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Cross-border contracting is where commercial deals are won or lost long before any dispute: the law chosen, the forum named, the way the document is signed and certified, the language it is written in and the registrations it needs all decide whether a promise can be enforced in the country where the counterparty and its assets are. The rules differ sharply between the main markets. The EU and UK give wide freedom to choose the governing law but keep mandatory and overriding rules; the Gulf states protect local commercial agents and require Arabic in court; India restricts clauses that shorten the time to sue; and each country treats penalties, liability caps and limitation periods differently. Recent changes matter: the UAE replaced its 1985 Civil Code with a new Civil Transactions Law in force from 1 June 2026, and Saudi Arabia's first codified Civil Transactions Law has been in force since late 2023.
Source-checked research100% of statements checked against a source47 checked against an official source13 checked against a secondary sourceChecked 2026-10-19Not yet professionally reviewed
A cross-border contract has to work in three places at once: under its governing law, before the court or tribunal that will hear a dispute, and in the country where the judgment or award must be enforced. A clause that is valid under English or New York law can still be cut down by mandatory rules of the place of performance, by public policy in the enforcing country or by local registration and language rules. The practical question is therefore not only what the contract says, but where it will be tested.
The modules below follow the order in which these issues arise: choosing the law and forum, signing and certifying the document, language and registration (including Gulf commercial agency registers), protection for commercial agents and distributors, limits on liability caps and agreed damages, and limitation periods. They compare India, the UAE, Saudi Arabia, Singapore, the UK, the US (state law for most contract rules), Germany and France, and the EU instruments that bind Germany and France. Where a point could only be confirmed from a law-firm commentary, the claim says so; where it could not be confirmed at all, it is listed as a gap. Dispute forums and enforcement of judgments and awards are covered in the disputes and resolution centre.
Most of the main markets let commercial parties choose the law that governs their contract, but none lets that choice override everything. In the EU and UK, Rome I gives effect to the chosen law subject to mandatory and overriding rules; the new UAE Civil Transactions Law expressly recognises an agreed law; US states allow a choice where the transaction has a reasonable relation to the chosen state. The forum clause is a separate decision, governed by different rules, and is often more important in practice.
Questions on this topic
10 statements on governing law and jurisdiction clauses
Electronic signatures are now broadly valid for commercial contracts in the EU, UK and US, but legal effect, evidential weight and statutory form requirements are different questions. Some documents still need wet ink, a qualified electronic signature, notarisation or apostille and legalisation, and the Gulf requires attestation where an apostille is not available. Stamp duty on contracts is a live issue mainly in India.
Questions on this topic
10 statements on signing and formalities
A contract that will be relied on in onshore UAE or Saudi courts will be read in Arabic, and Gulf commercial agency and distribution agreements must be registered with the ministry before they give the agent its statutory protection or, in the UAE, before the agency is valid at all. In the EU the agent can demand a signed written statement of terms. Planning the Arabic version and the registration at signing avoids disputes about translation and validity later.
Questions on this topic
10 statements on language and registration
Commercial agents are protected by mandatory rules in the EU and UK and by nationality and registration rules in the Gulf. In Germany and France the agent is entitled on termination to an indemnity or compensation that cannot be excluded in advance; in the UAE agency activity is reserved to UAE nationals and wholly UAE-owned companies, with compensation rights on expiry or termination; in Saudi Arabia only Saudis may act as agents, but termination alone does not create a compensation right. Getting the structure right at the start avoids expensive exits.
Questions on this topic
10 statements on commercial agency and distribution
Every market allows commercial parties to cap liability and agree damages in advance, but each one sets its own limits. English law tests exclusion clauses for reasonableness, with exceptions for international supply contracts; India allows only reasonable compensation up to the named sum; Germany lets courts reduce excessive penalties except between merchants; US states void unreasonably large liquidated damages; and the Saudi and new UAE civil codes let courts adjust agreed compensation and refuse exclusions for fraud or gross fault.
Questions on this topic
10 statements on liability limits and penalties
The time allowed to sue on a contract ranges from three years in Germany and India to six years in England and Singapore, with four years for US sales of goods under the UCC. The start date differs as much as the length: Germany counts from the end of the year of knowledge, India from the breach, England from accrual. Some systems let parties shorten the period by contract; India does not.
Questions on this topic
10 statements on limitation periods
Worked example, from official sources
A UK supplier sells equipment under an English-law contract to a buyer in either the UAE or Saudi Arabia. Which clauses give the best chance that the contract terms will hold when they are tested where the buyer and its assets are?
| Clause | Why it matters | UAE buyer (onshore) | Saudi buyer | Official or other source |
|---|---|---|---|---|
| Governing law: English law | Liability terms are judged by the chosen law where it is respected | Expressly agreed law governs contractual obligations (Civil Transactions Law 2025 Art 19(1)) | Foreign law and awards may be refused where contrary to Sharia (secondary) | UAE Legislation Platform; US State Department |
| Liability cap and exclusions | English law exempts international supply contracts from UCTA reasonableness | Check the cap against the local code if heard locally | Exclusion not effective for fraud or gross fault (Art 173, secondary) | legislation.gov.uk; Al Tamimi |
| Liquidated damages | Pre-agreed delay or default sums | Court may reduce if exaggerated or increase for fraud or gross fault (Art 340, secondary) | Not payable if no harm; may be reduced if excessive (Arts 178 to 179, secondary) | Afridi & Angell; Gibson Dunn |
| Arabic language clause | Controls the text a local court reads | Court documents must be in Arabic via an approved translator | Not confirmed | u.ae |
| Signing authority for the dispute clause | Avoids a void arbitration agreement | Signatory must be authorised to agree arbitration (onshore law) | Not confirmed | UAE Legislation Platform |
| Document certification | Powers of attorney and corporate documents used locally | No apostille; legalisation and MOFA attestation | Apostille available since 7 Dec 2022 | HCCH; u.ae |
| Limitation | Time to sue | New rules apply to running periods; contract period not confirmed | 1 to 10 years by type (secondary) | UAE Legislation Platform; Norton Rose Fulbright |
Result on these facts
English law can be chosen against both buyers, and for a cross-border sale of goods it frees the supplier's caps from the UCTA reasonableness test. The weak point is enforcement where the buyer is: a UAE or Saudi court can adjust liquidated damages, Saudi law will not honour an exclusion for fraud or gross fault, and onshore UAE proceedings run in Arabic. The clauses most worth adding are a fraud and gross-fault carve-out, a documented pre-estimate for liquidated damages, an agreed Arabic version, confirmed signing authority for the dispute clause and correct certification for each country.
Confirm the Saudi points against the official Civil Transactions Law text, check whether any public order exception in the UAE law limits the chosen law on the facts, and take local advice on the forum and enforcement route before signing.
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
Under the UAE Civil Transactions Law in force from 1 June 2026, the form and substance of contractual obligations are governed by the law expressly agreed by the parties; failing that, by the law of their common domicile and, if their domiciles differ, by the law of the place of main performance unless the circumstances show another law was intended. Federal; onshore UAE. Contracts on immovable property follow the law of the place where the property is located (Article 19(2)). Public order limits and the treatment of earlier contracts were not reviewed.
English text is an official translation; the platform states that the Arabic text prevails. The downloaded text was long and partly truncated when read.
Enforcement of foreign arbitral awards and foreign judgments has traditionally been time-consuming, and enforcement may be refused where it conflicts with Sharia principles; judgments from GCC and Arab League courts are enforced somewhat more readily.
Secondary (foreign government) source; the official Saudi text could not yet be checked run. Reused from sa-disputes-007.
The Unfair Contract Terms Act limits on excluding or restricting liability, including the reasonableness test, do not apply to international supply contracts: sales of goods between parties whose places of business are in different states, with goods crossing borders or offer and acceptance in different states. Section 26(3) and (4) set the conditions.
Under the Saudi Civil Transactions Law the parties may agree to exclude compensation for non-performance or delay, except where the damage results from the debtor's fraud or gross fault. Article 173(1); sale-specific limits apply where a seller intentionally conceals a defect (Article 343).
Secondary (law firm) source; article wording is the firm's translation.
Under the UAE Civil Transactions Law in force from 1 June 2026, a court may reduce agreed compensation that is exaggerated or disproportionate to the actual harm, where the obligation was partly performed or where the creditor's own fault contributed, and may increase it where the creditor proves the debtor's fraud or gross fault. Article 340 of the 2025 law, replacing Article 390 of the 1985 law, under which courts could amend agreed compensation to equal the loss and any agreement to the contrary was void.
Secondary (law firm) source dated June 2026; Article 340 was not reached in the truncated official text read.
Under the Saudi Civil Transactions Law, agreed compensation is not payable if the debtor proves the creditor suffered no harm; the court may reduce it if it is excessive or the obligation was partly performed, and may increase it only where the debtor's fraud or gross negligence caused greater harm. Articles 178 and 179 of the Civil Transactions Law (Royal Decree No. M/191 of 1444H). Agreed compensation cannot be set for an obligation to pay a sum of money (Article 178).
Secondary (law firm) source dated May 2025; the official text on the Bureau of Experts portal could not yet be checked.
Documents presented to UAE courts must be in Arabic, and documents in another language must be translated into Arabic by a legal translator approved by the UAE Ministry of Justice. Onshore UAE courts; DIFC and ADGM courts operate in English and are not covered by this statement.
A legal person can agree to arbitration only through a representative authorised to conclude arbitration agreements; otherwise the agreement is void. Onshore arbitration under Federal Law No. 6 of 2018, Article 4(1).
Article text read from the legislation platform download; the 2023 amendment (Federal Decree-Law No. 15 of 2023) was not compared article by article, so confirm the provision against the consolidated text. Reused from ae-disputes-g04.
The Hague Apostille Convention is in force for India (from 14 July 2005), Saudi Arabia (7 December 2022), Singapore (16 September 2021), the United Kingdom (24 January 1965), the United States (15 October 1981), Germany (13 February 1966) and France (24 January 1965). Hague Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents. Some contracting states have objected to particular accessions (India is marked with an objection), in which case the Convention does not apply between those states; check the pair concerned.
The status table listed 130 contracting parties when checked.
The United Arab Emirates does not appear in the HCCH status table of the Apostille Convention, so documents for use in the UAE cannot be apostilled and go through legalisation and attestation instead. International. The consequence (legalisation route) is our reading, consistent with the UAE requirement that foreign judgments be attested by the Ministry of Foreign Affairs.
To enforce a judgment issued abroad, the original judgment must be attested by the UAE Ministry of Foreign Affairs, and judgments are executed under the supervision of an execution judge at the Court of First Instance. Onshore courts; recognition conditions are in the Civil Procedure Code and were not reviewed.
Reused from ae-disputes-009.
The new UAE Civil Transactions Law applies its limitation rules to periods that had not been completed when it came into force on 1 June 2026, with special rules where the new period is shorter; claims for compensation for a harmful act are barred three years after the injured party knew of the damage and the person responsible, and in any event 15 years after the act. Federal; Articles 6(1), 7 and 258(1) and (3). The general period for contractual claims was not located in the truncated text read.
English text is an official translation; the platform states that the Arabic text prevails. The downloaded text was long and partly truncated when read.
The Saudi Civil Transactions Law, issued by Royal Decree No. M/191 on 19 June 2023 and in force 180 days after publication, sets limitation periods ranging from one year to ten years in specific cases. The commentary states the law has retrospective effect where relevant, applying to contracts made before and after it took effect.
Secondary (law firm) source; the commentary expected commencement in mid-December 2023. Specific periods and article numbers were not confirmed on an official text.
The United Kingdom keeps Rome I as domestic law, and Article 3(1), under which a contract is governed by the law chosen by the parties, applies unchanged; Article 3(4) now refers to assimilated law instead of Community law. UK version of Regulation (EC) No 593/2008, amended by S.I. 2019/834 from 31 December 2020 and S.I. 2025/82 from 27 February 2025.
Federal Decree by Law No. 25 of 2025 promulgating the Civil Transactions Law was issued on 1 October 2025, published on 14 October 2025, came into force on 1 June 2026 and repeals Federal Law No. 5 of 1985. Federal. Article 4(1) of the new law states that it does not apply retroactively unless it provides otherwise.
Dates from the legislation record; repeal and commencement read in the promulgating decree in the downloaded text.
Where the law of part of the UK applies to a contract only because the parties chose it, and would otherwise be a foreign law, sections 2 to 7 and 16 to 21 of the Unfair Contract Terms Act do not apply; the Act still applies where a foreign-law clause was imposed mainly to evade it. Section 27(1) and (2)(a).
The UAE Legislation Platform publishes English versions of federal laws as translations and states that the Arabic text prevails in case of conflict. Federal legislation, shown on the record for the 2025 Civil Transactions Law.
Under the Brussels I recast Regulation, parties may agree that the courts of an EU Member State are to settle their disputes; the agreement must be in writing or evidenced in writing (or meet the other permitted forms), and the chosen court's jurisdiction is exclusive unless the parties agree otherwise. Regulation (EU) No 1215/2012, Article 25(1); applies from 10 January 2015 (Article 81). Arbitration is excluded (Article 1(2)(d)). Does not apply to choice of UK courts after Brexit.
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A named WONE Global lead in 14 markets today. In every other featured market, WONE Global arranges qualified local expertise on request and tells you who it is before work begins.
ArgentinaLed by Dr. Esteban Lucio Maccari
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Buenos Aires · ArgentinaWONE Global Partner · Argentina
He is a lawyer with a degree from the University of Buenos Aires and a degree in Spanish Law. He completed postgraduate studies in Strategic Business Management at the Polytechnic University of Madrid and the Glocoll at…
Brunswick · Australia
São Paulo · BrazilWONE Global Partner · Brazil
Douala · Cameroon
Shanghai · ChinaWONE Global Partner · China
Roberto Gilardino is Regional Partner at Horizons, supervising the advisory’s activities in North Asia as well as additional countries (including Mongolia, Malaysia, Indonesia, Pakistan, UAE, Cyprus and Malta).
Tel Aviv · IsraelWONE Global Partner · Israel
Adv. Karin Horev has been practicing corporate and commercial law for more than 20 years, with a focus on complex technology-related matters. Over the years, Karin has led a large number of complex and wide-ranging tran…
Milan · ItalyWONE Global Partner · Italy
Nairobi · Kenya
Casablanca · MoroccoWONE Global Partner · Morocco
Business Law & Tax Advisor, I focus on Corporate Law, capital market, competition law, and energy law. I'm regularly involved in domestic and cross-border acquisitions, mergers and restructurings, international joint-ve…
Panamá · PanamaWONE Global Partner · Panama
Ebrahim Asvat K. is a founding partner of Patton, Moreno & Asvat. His practice focuses on corporate law, asset and tax planning, mergers and acquisitions, and offshore business structures. He holds an LL.M. from Harvard…
Kraków · PolandWONE Global Partner · Poland
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Attorney at Law. Co-founder of the law firm. Provides litigation services to banks and advises corporate clients in international trade. Supervises the work of the Litigation Department and the International Desk. Chair…
Lisbon · Portugal
South Carolina · United StatesWONE Global Partner · United States
Lusaka · ZambiaWONE Global Partner · Zambia
Reagan started his career in practice at Mainza & Company where he had interned while pursuing a bar qualification at the Zambia Institute of Advanced Legal Education (ZIALE) in 2008. Upon being called to the bar, Reaga…
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