A banking dispute often begins with a balance that does not match the customer's records. A borrower may dispute interest, a business may receive a demand under a guarantee, or a customer may be unable to resolve an unexplained charge. The first task is to identify what is disputed and which documents establish the bank's entitlement.
A lawyer in Dubai advising on banking and loan disputes should assess the account, the customer's legal status and the available procedure together. Negotiation, a regulatory complaint and court proceedings serve different purposes. Choosing the appropriate route early helps protect deadlines and keeps the dispute focused on a practical remedy.
The Central Bank’s UAE Banking Indicators recorded gross credit of AED 2,570.3 billion at the end of December 2025, a 17.9% year-on-year increase. The December figures were marked preliminary. This describes aggregate lending activity; it is not a total of disputed or overdue loans and does not establish an individual borrower’s liability.
Obtain the signed facility agreement, amendments, account terms, repayment schedule and security documents. Identify the borrower separately from any guarantor, director or shareholder. A person who signed for a company may have signed another document in a personal capacity, so each signature must be examined.
Different protections may apply to individuals, sole proprietorships and companies. Federal Decree Law No. 6 of 2025 contains the current Central Bank framework, including customer protection and specific requirements concerning facilities provided to natural persons and sole proprietorships.
Eligible business customers also have a separate regulatory framework. The Central Bank's SME Customer Protection Regulation, effective from 13 September 2026, addresses dealings by banks and finance companies with qualifying small and medium sized enterprises. Establish which regime applies before treating a consumer rule as universal.
Prepare a transaction schedule showing the original advance, repayments, interest or profit, fees and adjustments. Match each payment to a receipt or bank entry. Record the date the bank says a payment became overdue and whether it later accelerated the remaining balance.
Ask for an explanation of unclear entries rather than challenging every charge together. An accounting review should establish which amount is accepted, which is disputed and why. For example, an instalment paid into another account may require a payment allocation correction rather than an argument about the interest rate.
The Consumer Protection Standards require relevant final contractual documents to be provided to consumers, including security and guarantee documents. Guarantors and other signatories are also entitled to copies within the applicable requirements. Use those records to establish what was agreed.
Article 148 of the 2025 Central Bank law prohibits licensed financial institutions from charging interest on accrued interest in relation to customer facilities, subject to the Central Bank's applicable rules and controls. The contractual label attached to a charge does not settle how it was calculated.
Article 72 of the Commercial Transactions Law addresses contractual interest on commercial loans. Its nine per cent limit concerns the market rate used when the contract does not state a rate. It should not be described as a universal ceiling on every agreed lending rate. Article 88 separately prohibits compound interest.
Islamic financing requires examination of its underlying structure. Article 473 imposes specific restrictions on interest or benefit in lending and on overdue debt. A claim should identify the financing arrangement and disputed calculation, rather than assume conventional loan terminology resolves the issue.
Article 150 of the 2025 Central Bank law requires adequate guarantees for facilities provided to natural persons and sole proprietorships. It addresses admissibility of claims by institutions that fail to obtain or maintain the required guarantees.
The review should examine the actual security, applicable requirements and evidence of compliance. A disputed affordability assessment or missing document does not automatically establish that the entire debt has been extinguished. A banking lawyer in Dubai should identify the precise statutory consequence supported by the facts.
Use the bank's official complaint channel and retain its acknowledgement and reference number. Explain the disputed transaction, attach supporting records and state the correction sought. A concise complaint requesting reversal of an identified charge is easier to investigate than a general allegation of unfair treatment.
Where the bank rejects a customer complaint, Article 148 requires written reasons for its decision. Keep that response with the original complaint and any subsequent clarification.
If the concern involves unauthorised transactions, report them promptly through verified channels and preserve messages and transaction records. Do not delay immediate reporting while waiting to assemble a complete legal argument.
Sanadak's published eligibility checker covers individuals, sole proprietors and SMEs complaining about relevant licensed financial institutions. It asks whether an official complaint was made first and whether fifteen calendar days have passed without a satisfactory written response. Check the applicable period and current eligibility guidance before filing, as published procedures can change.
Its criteria also identify circumstances in which a complaint may be rejected, including a matter already before a court, a duplicate complaint, a settled issue or a matter outside the Central Bank's regulatory mandate. Issues materially concerning internal pricing, risk management or money laundering policies can also fall outside acceptance criteria. 5
A complaint should therefore describe a specific service failure, disputed conduct or financial harm. Do not assume submission prevents debt collection, pauses a court deadline or cancels the obligation to respond to legal proceedings.
Financial difficulty and a disputed balance may exist together. Separate them in correspondence. Explain the proposed payment amount, its funding source and the period required, while identifying any unresolved calculation issue.
The Consumer Protection Standards require reasonable consideration of alternative arrangements for distressed consumers. Where a revised arrangement is agreed, the standards require written disclosure of its terms and repayment allocation. They do not guarantee acceptance of every proposal or a reduction in principal.
Before signing, check whether the agreement changes interest, extends the term, replaces security or releases a guarantor. State how existing proceedings and cheques will be addressed. A verbal assurance from a collection agent should not substitute for documented settlement terms and verified authority.
A guarantee is not simply another copy of the borrower's obligation. Identify its amount, duration, covered facilities and any provisions concerning joint liability. Check whether later changes to the borrowing are said to fall within its terms.
The Civil Transactions Law effective from 1 June 2026 contains important suretyship provisions. Article 1006 addresses release where the creditor fails to begin judicial proceedings against the debtor and surety within six months from the day after the debt falls due. Article 1009 addresses recourse against the debtor and exhaustion of the debtor's property, with exceptions concerning joint liability, law and agreement. The relevant defence must be raised before the court.
A guarantor should obtain advice promptly on the relevant dates, contractual wording and applicable law, especially where agreements or events predate the new law. These provisions should not be presented as an automatic defence for every guarantee.
Banking debt recovery may involve an ordinary claim, a payment order or execution of an existing enforceable instrument. Articles 143 and 144 of the Civil Procedure Code provide a payment order procedure for qualifying written and due claims, with prescribed notice requirements. The chosen procedure must fit the claim.
Article 667 of the Commercial Transactions Law gives execution status to a cheque bearing the bank's statement that payment failed because of insufficient or absent funds. Receipt of such an execution notice requires prompt review of the instrument and available objections.
Loan default should not be described as automatic criminal liability. Likewise, a travel ban requires a judicial decision under applicable conditions, including those in Article 324. Civil detention involves its own statutory requirements and assessment of ability to pay under Article 319. Verify any actual order rather than relying on a collection message.
Yes. The review should connect each disputed entry to the agreement, statements and applicable rules. A supported calculation is more useful than a general rejection of the total.
No automatic cancellation should be assumed. The complaint, any repayment arrangement and pending court proceedings must be assessed separately, including their respective deadlines.
Liability depends on the company's legal form, the documents signed and the legal basis of the claim. A personal guarantee or separate undertaking requires its own assessment. Shareholding alone does not answer every liability question.
No automatic result should be assumed. Examine the actual guarantees, the customer’s status, applicable requirements and evidence of compliance. Counsel should identify the precise statutory consequence and any issue about how it applies to the particular facility.
Obtain the agreed terms in writing and verify the authority of the person giving the assurance. Check payment allocation, interest, security, guarantees and the treatment of any existing proceedings or cheques before relying on a revised arrangement.
Dr. Hassan Elhais is a Senior Legal Consultant at Amal Al Rashedi Lawyers and Legal Consultants in Dubai. He advises on UAE family, civil, commercial and criminal law matters.
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