Onshore, DIFC, ADGM: os três regulamentos de IA de um advogado nos Emirados

A lawyer in Dubai can file in three court systems in the same week. Each one treats AI differently. One has written guidance. One made its rule through a costs order. One has no rule at all.

Most summaries call the UAE "AI-permitted" and stop there. That label hides the part that can cost you money.

The short answer

DIFC Courts have had written guidance since 21 December 2023: Practical Guidance Note No. 2 of 2023. Verify everything. Declare AI use early. Keep witness statements in the witness's own words.
ADGM Courts have no AI practice direction. The rule came from a judgment instead: in Arabyads Holding Ltd v Gulrez Alam [2025] ADGMCFI 0032, the defendant's former lawyers were ordered to pay AED 282,508 in wasted costs for filing unverified, AI-assisted research.
Onshore federal and local courts have no AI rule for lawyers. As of March 2026, no UAE courts other than the DIFC Courts had issued AI guidelines for practitioners. Your general professional duties still apply in full.

Key facts

	DIFC Courts	ADGM Courts	Onshore courts
Written AI guidance	Yes, PGN No. 2 of 2023	No	No
Where the rule comes from	Guidance note + Rules of the DIFC Courts	Case law: Arabyads v Alam	Federal Law 34/2022 on advocacy, general duties
Must you declare AI use?	Expected "at the earliest possible opportunity"	Not stated	Not stated
Proven sanction	Court may reject AI content; contempt for false statements of truth	AED 282,508 indemnity wasted costs	General discipline. In Dubai, the Legal Affairs Department can warn, suspend for up to two years, or strike off
Language of proceedings	English	English	Arabic

1. DIFC: a written rulebook

The DIFC Courts issued Practical Guidance Note No. 2 of 2023 on 21 December 2023. It covers large language models and generative AI in proceedings.

Four things matter in practice.

Verify before you file. "Parties should not rely on AI-generated content without first verifying its accuracy." The note also tells you to check the sources the tool relied on, not only its answer.

Declare early. "Parties should declare at the earliest possible opportunity" that they intend to use AI, and the question "should be resolved no later than the Case Management Conference stage." Raise it with the other side first. If you can't agree, apply to the court.

Witness statements stay human. A witness statement must, if practicable, be in the witness's own words, and the statement of truth is signed only once the witness believes the contents are true. A false statement of truth can lead to contempt proceedings.

Clients come first. Keep clients informed and get their consent. Don't put a client's confidential information into a tool without that consent. The note ties this to paragraph 19 of the DIFC Courts' Code of Conduct.

One nuance most summaries miss. The Oxford Institute of Technology and Justice reads the note as guidance that "does not impose a formal, legally binding obligation to disclose the use of AI tools." Treat that as a reason for care, not comfort. The court can still reject AI-generated content, and late disclosure risks adjournments and lost trial dates.

2. ADGM: the rule written by a costs order

ADGM has no AI practice direction. It has something that bites harder: a judgment.

In Arabyads Holding Ltd v Gulrez Alam [2025] ADGMCFI 0032, decided in December 2025, the defendant's lawyers filed a defence of 327 paragraphs with 233 pages of exhibits. The claimant's team found authorities that did not exist and others that did not support the point they were cited for.

The ADGM Court of First Instance:

called the failure to verify AI-generated research "reckless" and a breach of the ADGM Rules of Conduct
ordered the defendant's former legal representatives to pay the claimant AED 282,508 in wasted costs, on an indemnity basis
held that "it remains a legal practitioner's obligation to verify any research prepared by an AI tool"

Read that last line again. The court did not ban AI. It made verification a personal cost risk for the lawyer who signs.

3. Onshore: no rule, every duty

Onshore federal and emirate-level courts have not published AI rules for lawyers. The Oxford Institute's UAE profile, current to March 2026, says "only the Dubai International Financial Centre (DIFC) Courts have issued specific guidelines for legal practitioners on the use of AI."

No rule does not mean no risk. Advocates practise under Federal Law 34/2022 regulating the advocacy and legal consultancy profession, in force since 2 January 2023. Its confidentiality duties are broader than under the previous law. In Dubai, the Legal Affairs Department's committees can respond to a violation with a written warning, suspension of up to two years, or striking the lawyer off the roll, and federal regulators can also discipline lawyers.

Two things make onshore AI use harder, not easier.

The proceedings run in Arabic. An AI tool that reasons well in English can still mistranslate a statutory term or cite an article number that moved in an amendment. Check the Arabic primary text, not a translation of it.
The courts use AI themselves. Onshore courts use AI for case management, translation and transcription, and Abu Dhabi introduced a machine-learning programme to follow criminal cases in 2022. A bench that uses these tools is more likely to notice a fabricated citation, not less.

How the neighbours compare

Qatar. The QICDRC issued Practice Direction No. 1 of 2026 on 6 January 2026. Every citation must be checked against primary sources or recognised legal databases. A pre-emptive declaration of AI use is not required unless the court asks. Sanctions include adverse costs orders and referral to professional regulators. It binds the QFC courts, not Qatar's onshore courts. We covered it in full in Qatar's AI Practice Direction.

Saudi Arabia. No court rule on AI in proceedings yet. SDAIA has published AI Ethics Principles (September 2023) and Generative AI Guidelines for government and for the public (January 2024).

The pattern across the Gulf is clear. Where there is a rule, it says the same thing: verify against the primary source, and you carry the risk.

What to do this week

Adopt the strictest standard everywhere. Run DIFC-level verification on every filing, onshore included. It costs minutes. Arabyads cost AED 282,508.
Check every authority against the primary source. Open the judgment or the law itself. A tool's summary is not a source.
Keep a matter log of AI use. Which tool, which task, who verified it. In DIFC you may need to declare it. Anywhere, you may need to explain it.
Get client consent before confidential data goes into any tool. Write it into your engagement letter.
Read Arabic against Arabic. For onshore work, verify the Arabic text of the article you cite, and its current version.

Where HAQQ Legal AI fits

HAQQ Legal AI is built for this kind of checking. It applies the right jurisdiction, cross-checks verified sources and shows where each answer came from, so you can open the source before you file. The duty doesn't move, though. In all three systems, the lawyer who signs carries the risk.

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Frequently asked questions

Can I use AI in UAE court proceedings?

Yes. No UAE court bans it. DIFC expects early declaration and verification. ADGM sanctions unverified output through costs. Onshore courts have no specific rule.

Do I have to tell the DIFC Courts I used AI?

The guidance expects parties to declare it at the earliest opportunity, and to resolve it by the Case Management Conference. Oxford's reading is that this isn't a formal legally binding obligation. Declare anyway.

Who paid in Arabyads v Alam?

The defendant's former legal representatives were ordered to pay AED 282,508 in wasted costs. The defendant was separately ordered to pay costs.

Does Federal Law 34/2022 mention AI?

No. Your existing duties of confidentiality, care and honesty to the court apply to AI-assisted work like any other work.

Is the Qatar practice direction stricter than DIFC's?

It's stricter on citations and sanctions, and looser on declaration. Qatar doesn't require you to declare AI use unless the court asks.

Sources and further reading