Out-Law Analysis 2 min. read
Downtown Riyadh. Photo: iStock
09 Feb 2026, 11:36 am
For more than a decade, the UAE has rightly been regarded as the Middle East’s benchmark for international dispute resolution – but after attending Riyadh International Disputes Week (RIDW) 2026, it is increasingly clear that Saudi Arabia is pursuing its own distinct and increasingly confident institutional path.
Until now, the Dubai International Financial Centre (the DIFC) and the Abu Dhabi Global Market (the ADGM) have each demonstrated how common-law courts, operating in English and embedded within international financial centres, can attract global capital and complex cross-border disputes. That success has reshaped regional expectations.
A clear takeaway from RIDW 2026 is that Riyadh is not attempting to displace the UAE’s achievements, nor is it seeking to replicate them wholesale. Instead, it is travelling upon one that reflects its own legal tradition, scale and economic ambitions, a route that means the future of dispute resolution in the region is no longer a single-centre story.
The DIFC and ADGM models are often cited in discussions about Saudi Arabia’s legal trajectory, particularly when observers ask whether Riyadh, and specifically the King Abdullah Financial District (KAFD), might establish a similar common-law free zone court.
As of today, there is no public indication that such a model is planned. But this should not be mistaken for hesitation or reluctance.
Rather, it reflects a strategic choice.
The UAE’s approach has been to create internationally familiar legal environments operating alongside domestic systems. Saudi Arabia’s approach has been more integrative: strengthening its core judicial and arbitral framework while progressively aligning it with international commercial standards.
Both strategies can succeed, and, importantly, they can coexist.
What the UAE experience has demonstrated is that credibility in dispute resolution does not rest solely on the formal designation of a court system. It is built through an ecosystem of enforceability, judicial competence, institutional confidence and repeated user engagement.
On these metrics, Saudi Arabia’s progress has become increasingly visible.
A decade of practice under a modern arbitration law, growing sophistication in enforcement courts and deeper judicial engagement with arbitral principles have begun to translate into something more meaningful than reform announcements – predictability. That predictability, in turn, is changing behaviour.
At RIDW 2026, arbitrators spoke openly about accepting Saudi-related appointments as a matter of course. In-house counsel discussed Saudi enforcement risk with nuance rather than caution.
This is not a story of catching up. It is a story of consolidation.
What is emerging across the Gulf is not a zero-sum competition between dispute hubs, but a more sophisticated regional ecosystem.
Dubai, Abu Dhabi and Riyadh each now offer distinct propositions:
For users of dispute resolution, particularly multinational investors, project sponsors and sovereign-linked entities, this diversity is an advantage, not a risk. It allows dispute mechanisms to be matched more precisely to commercial realities.
The persistent question of whether Riyadh will adopt a DIFC or ADGM-style model may ultimately miss the point. The more consequential issue is how Saudi Arabia’s model will influence regional practice over time, particularly as its institutions mature and its courts and arbitral bodies continue to build jurisprudential confidence.
What RIDW 2026 demonstrated to me is that Saudi Arabia is no longer waiting for validation from external models. It is instead shaping its own, informed by regional success but grounded in domestic ambition.
The UAE showed what was possible. Saudi Arabia is now showing what comes next.
Out-Law Analysis
03 Feb 2025