CRSD Appeal in Saudi Arabia: 30-Day Deadline and Enforcement

The Committee for Resolution of Securities Disputes ordered your brokerage firm to pay you SAR 180,000. Two weeks later you were notified that the firm has appealed. Or the opposite: the decision went against you and you think it rests on a wrong calculation. Either way the question is the same: how much time do I have, and when can the decision be enforced?

The direct answer: the appeal deadline is 30 days from the date you were notified of the decision. The appeal memorandum is filed with the Committees' General Secretariat through the online service "Submit an appeal" (تقديم استئناف). Decisions of the Appeal Committee are final (Article 30 of the Capital Market Law). Once the decision is final and the other side does not pay, you apply to the Enforcement Court to enforce it, in the same way court judgments in civil cases are enforced.

Saudi Arabia's new Enforcement Law (issued by Royal Decree M/237, published on 14/11/1447H = 1 May 2026) takes effect 180 days after publication, around 28 October 2026. The Royal Decree states that the enforcement courts execute decisions of committees with quasi-judicial jurisdiction under the new law.

What is the Appeal Committee for securities disputes?

It is the second level for decisions of the Committee for Resolution of Securities Disputes, established by Article 30 of the Capital Market Law (consolidated CMA text). It sits in one or more panels, each with three principal members and one alternate, for renewable three-year terms. It may decline to review a decision, confirm it, or re-examine the case on the basis of the file and issue the decision it finds appropriate. Its decisions are final.

What is the deadline to appeal a CRSD decision?

30 days from the date you were notified of the decision, not from the date it was issued (Article 30 of the Law; Article 43 of the Securities Disputes Resolution Proceedings Regulations). A decision issued in absentia can be appealed within 30 days from the date the losing party is notified of it (Article 44 of the Regulations). A party that obtained everything it asked for, or expressly accepted the decision, cannot appeal.

If 30 days pass without an appeal, the decision becomes final, and the only remaining door is the narrow one of a petition for review.

What goes into the appeal memorandum?

The memorandum is filed with the General Secretariat and its filing date is recorded in the case file (Article 45). It must state the decision appealed, its number and date, the grounds of appeal, and the appellant's requests (Article 46).

• Pinpoint the error: in the facts, in applying the law, or in calculating compensation. Do not simply repeat the statement of claim.
• New requests are not accepted on appeal, except a request to increase compensation for harm arising after the final submissions (Article 46).
• A person who was not a party before the first-instance Committee cannot be brought in on appeal except within narrow limits (Article 47).
• If you have new, relevant information you could not submit earlier, explain why; the Regulations allow a decision to be reconsidered in defined cases (Article 49).

The Appeal Committee reviews the file and may hold hearings when it sees a need (Article 48).

When does the decision become final?

A decision becomes final (acquires conclusive force) in any of these cases (Article 50 of the Regulations):

• The parties agree in writing on a settlement before the Committee.
• 30 days pass from notification without an appeal.
• All parties accept the decision.
• The Appeal Committee confirms the decision.
• The Appeal Committee issues its decision after re-examining the case.

The parties then receive copies of the decision, and it is enforced as provided in the Law (Article 51).

Can the Appeal Committee's decision be challenged?

Its decisions are final under Article 30. What remains is a petition for review (التماس إعادة النظر), filed with the panel or Appeal Committee that issued the decision, in the cases set out in the Law of Procedure before Sharia Courts for private-right claims, and in the Law of Criminal Procedure for criminal cases (Article 52 of the Regulations). Under Article 200 of the Law of Procedure before Sharia Courts these include: documents on which the decision was based later proven forged, decisive documents obtained afterwards that could not be produced before, or fraud by the other party that affected the decision. That law sets a 30-day period for the petition (Article 201), so do not wait longer. The General Secretariat offers an online "Submit a petition" (تقديم التماس) service.

How do I enforce a CRSD decision?

The Law distinguishes two kinds (Article 30):

• Final decisions in general, such as fines and penalties, are enforced at the request of the CMA or the Exchange through the government body authorised to enforce court judgments.
• Decisions in favour of parties under Articles 55, 56 and 57 (compensation for a misleading prospectus or statement, or for manipulation) are enforced by those parties themselves, in the way court judgments in civil cases are enforced.

In practice you take a copy of the final decision and file an enforcement request with the Enforcement Court through Najiz (the Ministry of Justice e-portal). Item Four of the Royal Decree issuing the new Enforcement Law expressly states that the enforcement courts execute decisions and orders of committees with quasi-judicial jurisdiction under the new law.

Before that, while the case is pending, the Regulations allow the Committee, at the claimant's request, to order a precautionary measure such as a travel ban, a precautionary attachment of the defendant's assets, or a ban on buying in the market, if the claimant submits supporting documents (Article 41 of the Regulations). This helps if you fear the other side will move its assets before the decision.

What changes with the new Enforcement Law?

• If five working days pass after the debtor is notified of the enforcement order without payment, the court immediately notifies the credit bureaus and attaches the debtor's assets, including future funds, and may impose a fine of up to SAR 5,000 for each day of delay (Article 18).
• A travel ban is issued only at the creditor's request, for up to three years, extendable by a new request to a maximum of six years (Article 19).
• Detention is now limited to direct enforcement (an obligation to do or not do something), at the creditor's request after 30 working days, for up to 180 days, extendable (Articles 36 and 37). The insolvency provisions of the 1433H Enforcement Law, including detention where there are signs the debtor is hiding assets (Article 78), continue until a civil insolvency law is issued (Royal Decree M/237, Item Seven).
• If the debtor is a company, the direct-enforcement rules apply to the person within the company who obstructs enforcement, as the implementing regulation will specify (Article 41).

An investor obtained a CRSD decision awarding her SAR 95,000 for a misleading statement in a listed company's announcement. The company was notified on 5 March and did not appeal by 4 April, so the decision became final.

She filed an enforcement request with the Enforcement Court through Najiz with a copy of the decision. If the company does not pay within five working days of being notified of the enforcement order, attachment of its assets starts, and once the new law is in force the court may impose the daily fine under Article 18.

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 steps for both sides

If the decision is in your favour:

• Count the 30 days from the date the other side was notified, not from the date of the decision.
• If the other side appeals, answer its grounds with the same documents that won your case; do not open new issues.
• Once the decision is final, file the enforcement request without delay.
• If you fear assets will be moved while the case is pending, ask the Committee for a precautionary measure with your documents.

If the decision is against you:

• File the appeal within the 30 days, even while you negotiate a settlement.
• Focus the memorandum on a specific error in the facts, the law or the calculation.
• If no route remains, a written settlement before the Committee or payment is better than daily fines and asset attachment.
• Do not rely on a petition for review unless one of its specific legal grounds exists.

The appeal window is short, and a good memorandum wins or loses on its grounds. You can send us the decision and the date you were notified on WhatsApp, and we will look at the grounds of appeal or the enforcement steps with you before the deadline gets close.