Enforcement of Foreign Judgments in Saudi Arabia: Conditions

Your company sued a Saudi client before a court in the country where the contract was made, and won a judgment for an amount equal to SAR 400,000. The problem is that the client owns nothing there; all his bank accounts and properties are in Riyadh. You have the judgment, but it does not turn into money in Saudi Arabia until it goes before the enforcement judge and passes a specific test set by the law.

The short answer: a foreign judgment is enforced in Saudi Arabia if a treaty covers it or reciprocity is proven, the judgment is final, the losing party was notified and given the chance to defend himself, it does not conflict with Saudi public order or an earlier Saudi judgment, and the dispute is not one that falls under the jurisdiction of Saudi courts. You submit it to the competent enforcement judge with the original and a certificate that it is final, attested and translated, so that the judge places the enforcement seal (khatm al-tanfidh) on it.

The following is based on the Enforcement Law of 1433H (2012) and its Implementing Regulations, which are in force now. The new Enforcement Law, published on 14/11/1447H (1 May 2026), replaces it 180 days after publication (around late October 2026), and it changes some conditions for enforcing foreign judgments, as explained in a separate section below.

Can a foreign judgment be enforced in Saudi Arabia directly?

Article 9 of the Enforcement Law lists judgments, judicial orders, arbitral awards and notarised documents issued in a foreign country among the executive instruments (sanad tanfidhi, documents enforceable directly at the Enforcement Court). But Article 14 requires that they first be submitted to the enforcement judge competent for foreign judgments, who checks that they meet the conditions for enforcement and places the enforcement seal on them.

The basis of all this is in Article 11: subject to treaties and agreements, a foreign judgment is enforced only on the basis of reciprocity. The Implementing Regulations state that the burden of proving reciprocity is on the person requesting enforcement. So start with two questions: Is there a treaty between Saudi Arabia and the country of the judgment that covers this type of judgment? If not, what proves that the courts of that country enforce Saudi judgments?

What conditions does the enforcement judge check?

Article 11 sets five points the judge must verify before ordering enforcement:

1. Saudi courts do not have jurisdiction over the dispute, and the foreign court has jurisdiction under the international jurisdiction rules of its own law.
2. The parties were summoned to appear, were properly represented, and were able to defend themselves.
3. The judgment has become final under the law of the court that issued it.
4. It does not conflict with a judgment or order issued on the same subject by a competent judicial body in Saudi Arabia.
5. It contains nothing that violates public order in Saudi Arabia.

The Implementing Regulations add important details. Public order here means the rules of Islamic Sharia. The judgment is not enforced if a case was already pending in Saudi Arabia before the case in which it was issued. It is also not enforced in matters that only Saudi courts may hear, for example claims over rights in real estate located in the Kingdom. So if the foreign judgment orders the transfer of ownership of an apartment in Jeddah, it cannot use this path at all.

What documents do you need to enforce a foreign judgment?

Paragraph 11/1 of the Implementing Regulations sets what must accompany the judgment:

• The original foreign judgment or order, or a certified true copy.
• A certificate that the judgment is final and enforceable, unless the judgment itself states this.
• For a judgment issued in absence (default judgment): a certified copy of the document notifying the judgment, or any document proving the defendant was properly notified.

Official documents issued in the foreign country must be attested by the Ministries of Foreign Affairs and Justice, and translated into Arabic by a certified translation office (paragraph 11/4). If an appeal judgment changed the amount, it is an essential part of the file. Do not correct a name or number in the translation yourself if it does not match the original; ask the issuing body to correct it.

What about default judgments and foreign arbitral awards?

A judgment issued in the absence of the defendant is not barred from enforcement for that reason alone. What matters is proof that the losing party was properly notified and given the chance to defend himself. This is why the Regulations require the notification document in this case specifically.

An arbitral award issued in a foreign country is subject to the same Article 11 under Article 12. A foreign notarised document, such as a contract notarised before a notary abroad, may be ordered for enforcement under Article 13, under the conditions that country's law sets for enforcing Saudi notarised documents, and on the basis of reciprocity.

After the enforcement seal: do you get the money immediately?

The enforcement seal means the instrument can now be enforced in Saudi Arabia, not that the money is in your account. After it, the usual steps follow: notifying the debtor, disclosure of his assets, and seizure. If the losing party paid part of the amount after the judgment, state this in the request from the start.

A foreign judgment for the equivalent of SAR 400,000.

The losing party transferred SAR 100,000 three months after the judgment.

You request enforcement of the remaining balance and attach the transfer receipt. Claiming the full amount would open a dispute you will lose and would delay your file.

What changes with the new Enforcement Law?

Article 9 of the new law rewrites the conditions. Instead of requiring that Saudi courts lack jurisdiction and the foreign court has it, it requires that the case is not one that a Saudi judicial body has exclusive jurisdiction to hear. It moves into the law itself the condition that no similar case was pending in Saudi Arabia before the foreign case was filed, and it keeps the conditions on summons, finality, no conflict with an earlier Saudi judgment, and no violation of public order.

• Article 7 adds settlement agreements issued in a foreign country to the executive instruments. They, and foreign arbitral awards, are enforced in line with Saudi Arabia's obligations under international treaties and agreements, after the same conditions are checked.
• Article 4 states that the court checks that the instrument meets its conditions without examining the merits of the right, subject to Article 9.
• Article 17 allows exchange of asset disclosure with other countries on the basis of reciprocity and within the limits of the purpose.

This is general information based on the official Arabic texts of Saudi laws, which prevail over any translation. It is not legal advice for your specific case.

Practical solutions for both sides

If you hold the foreign judgment:

• First confirm the basis for enforcement: a treaty that covers the country of the judgment, or proof of reciprocity.
• Ask the issuing court for a certificate of finality, and the notification document if the judgment was issued in absence.
• Complete the attestation and certified translation before filing; gaps here are the most common cause of delay.
• Deduct what you received after the judgment, and state the currency and amount exactly as in the operative part of the judgment.
• Collect what you know about the debtor's assets in Saudi Arabia to speed up seizure after the enforcement seal.

If the judgment was issued against you:

• Identify exactly which condition you believe is not met: a notification you never received, a judgment that is not final, an earlier case pending in Saudi Arabia.
• Collect proof of this from the foreign court itself or from case files here.
• Submit receipts for any amount you paid after the judgment so you are not asked to pay it twice.
• If the right is clearly established, a documented settlement may save you long seizure procedures.

If you hold a judgment from outside Saudi Arabia, or one was issued against you, send us a copy and its documents on WhatsApp, and we will review the conditions and any missing items with you before filing.