A heavier week than the last on the regulatory side and one genuinely material reasoned First Instance judgment to read. The substantive reasons in A28 v B28 [2026] ADGMCFI 0012 have now been published and the case is the first ADGM authority squarely on the curial supervision of ICC institutional arbitrator-appointment powers, a reasoned decision of Heath KC declining jurisdiction to set aside the ICC Court's appointment of a sole arbitrator under Articles 12(9) and 13(4)(a) of the ICC Rules.

The DIFC Court of First Instance also published a full judgment, Stephenson Harwood Middle East LLP v Mark A B Capital Investment LLC [2025] DIFC CFI 009 of H.E. Justice Shamlan Al Sawalehi, alongside reasons of H.E. Justice Roger Stewart KC in Kitopi Catering Services LLC v Mons Hospitality FZE CFI 081/2024 and the Court of Appeal's reasons in (1) The Collection Club Restaurant Ltd, (2) Buisine, (3) Valat v Mag Development Services Ltd CA 006/2026 (the companion appeal to the strike-out and immediate-judgment order in CFI 092/2024 reported last week). Full reasons in the three 28 April 2026 DIFC orders previewed last week - Hallam v Natixis CFI 016/2025, Alizz Islamic Bank v Alef Capital CFI 048/2025 and MAG Development v The Collection Club CFI 092/2024 have now been posted.

Of the three, Alizz Islamic Bank is the most substantive, with Justice Le Miere striking out the Defendant's counterclaim in a USD 5m wakalah claim and ordering costs of all three contested applications to be costs in the case; the other two are short consequentials orders. All three are taken in turn below.

On the regulatory side, Friday 1 May 2026 was the commencement date for two QFCRA Rulebook amendment instruments, the Representative Office and Miscellaneous Amendments Rules 2026 (RM/2026-2) and the INMA (Wholesale Advisory Firms) Amendments Rules 2026 (RM/2026-1), both of which have now taken effect, with approximately 295 section revisions across the consolidated rulebook timestamped that morning.

The ADGM Registration Authority published a major commercial legislation refresh on the same day, amending the Foundations Regulations 2017, the Distributed Ledger Technology Foundations Regulations 2023, the Trusts (Special Provisions) Regulations 2016, the Beneficial Ownership and Control Regulations 2022, the Administrative Regulations 2025 and the Companies Regulations 2020, and replacing the 2025(B) Conditions of Licence and Branch Registration Rules with new 2026 Rules.

No new DIFC Laws, Regulations, Amendment Laws, Enactment Notices, Practice Directions or Registrar's Directions, no new QFC Laws, no new QICDRC Practice Directions and no new ADGM Court Procedure Rules amendments came into force in the period.

New judgments

[2026] ADGMCFI 0012 — A28 v B28 (anonymised) Court: ADGM Court of First Instance, Al Maryah Island Date: 17 April 2026 Judge: Justice Paul Heath KC Case number: ADGMCFI-2025-301 Provisions: ADGM Arbitration Regulations 2015, ss. 14(6), 19(2), 20(2) and 21; ICC Rules of Arbitration, Articles 11(4), 12(9) and 13(4)(a).

The reasons of Heath KC in A28 v B28 were flagged in last week's update as a sealed and anonymised CFI judgment newly added to the ADGM Courts listing. The full reasons have now been published and the case is by some distance the most material First Instance ruling of the period for ADGM litigators. Heath KC held that the ADGM Court of First Instance has no jurisdiction under section 14(6) of the ADGM Arbitration Regulations 2015 to set aside an appointment by the ICC Court of a sole arbitrator made pursuant to Articles 12(9) and 13(4)(a) of the ICC Rules in circumstances where the parties have adopted the ICC Rules without expressly excluding Article 12(9), and that the Court is precluded from reviewing the ICC Court's "exceptional circumstances" finding under Article 11(4). The Court engaged with Jivraj v Hashwani [2011] UKSC 40 and Sierra Fishing v Farran [2015] EWHC 140 (Comm), and with the recent ADGM authorities of A24 v B24 [2025] ADGMCFI 0019 and A30 v E30 [2025] ADGMCA 0003. The decision is the first ADGM authority squarely addressing the interplay between ICC institutional appointment powers and unilateral appointment clauses, and the limits of curial supervision where parties have adopted institutional rules. It is likely to be cited regularly in ADGM-seated ICC arbitration challenges and is the diary item for any practitioner with an ADGM-seated arbitration touching on appointment, removal or replacement of arbitrators.

[2025] DIFC CFI 009 — Stephenson Harwood Middle East LLP v Mark A B Capital Investment LLC Court: DIFC Court of First Instance Date: 29 April 2026 Judge: H.E. Justice Shamlan Al Sawalehi Case number: CFI 009/2025 Issues: claim by a DIFC-based law firm against a former client.

A full substantive judgment of H.E. Justice Shamlan Al Sawalehi on a claim by a top-tier law firm against a corporate client. Cases of this fact pattern are rarely reported in the DIFC Courts and the judgment is therefore a useful precedent for DIFC-registered firms suing on engagement letters, fee disputes and recoverable disbursements, and for clients defending such claims. Practitioners should read the linked PDF in full before relying on it; on the public listing the Court's reasoning is set out in some detail and is the more substantive of this week's three reasoned DIFC items.

CA 006/2026 — (1) The Collection Club Restaurant Ltd, (2) Laurent Buisine, (3) Hugo Valat v Mag Development Services Ltd Court: DIFC Court of Appeal Date: 24 April 2026 Case number: CA 006/2026.

The Court of Appeal's reasons dismissing the appeal against the strike-out and immediate-judgment order in CFI 092/2024 (covered last week as one of the three 28 April 2026 Orders with Reasons of the DIFC Court of First Instance). Costs are to be assessed by H.E. Chief Justice Wayne Martin sitting as delegate. Read together with the underlying first-instance order, the pair is a useful working primer on DIFC strike-out and immediate-judgment practice and on the way the Court of Appeal handles appeals from interlocutory orders without leave. A diary item for any DIFC litigator advising on either side of a strike-out application.

CFI 081/2024 — Kitopi Catering Services LLC v Mons Hospitality FZE Court: DIFC Court of First Instance Date: 30 April 2026 Judge: H.E. Justice Roger Stewart KC Case number: CFI 081/2024.

A short Order with Reasons of H.E. Justice Roger Stewart KC, consequential to the substantive judgment of 4 February 2026 in the same matter. The interest of the order is largely procedural and lies in Stewart KC's continued willingness to dispose of consequentials by reasoned order rather than by a separate hearing where the parties' positions are sufficiently set out in their written submissions. Worth reading as a template for the way DIFC consequentials applications are now being managed under the post-2025 case management rules.

CFI 004/2023 — Zuzana Kapova v (1) Miloslav Makovini, (2) Pharm Trade Holding Ltd, (3) Mr Sebastian Kapa Court: DIFC Court of First Instance Date: 29 April 2026 Judge: Sir Jeremy Cooke Case number: CFI 004/2023.

An order of Sir Jeremy Cooke giving effect to a settlement agreement reached between the parties, including in respect of a third party. The order is short and is included here for completeness; it is unlikely to be cited as authority but does illustrate the form of order the DIFC Court will make where settlement is reached after a long-running matter has been listed for hearing.

CFI 073/2024 — LXT Real Estate Broker LLC v SIR Real Estate LLC Court: DIFC Court of First Instance Date: 24 April 2026 Judge: H.E. Justice Andrew Moran Case number: CFI 073/2024.

A consequential order of H.E. Justice Andrew Moran flowing from his Order of 9 January 2026 in the same matter. The companion Court of Appeal proceedings — CA 005/2025 — produced two short orders earlier in the year and are linked from the listing for cross-reference. The case is part of a longer real-estate brokerage commission dispute and the order is procedural rather than substantive.

DIFC Court of First Instance — full reasons in the three 28 April 2026 orders

CFI 016/2025 — Omar Ben Hallam v Natixis Court: DIFC Court of First Instance Date: 28 April 2026 Judge: H.E. Deputy Chief Justice Ali Al Madhani Case number: CFI 016/2025 Application: CFI-016-2025/1.

Order with Reasons of H.E. Deputy Chief Justice Ali Al Madhani on the costs of the Claimant's Extension Application made under paragraph 3 of the 12 June 2025 Extension Order. The Application having been previously dismissed, the costs of it have now been summarily assessed at AED 6,120 in the Defendant's favour. The order is short and the practitioner interest lies in DCJ Al Madhani's continued willingness to assess summary costs on the papers in modest extension-application disputes rather than ordering detailed assessment, and in the firm cost consequences of an unsuccessful procedural application against a represented respondent.

CFI 048/2025 — Alizz Islamic Bank S.A.O.C v Alef Capital B.S.C.(C) (formerly Investrade Company B.S.C.(C)) Court: DIFC Court of First Instance Date of order: 28 April 2026 Date of hearing: 8 April 2026 Judge: H.E. Justice Rene Le Miere Case number: CFI 048/2025 Applications: CFI-048-2025/2 (Claimant) and CFI-048-2025/3 (Defendant) Provisions: RDC 4.16. Faisal Osman for Alizz.

A substantive Order with Reasons of H.E. Justice Le Miere disposing of three contested applications in the Claimant Bank's USD 5,061,907.38 wakalah claim against a Bahraini counterparty (formerly Investrade Company B.S.C.(C)). On the Claimant's Application CFI-048-2025/2, Le Miere J struck out the Defendant's counterclaim under RDC 4.16, holding that the pleaded recovery-costs counterclaim was contractually and legally foreclosed and disclosed no reasonable grounds. Justice Le Miere declined to grant immediate judgment on the principal claim, holding that the Defendant has a real prospect of defending breach, causation and loss at trial, and declined to strike out the limitation defence on the footing that the accrual-based limitation argument was arguable rather than legally incoherent and so was not amenable to summary disposition under the exceptional RDC 4.16 jurisdiction. The Defendant's cross-Application to have limitation determined as a preliminary issue (CFI-048-2025/3) had already been disposed of by the Court's Direction of 30 March 2026 and the Order of 6 April 2026 and was not entertained further. Costs of all three Applications, including the costs reserved by the 6 April 2026 Order, were ordered as costs in the case, a sensible disposition that preserves the Claimant Bank's costs position to the eventual trial outcome rather than crystallising it on the interlocutory applications. The order is a useful authority for any DIFC practitioner advising a financial-institution claimant on the deployment of strike-out under RDC 4.16 against unfounded counterclaims, and on the interaction between strike-out, immediate judgment and limitation in cross-border banking proceedings against GCC counterparties.

CFI 092/2024 — Mag Development Services Limited v (1) The Collection Club Restaurant Ltd, (2) Laurent Buisine, (3) Hugo Valat Court: DIFC Court of First Instance Date: 28 April 2026 Judge: H.E. Deputy Chief Justice Ali Al Madhani Case number: CFI 092/2024 Application: CFI-092-2024/2.

Read together with the Court of Appeal's reasons in CA 006/2026 above, this is the costs sequel — not the substantive ruling — in the Collection Club litigation. The substantive immediate-judgment ruling against the Defendants was made by DCJ Al Madhani on 28 January 2026; the 28 April 2026 order assesses costs of that Application, ordering the Defendants to pay 60% of the Claimant's costs of CFI-092-2024/2, summarily assessed at USD 46,418.37. The 60% figure is a useful data point for parties negotiating settlements at the strike-out / immediate-judgment stage of DIFC proceedings; the Court's preparedness to discount costs against an unsuccessful applicant where the application has nonetheless served some case-management function is consistent with recent practice.

Regulations, Rulebooks and Practice Directions

ADGM — Registration Authority commercial legislation refresh in force 1 May 2026. The ADGM Registration Authority has published amendments to multiple commercial Regulations, effective on publication on 1 May 2026. The instruments amended are the Distributed Ledger Technology Foundations Regulations 2023, the Foundations Regulations 2017, the Trusts (Special Provisions) Regulations 2016, the Beneficial Ownership and Control Regulations 2022, the Administrative Regulations 2025 and the Companies Regulations 2020. In addition, the Commercial Licensing Regulations (Conditions of Licence and Branch Registration) Rules 2025(B) have been repealed and replaced by the Commercial Licensing Regulations (Conditions of Licence and Branch Registration) Rules 2026. Headline practitioner-facing changes are: (i) foundations and trusts may no longer be set up for purposes falling within the ADGM AML definition of non-profit organisations, (ii) trustee beneficial-ownership obligations have been clarified and streamlined under the BOC Regulations, (iii) the issue of bearer shares is now expressly prohibited and (iv) the Companies Regulations filing deadlines have been updated. None of the amendments are Courts-issued and they will not appear on the ADGM Courts legislation page; practitioners should pull the consolidated 2026 versions from the ADGM Legal Framework page.

QICDRC / QFC — RM/2026-1 and RM/2026-2 in force 1 May 2026. Two QFCRA Rulebook amendment instruments came into force on Friday 1 May 2026, as flagged in last week's update: the Representative Office and Miscellaneous Amendments Rules 2026 (RM/2026-2) and the INMA (Wholesale Advisory Firms) Amendments Rules 2026 (RM/2026-1). The consolidated QFCRA rulebook update went live on schedule, with approximately 295 section revisions across GENE, COLL, CIPR and the archives timestamped 1 May 2026 at 08:58. Affected QFC firms should now treat the amended provisions as the live primary materials.

ADGM — open consultation, AML framework, closing 14 May 2026. The ADGM Financial Services Regulatory Authority's Consultation Paper No. 1 of 2026 — Proposed Enhancements to the Anti-Money Laundering Framework of the FSRA, opened on 30 April 2026 and flagged in last week's update — remains open for response until 14 May 2026. The full English version is now available on the ADGM Document Repository. Recommended reading for any ADGM-regulated entity with AML compliance responsibilities; the closing date falls within next week's coverage period.

DIFC / DFSA — no rulebook or legislative changes in the period. No new DIFC Laws, Regulations, Amendment Laws or Enactment Notices were added to the DIFC Legal Database. The known backlog item is Regulatory Law Amendment Law DIFC Law No. 2 of 2025 (in force 30 October 2025), which has yet to appear in the publicly indexed Amendment Laws folder; practitioners working with the most recent DFSA-regulated population should treat the consolidated DIFC Regulatory Law as the authoritative version pending publication. CP 170 and CP 171 (both released 27 March 2026) remain open consultations, with no change in status during the period.

QICDRC and DIFC Practice Directions — nothing new. No new Practice Directions, Practical Guidance Notes, Registrar's Directions or Court Administrative Orders were issued in either centre during the coverage period. The most recent QICDRC PD remains PD 1/2026 (Artificial Intelligence in Court Proceedings, 6 January 2026); the most recent DIFC PD remains PD 1/2025 (Access to Justice in Employment Disputes, 9 October 2025). The most recent ADGM Practice Direction remains PD01 (General, 30 November 2023) save that the eleven topic-specific Practice Directions consolidated at 17 October 2025 (PD02 Commercial & Civil through PD16 Short-Term Residential Lease, save PD08 Evidence and PD13 Court-Annexed Mediation) remain the live versions.