Across key Middle Eastern enforcement hubs, the direction of travel is increasingly creditor- and enforcement-friendly. Courts and lawmakers are placing greater emphasis on speed of enforcement, access to information and interim relief to facilitate recovery. For creditors holding judgments or arbitral awards, including those obtained outside the region, this is a welcome development.

Debtors increasingly hold assets, shares, receivables, bank accounts, real estate or valuable commercial relationships in the Middle East even where the underlying dispute has little or no obvious connection with the region. Creditors think carefully about how best to position themselves before assets are moved or competing creditors gain priority. Legal finance can form part of that analysis, where creditors do not want to bear the full cost and risk of recovery internally.

Saudi Arabia’s new Enforcement Law

Saudi Arabia issued a new Enforcement Law under Royal Decree No. M/237 dated 20 April 2026. The law replaces the previous enforcement framework and is expected to come into force in October 2026.

The reform is part of a broader push across the region to make enforcement more structured, efficient and asset-focused. It is expected to introduce shorter response periods, more formal mechanisms for obtaining debtor asset information, a greater role for licensed private-sector service providers and tougher consequences for obstruction or asset dissipation.

There are still uncertainties. The law is not yet in force, and much will depend on the implementing regulations. Creditors holding older instruments, foreign judgments or awards, or claims involving complex debtor structures should seek local advice on how the new framework applies in practice.

That said, the overall direction is clear: The reform also fits within a broader regional shift towards effective cross-border enforcement and asset recovery.

A broader regional trend

Saudi Arabia is not alone. In the UAE, the DIFC and ADGM courts have become increasingly important in cross-border enforcement and asset recovery. The DIFC Court of Appeal has recently confirmed the DIFC Courts’ jurisdiction to grant interim relief in support of foreign proceedings that may result in a judgment capable of recognition and enforcement in the DIFC, without requiring assets to be located there.

The ADGM Courts have similarly confirmed jurisdiction to grant worldwide freezing orders in support of international enforcement proceedings, including foreign arbitral award enforcement.

Onshore UAE courts are also increasingly recognizing foreign judgments and awards, including from Canada, England & Wales, Switzerland, Russia, Singapore and the US.

Why this matters for international creditors

More enforcement tools do not automatically translate into it being straightforward to enforce.

A creditor that (acts fast; understands the debtor’s asset position; and has the capital to pursue the right strategy stands a much better chance of successfully recovering than one who does not.

An enforcement strategy should therefore start well before a judgment is in hand, not only once the debtor has failed to pay.

What creditors should be doing now

Preparation is the key to success. As enforcement regimes in Saudi Arabia, the Middle East and worldwide become increasingly effective, creditors should ensure they are well-positioned should they need to rely on them. Key steps include:

1. Map the asset position early

Saudi Arabia’s new Enforcement Law requires debtors to disclose their assets once notified of an enforcement order, and lets courts compel disclosure from third parties, including registries, agents, financial counterparties and anyone suspected of helping conceal or transfer assets.

This is a welcome development, but no substitute for early intelligence. Creditors should still spend time and money upfront to understand where the debtor’s assets are located, how they are held and whether they are vulnerable to movement or dissipation. This means looking  not only at assets held directly by the debtor, but also at assets connected to corporate structures, family members, related parties or nominees, as well as receivables, shareholdings and commercial relationships. Particular attention should be paid to assets that can be easily moved or may be subject to competing claims.

2. Identify the most effective enforcement forums

Not every jurisdiction offers the same tools or speed. Creditors should consider where recognition, interim relief, disclosure, freezing orders or asset attachment may be available.

Saudi Arabia’s new law preserves the broad framework for enforcement of foreign judgments and arbitral awards, rather than replacing it entirely, and appears to preserve the core existing gateways to enforcement rather than create an entirely new regime. Creditors will still need to consider issues such as applicable treaty routes, reciprocity, procedural fairness, finality, public policy and whether the matter falls within the exclusive jurisdiction of the Saudi courts.

Treaty routes and reciprocal recognition agreements, such as the UAE’s membership of the Riyadh Arab Convention and the GCC Convention, can streamline the process. The Recent Dubai Court of Cassation guidance also confirms that a Saudi judgment can be enforced in parallel across multiple GCC states, provided the judgment debt has not already been satisfied.

3. Review documentation and consider timings

Documentation matters. Under the new law, bills of exchange and promissory notes qualify as enforcement instruments only if registered on Saudi Arabia’s national electronic platforms; existing unregistered instruments remain remain enforceable for a one-year transitional period, after which they  may no longer be accepted by the enforcement courts.

Creditors should also consider timing more generally. The new law introduces a 10-year limitation period for enforcement, and this is an obvious reason to audit enforcement options now rather than waiting until enforcement becomes urgent.

4. Consider competing creditors

Recoverability depends not only on whether the debtor has assets, but on timing and priority relative to other creditors. Competing creditors, secured lenders and insolvency officeholders can all reduce the practical value of a judgment or award.

Saudi Arabia’s new law recognizes that priority disputes may arise over seized assets and protected income streams, and recent UAE case law confirms creditors can pursue parallel enforcement of Saudi judgments across GCC states. Where debtor assets are spread across the region, a comprehensive, cross-border strategy beats a sequential one.

5. Budget for recovery, not just litigation

Enforcement costs often exceed the costs of the substantive proceedings that preceded them. Asset tracing, local counsel in multiple jurisdictions, recognition proceedings, interim relief, court fees and unwinding or complex trust structures all add significant cost after the merits phase concludes.

How legal finance can help

This is where legal finance can play an important role. Legal finance can enable creditors to pursue the recovery strategy most likely to succeed, rather than the one that fits an internal budget. It can support asset tracing, investigations, local counsel, interim applications and multi-jurisdictional enforcement. It can also provide liquidity through monetization or purchase of judgments and awards, letting creditors realize value upfront rather than bearing the cost and uncertainty of enforcement themselves.

It should not be assumed unavailable in Saudi Arabia or the wider region, nor incompatible with Islamic finance principles, provided the funder’s return is contingent on a successful recovery and the funder bears the risk of loss.

Conclusion

Saudi Arabia’s new Enforcement Law is a significant, positive step for the Kingdom and the wider region, though the implementing regulations and early court practice will need close attention.

More broadly, it reflects a wider shift across the Middle East. Key regional enforcement hubs are becoming more sophisticated, and creditors with international judgments and awards should not treat the region as peripheral to their recovery strategy.

The opportunity favors prepared creditors, those who understand the debtor’s asset position, act early, weigh competing creditor risk and secure the capital to execute.

For creditors, the message is simple: Enforcement reform creates opportunity, but recovery still requires strategy.