Commercial disputes go to specialised commercial courts under the Commercial Courts Law of 2020, while disputes with government contracting bodies generally go to the Board of Grievances. Saudi Arabia has a Model Law-based arbitration law, an active institution in the Saudi Center for Commercial Arbitration (SCCA), and is party to the New York Convention (with a reciprocity limitation) and the Singapore Convention on Mediation. Enforcement of foreign judgments and awards is possible but can be slow, and anything contrary to Sharia or public policy may be refused.
Courts
Specialised commercial courts operate under the Commercial Courts Law of 2020, which encourages arbitration and mediation. The Board of Grievances generally hears disputes between government bodies and private contractors and has historically reviewed foreign judgments and awards.
Judgments from GCC and Arab League courts are enforced more readily than others, and Sharia principles can override foreign rulings. Contracts with Saudi counterparties should therefore choose the forum deliberately rather than default to a foreign court.12
Arbitration
Saudi arbitration legislation was recognised by UNCITRAL in 2017 as based on the 2006 Model Law. The SCCA's 2023 rules created an SCCA Court and allow foreign counsel. Saudi Arabia acceded to the New York Convention in 1994 and applies it only to awards made in another contracting state, so the seat of a foreign arbitration matters.
Saudi Arabia is an ICSID member but has not given general consent; investor-state claims depend on case-by-case consent or a bilateral investment treaty, such as those with France, Spain, China and Japan.3456
Mediation and settlement
Saudi Arabia ratified the Singapore Convention on Mediation, in force for it since 5 November 2020, so international mediated settlement agreements can be relied on directly, except those involving the government to the extent of its declaration. Building a mediation step into dispute clauses aligns with the courts' encouragement of settlement.71
| Route | Key point | Status |
|---|---|---|
| Commercial courts | Specialised courts for commercial disputes | Commercial Courts Law 2020 |
| Board of Grievances | Disputes with government contracting bodies | Administrative judiciary |
| SCCA arbitration | Institutional arbitration; 2023 rules | Active |
| New York Convention | Applied to awards made in another contracting state | In force 18 July 1994 |
| Singapore Convention | Enforcement of international mediated settlements | In force 5 November 2020 |
| ICSID | Investor-state arbitration | Member; consent case by case |
How it works, step by step
- Choose the dispute route in the contract: Saudi courts, SCCA arbitration, or foreign-seated arbitration in a New York Convention state.54Parties
- Add a mediation step before arbitration or litigation where settlement is realistic.7Parties
- When enforcing a foreign award or judgment, apply to the competent Saudi court and prepare for review on Sharia and public policy grounds.2Saudi enforcement courts
No timings or fees are shown unless an official source states them.
Documents usually needed
- Signed contract with an express arbitration or jurisdiction clause
- Original or certified award or judgment and proof it is final
- Certified Arabic translations of the award, judgment and key documents
- Evidence of proper notice to the other party
Common mistakes
- Seating arbitration in a state that is not party to the New York Convention, which Saudi Arabia's reciprocity limitation excludes.
- Relying on a foreign court judgment without checking enforceability in Saudi Arabia.
- Drafting remedies, such as interest, that may conflict with Sharia principles at enforcement.
- Assuming ICSID is available without a treaty or specific consent.
When the business crosses borders
- Foreign awards from New York Convention states can be enforced in Saudi Arabia, subject to Sharia and public policy review.
- International mediated settlement agreements benefit from the Singapore Convention, except those involving the Saudi government to the extent of its declaration.
- Investor-state protection depends on bilateral investment treaties or case-specific ICSID consent.
Questions businesses ask
Will a London- or Singapore-seated arbitration award be enforced in Saudi Arabia?
Awards made in New York Convention states can be enforced, but enforcement may be refused where it conflicts with Sharia or public policy and can take time.52
Is there a local arbitration institution?
Yes. The Saudi Center for Commercial Arbitration administers arbitrations under rules revised in 2023, which allow foreign counsel.4
Can we enforce a foreign court judgment?
Possibly. Judgments from GCC and Arab League courts are enforced more readily; others face a slower and less predictable process and review against Sharia principles.2
What this guide does not yet confirm
These points need checking with a qualified local professional in Saudi Arabia before you rely on them.
- The Enforcement Law conditions for foreign judgments and awards (reciprocity, jurisdiction, public order) were not confirmed on an official page.
- The Arbitration Law text, the current SCCA rules and SCCA mediation services could not yet be checked (SCCA site rate-limited).
- Ministry of Justice reconciliation and mediation services and any mandatory pre-filing settlement steps were not confirmed.
- ICSID membership dates were not confirmed on the ICSID database.
- Court points rely on a foreign-government summary.
Sources and review status
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.
The Commercial Courts Law of 2020 governs the specialised commercial courts, which hear commercial disputes, and the law encourages arbitration and mediation. Disputes between the government and private contractors generally go to the Board of Grievances.
Secondary (foreign government) source; the official Saudi text could not yet be checked run.
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.
UNCITRAL recognised Saudi Arabia in 2017 as having arbitration legislation based on the 2006 version of the UNCITRAL Model Law on International Commercial Arbitration.
Secondary (foreign government) source; the official Saudi text could not yet be checked run. The UNCITRAL Model Law status page could not yet be checked.
The Saudi Center for Commercial Arbitration (SCCA) administers arbitration, and its 2023 rules created an SCCA Court of 15 members and allow representation by foreign counsel.
Secondary (foreign government) source; the official Saudi text could not yet be checked run. The SCCA website could not yet be checked.
Saudi Arabia acceded to the New York Convention on 19 April 1994, with entry into force on 18 July 1994, and applies it only to awards made in the territory of another contracting state. Saudi Arabia has made no commercial-relationship declaration under the Convention.
Saudi Arabia is a member of ICSID but has not given general consent to refer investment disputes to ICSID; consent is required case by case. Saudi Arabia has bilateral investment treaties with investor-state arbitration clauses, including with France, Spain, China and Japan.
Secondary (foreign government) source; the official Saudi text could not yet be checked run. The ICSID member-state database could not yet be checked.
Saudi Arabia ratified the Singapore Convention on Mediation on 5 May 2020 and it entered into force for Saudi Arabia on 5 November 2020. Saudi Arabia declared that it will not apply the Convention to settlement agreements to which it, a government agency or a person acting for one is a party, to the extent specified in its declaration.
Questions on this topic
7 statements on courts, arbitration, mediation and enforcement in Saudi Arabia
