Enforcing an arbitral award in Saudi Arabia: from the award to the enforcement order

The issue of an arbitral award does not mean the money has automatically passed to the winning party. There is a difference between the award's binding force, the order to enforce it, and then compulsory enforcement proceedings.

The practical path can be summarised in four stages:

Issue of the award → expiry of the annulment period → obtaining an order to enforce the award → presenting the instrument for compulsory enforcement.

And the common mistake is to confuse the last two stages.

The competent court under the Arbitration Law first issues the order to enforce the arbitral award after verifying the statutory requirements. After that, the award bearing the enforcement order enters the compulsory enforcement system as an enforceable instrument under the law in force.

Article 52 of the Arbitration Law provides that an award issued under the Law:

carries the force of res judicata and is enforceable.

But the very next article provides that the competent court, or whoever it delegates, issues the order to enforce the arbitrators' award.

So it is not enough to have:

You need to convert it into an instrument capable of compulsory enforcement through the statutory route.

This is one of the most important timing points.

Article 55 of the Arbitration Law provides that:

And the annulment period is 60 days from the date the party is notified of the award.

Example

If the award was notified to the losing party on 1 October, we do not deal only with the day the award was issued, but fix precisely:

when was formal notification made?

Because that date is what is tied to the annulment period, and therefore to when the enforcement application will be accepted.

For this reason the first document we review after an award is not only the operative part, but the proof of notification.

Filing an annulment action does not automatically stop enforcement.

The competent court may stay enforcement if the annulment claimant requests it in the statement of claim and the request rests on serious grounds, and the court must decide the stay request within 15 days. It may, on granting the stay, require security or a financial guarantee.

So we have two different situations:

This makes the enforcement strategy and the annulment strategy one file in practice, not two separate subjects.

Article 53 sets out the main documents:

This is another reason to manage an award file from the moment of issue, not wait until the end of the sixty days and then search for documents.

An important note

The Arbitration Law obliges the tribunal to deposit the original award, or a signed copy of it, with the competent court within the statutory period, with a certified Arabic translation if the award is in a foreign language.

The competent court in the Arbitration Law means the court of appeal that would originally have jurisdiction over the dispute.

And in international commercial arbitration, whether held in the Kingdom or abroad within the Law's scope of application, jurisdiction lies in principle with the competent court of appeal in Riyadh, unless the parties agree on another court of appeal within the Kingdom.

So one should not jump straight to the enforcement court before completing the enforcement-order stage the Arbitration Law requires.

The court does not re-hear the dispute from the beginning.

Under Article 55, it verifies three main matters:

This is a different review from:

or:

The enforcement-order stage is not a new appeal on the merits of the award.

The Law allows a partial solution.

If the award can be divided and the part contrary to Sharia or public order is separable from the rest, enforcement of the part that is not in breach may be ordered.

This is important because it prevents the assumption that:

The analysis must first look at whether the parts can be separated.

There is an important procedural difference:

An order issued enforcing an arbitral award cannot be challenged.

But if an order refusing enforcement is issued, it may be challenged before the competent body within 30 days of its issue.

So after a refusal, the reason must be assessed at once:

Is the problem in the notification?

In the documents?

In the scope of public order?

In a conflict with an earlier judgment?

And one should not wait until near the end of the thirty days to start the analysis.

Here we move from the Arbitration Law to the Enforcement Law.

The enforcement law currently in force treats arbitral awards bearing an enforcement order under the Arbitration Law as enforceable instruments.

After this stage is complete, the Ministry of Justice allows the enforceable instrument to be filed electronically through Najiz; the service includes entering the details of the enforcement applicant and the debtor and the content of the application, and uploading a copy of the instrument and the required documents.

So the journey becomes:

The arbitral award → the enforcement order → the enforceable instrument → enforcement proceedings

And this is the natural link between the practice of arbitration and the practice of enforcement and recovery.

Obtaining an enforcement order does not by itself answer the question:

So, in large awards, an asset-tracing and enforcement plan should begin early.

We want to know:

Is the debtor an operating company?

Are there assets inside the Kingdom?

Are there several enforcement applications against it?

Are there assets in other countries?

And does the award need to be enforced in more than one country?

And here the legal value of the award differs from its practical collectability.

Not every arbitral award says:

It may include:

delivery of documents, doing an act, refraining from an act, or other effects depending on the dispute.

And the design of enforcement then depends on the operative part of the award itself.

For this reason, already at the arbitration stage care must be taken over how claims are framed and the expected operative part; an award in which the obligation required cannot be clearly understood may create problems later in enforcement.

This point calls for a warning.

A new enforcement law was issued by Royal Decree No. M/237 and officially published on 1 May 2026, but it provides that it takes effect 180 days after its publication, that is, around the end of October 2026. And as of the date this article was updated, 7 October 2026, that period has not yet run.

So as of the date of the article:

The old Enforcement Law is still the law being applied, with the system approaching its move to the new law.

The new law keeps arbitral awards under the relevant statutory provisions as enforceable instruments, but reorganises a number of the stages and procedures of enforcement.

For this reason we will review this page as soon as the new law and its executive regulations take effect, rather than writing a long explanation of enforcement procedures that will change within weeks.

It will not change the basic principle that an arbitral award must meet the requirements set out in the Arbitration Law.

But once in force it organises the stage of compulsory enforcement after the enforceable instrument exists in a new way.

Article 7 of the new law lists arbitral awards among enforceable instruments, and Article 4 has the enforcement court verify that the instrument meets its statutory conditions without looking into the underlying right the instrument records.

And this reinforces the distinction between two stages:

Then:

No.

This article focuses mainly on an award subject to the enforcement route under the Saudi Arbitration Law.

As for an arbitral award issued in a foreign country, its analysis also involves:

the international conventions to which the Kingdom is a party, the place where the award was issued, and the enforcement provisions specific to foreign awards.

And the new enforcement law itself provides for dealing with arbitral awards issued in a foreign country in light of the Kingdom's international obligations and the relevant statutory conditions.

For this reason enforcing a foreign arbitral award in Saudi Arabia deserves separate treatment, rather than merging two different subjects into one page.