A comparative review of contract law

The UAE and the Kingdom of Saudi Arabia have recently reformed their core contract law frameworks to meet the complexities of modern international business dealings, as part of their extensive national legal reform programmes. The UAE issued a new Civil Code (Federal Decree-Law No. 25 of 2025) in late 2025, which comes into force in June 2026 and contractual relationships in Saudi Arabia are governed by a Civil Transactions Law that came into force in December 2023. Clear contract law frameworks can provide parties with greater certainty, both in terms of drafting local law governed contracts and understanding how their contracts (whether local or foreign law governed) may be interpreted by courts in the jurisdictions in which they operate, should contractual disputes be heard in the local courts.

In our 2026 update, we set out a high-level overview of the general contract law rules in Saudi Arabia, the UAE (in force from 1 June 2026) and England and Wales.

Please contact a member of our Middle East team if you would like to discuss these issues with us.