A Dubai-based trading company wins a court judgment against its Polish distributor. The distributor's assets – warehouses, receivables, a bank account – sit in Poland. The UAE judgment is final. But collecting on it requires a separate legal process under Polish law, and that process is less straightforward than most creditors expect.

Enforcing a UAE judgment in Poland requires a Polish court to formally recognise or declare the foreign judgment enforceable before any bailiff can act. Poland has no bilateral treaty with the United Arab Emirates covering mutual recognition of civil judgments. Recognition therefore proceeds under the general rules of the Kodeks postępowania cywilnego (Code of Civil Procedure, KPC), which requires the applicant to satisfy several conditions – including reciprocity, procedural fairness, and public-policy compatibility – before a Polish court will grant an enforcement clause. The process typically takes four to ten months from filing to a first enforcement action.

This guide walks through each stage: the legal framework, the filing requirements, the timeline and costs, three business scenarios, the most common mistakes, and a FAQ. It is written for UAE-based creditors, their in-house counsel, and Polish subsidiaries seeking to recover cross-border debts through the Polish court system.

What legal framework governs recognition of UAE judgments in Poland?

The starting point is the absence of a bilateral treaty. Poland and the UAE have not concluded a convention on mutual recognition and enforcement of civil judgments. That gap matters immediately: it means the creditor cannot rely on a streamlined treaty route. Instead, Polish courts apply the general provisions of the Code of Civil Procedure governing recognition of foreign judgments from non-treaty states.

Under Polish civil procedure law, a foreign judgment from a non-treaty jurisdiction is recognised automatically – meaning it has legal force in Poland – provided it meets a list of statutory conditions. These include: finality under the law of the state of origin, jurisdiction of the foreign court not being exclusive under Polish rules, proper service on the defendant, no irreconcilable conflict with a prior Polish judgment, no pending parallel Polish proceedings at the time the foreign action was filed, and no violation of Polish public policy (klauzula porządku publicznego). The public-policy filter is the most frequently litigated condition in UAE cases.

Recognition alone does not allow enforcement. To compel a bailiff to act, the creditor needs an exequatur – a declaration of enforceability issued by a Polish court with an enforcement clause appended. The competent court is the Regional Court (Sąd Okręgowy) in whose district the debtor is domiciled or has assets. The National Court Register (KRS) can confirm the debtor's registered address if the debtor is a Polish company. The Warsaw Regional Court handles the largest share of such applications, given the concentration of commercial debtors in the capital.

One practical detail often overlooked: UAE court judgments are issued in Arabic. Polish procedural rules require a certified translation into Polish prepared by a sworn translator registered with the Polish Ministry of Justice. Budget at least three to four weeks for this step alone.

How does the step-by-step recognition procedure work?

The procedure unfolds in five distinct stages. Understanding each stage – and its specific deadline or cost – prevents the delays that most creditors encounter on their first attempt. The total elapsed time from a complete filing to enforcement action is typically six to twelve months, depending on court workload and whether the debtor contests the application.

Stage one is document preparation. The applicant must file: the original UAE judgment (or a certified copy), a certificate of finality from the UAE court, certified Polish translations of both documents, proof of proper service on the defendant in the UAE proceedings, and a power of attorney for the Polish advocate. The UAE Ministry of Justice issues the finality certificate. Apostille authentication under the Hague Convention applies – both Poland and the UAE are Contracting States to the 1961 Apostille Convention, so UAE public documents can be apostilled without full diplomatic legalisation. This saves two to three weeks compared to non-Apostille jurisdictions.

Stage two is filing with the Regional Court. The court fee for an exequatur application is a fixed PLN 300 under Polish civil procedure fee rules. This is one of the lowest court fees in the entire enforcement chain. The application must state the amount claimed, identify the debtor's assets in Poland if known, and attach all translated documents.

Stage three is the inter partes hearing. The court notifies the debtor, who has the right to oppose recognition. Opposition is common in contested commercial disputes. The debtor typically raises public-policy objections or challenges the finality certificate. The court schedules one to three hearings. Each hearing adds six to ten weeks to the timeline.

Stage four is the court's decision. If the court grants recognition, it issues a declaration of enforceability and appends the enforcement clause (klauzula wykonalności). If refused, the applicant may appeal to the Court of Appeal (Sąd Apelacyjny) within two weeks of service of the written grounds.

Stage five is enforcement. With the enforcement clause in hand, the creditor engages a court bailiff (komornik sądowy). The bailiff can seize bank accounts, attach receivables, and initiate sale of real property. Bailiff fees are calculated as a percentage of the amount recovered – typically 15% of the sum collected, subject to a statutory cap.

What are the most common pitfalls in UAE judgment enforcement cases?

Most failed or delayed applications share the same avoidable errors. Identifying them early protects the creditor's timeline and – more importantly – prevents the debtor from dissipating assets while the process drags on. Asset dissipation is irreversible: once funds leave Poland, a Polish bailiff has no reach.

The first and most damaging mistake is filing without interim protective measures. Polish civil procedure allows a creditor to apply for a zabezpieczenie roszczenia (interim asset freeze) simultaneously with – or even before – the exequatur application. The threshold for granting a freeze is lower than for enforcement. A creditor who waits for the full recognition process before securing assets risks finding an empty bank account at the end of a ten-month procedure. We secured interim measures protecting assets worth over EUR 3m for a UAE trading client against a Warsaw-based distributor (autumn 2025). The freeze was granted within 48 hours of filing.

The second common error is underestimating the public-policy objection. UAE commercial court judgments occasionally include penalty clauses or interest rates that Polish courts view as disproportionate. A judgment awarding contractual penalties of 30% per month, for example, may be partially refused on public-policy grounds – not the entire judgment, but the penalty element. The practical fix is to separate the principal debt from the penalty claim in the application and seek recognition of the principal first.

The third mistake is incorrect identification of the competent court. Filing with the wrong Regional Court causes automatic rejection and restarts the clock. The competent court is determined by the debtor's domicile or the location of the assets – not the creditor's preference. Check the KRS entry before filing.

A fourth issue arises in sanctions-adjacent cases. If the UAE judgment involves a party subject to EU or Polish sanctions, Polish banks and bailiffs will refuse to cooperate regardless of the enforcement clause. Sanctions compliance review – checking against the EU Consolidated Sanctions List and the Polish Financial Supervision Authority (KNF) watch-list – must precede any enforcement action. Skipping this step can expose the creditor's own Polish entity to regulatory liability.

How do three business scenarios illustrate the practical differences?

The legal framework applies uniformly, but the practical experience differs significantly depending on the commercial context. Three scenarios illustrate the range.

Scenario one – UAE construction contractor vs. Polish subcontractor. A UAE-based FIDIC contractor obtains a Dubai court judgment for AED 4.2m against a Polish civil engineering firm that abandoned a project in the Gulf. The Polish firm has equipment and receivables in Silesia. The creditor files for an exequatur in the Katowice Regional Court and simultaneously requests an asset freeze on the firm's bank accounts. The debtor contests finality – arguing the UAE judgment was not yet final because an appeal period had not elapsed. The creditor presents a UAE Ministry of Justice certificate confirming finality. The court grants recognition after two hearings, total elapsed time: eight months. Enforcement against receivables recovers approximately 60% of the judgment within three months of the enforcement clause being issued.

Scenario two – Dubai financial services firm vs. Polish holding company. A Dubai-registered lender holds a UAE judgment for USD 2.1m against a Polish holding company whose sole asset is a Warsaw apartment block. The debtor challenges the public-policy condition, arguing the UAE court lacked jurisdiction because the contract contained a Warsaw arbitration clause. The Polish court finds the arbitration clause was waived by the debtor's voluntary participation in UAE proceedings. Recognition is granted. The enforcement against real property takes an additional 18 months through the auction process – the longest stage in the entire chain. Total time from filing to recovery: approximately 28 months. The lesson: real-property enforcement in Poland is slow. Creditors with a choice should prioritise bank accounts and receivables.

Scenario three – UAE e-commerce company vs. Polish logistics provider. A UAE online retailer obtains a small-claims UAE judgment for AED 180,000 against a Warsaw logistics firm for lost cargo. The amount is modest. The creditor's Polish counsel advises that the cost-benefit ratio of full exequatur proceedings – advocate fees, translations, court time – may not justify the exercise for this amount. An alternative: the parties negotiate a settlement using the UAE judgment as leverage, avoiding Polish court proceedings entirely. The judgment's existence, combined with a creditor-side threat to file, produces a settlement at 80% of face value within six weeks. Sometimes the most effective enforcement tool is the one you do not have to use.

For UAE creditors seeking a broader comparison of how Poland handles foreign judgments from different jurisdictions, our guide on enforcing a Ukrainian judgment in Poland covers parallel procedural questions under a different treaty framework.

What checklist should a UAE creditor prepare before filing?

Preparation quality determines speed. Courts reject incomplete applications, and each rejection adds weeks. The following checklist covers the minimum required documents and pre-filing steps for a UAE exequatur application in Poland.

  • Original UAE judgment or certified copy, apostilled by the UAE Ministry of Foreign Affairs
  • UAE court certificate confirming the judgment is final and not subject to further appeal, apostilled
  • Certified Polish translation of both documents by a sworn translator on the Polish Ministry of Justice register
  • Proof of proper service on the defendant in the UAE proceedings (court bailiff record or equivalent)
  • KRS extract for the Polish debtor entity (not older than 30 days) confirming current registered address and competent Regional Court

Beyond documents, two pre-filing steps are worth completing before the application is lodged. First, conduct a sanctions compliance check against the EU Consolidated Sanctions List. Second, instruct Polish counsel to search for any parallel Polish proceedings involving the same parties and the same claim – a pending parallel action precludes recognition under KPC rules and must be resolved first. Skipping either step can derail the application after months of preparation.

We obtained a declaration of enforceability for a UAE-based commodities trader against a Mazowieckie-registered importer within seven months of filing (spring 2026). The application succeeded on the first attempt because the document package was complete and the interim freeze was filed simultaneously.

UAE creditors with Polish VAT or tax obligations arising from their commercial activity in Poland may find our overview of KSeF obligations for UAE-based companies useful as a parallel compliance reference.

For a full overview of the firm's contentious practice, including cross-border enforcement and arbitration in Poland, visit our disputes practice page.

The specific circumstances of your enforcement case determine which steps carry the greatest risk. A creditor who files without interim protection and without a sanctions check forfeits the two most important safeguards in the process – and those losses are irreversible once assets leave Poland.

To receive an expert assessment of your UAE judgment enforcement options in Poland, contact info@kordeckipartners.com.

Frequently asked questions

Q: Does Poland have a treaty with the UAE that simplifies enforcement?

A: No. Poland and the UAE have not concluded a bilateral treaty on mutual recognition and enforcement of civil judgments. Enforcement therefore proceeds under the general provisions of Polish civil procedure law applicable to non-treaty states. This means the creditor must satisfy the full list of statutory recognition conditions, including the public-policy filter, rather than relying on a streamlined treaty mechanism. The process is manageable but requires more preparation than enforcement from EU member states.

Q: How long does the full enforcement process take, and what does it cost?

A: The exequatur stage – from filing to the court's decision – typically takes four to ten months, depending on whether the debtor contests the application. An uncontested application in a straightforward case can conclude in four months. A contested case with two or three hearings takes eight to twelve months. Court fees for the exequatur application are PLN 300. Advocate fees vary by case complexity, typically in the range of PLN 15,000 to PLN 40,000 for the recognition stage. Enforcement by bailiff adds 15% of the recovered amount in bailiff fees. Translation costs for Arabic-language UAE judgments typically run PLN 3,000 to PLN 8,000 depending on document length.

Q: Can a UAE arbitral award be enforced in Poland more easily than a UAE court judgment?

A: Yes, in most cases. Poland is a party to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (1958), and the UAE is also a Contracting State. A UAE-seated arbitral award therefore benefits from a multilateral treaty framework that is more creditor-friendly than the general recognition rules for foreign court judgments. The grounds for refusing recognition of a New York Convention award are narrower than those applicable to foreign judgments under KPC rules. Creditors structuring future UAE-Poland contracts should consider specifying arbitration – in a New York Convention seat – rather than UAE court jurisdiction, specifically to preserve this enforcement advantage in Poland.

KORDECKI & Partners is a law firm based in Warsaw and Krakow, advising business clients across 30 jurisdictions. Our team combines expertise in Polish and international law with a practical approach to cross-border enforcement, commercial litigation, and arbitration in Poland. We work with Polish entrepreneurs, foreign investors, and in-house legal teams. To discuss your situation, contact info@kordeckipartners.com.

Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. KORDECKI & Partners assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@kordeckipartners.com.