM Employment Regulations 2024 took effect on 1 April 2025 (introducing, among other things, a remote-employee definition, a one-month written-contract requirement and expanded anti-discrimination duties), and the FSRA’s virtual-asset framework continues to move quickly — both are covered in their dedicated notes and should be checked at the time of use. Our ADGM case notes analyse the reported ADGM judgments, including matters in which the firm acted.

9. ADGM and DIFC at a glance

Both are English-language common-law courts with worldwide-freezing-order powers and onshore-enforceable judgments; the deciding differences are the source of the law and the conduit question. The full legal comparison is on DIFC vs ADGM.

10. The ADGM disputes practice

ATB Legal advises and represents claimants and defendants across the ADGM Courts — from Small Claims and Employment Division matters to high-value Civil & Commercial litigation and appeals — and in ADGM-seated arbitration, including urgent freezing and disclosure applications, jurisdiction and Al Reem questions, FSRA regulatory and enforcement matters, the legal structuring of SPVs and Foundations, and the enforcement of judgments and awards onshore and abroad.

Frequently asked questions

Last reviewed: July 2026. This page provides general legal information, not legal advice on any specific matter.