Comparison
Read two legal systems against each other
Because every portal follows the same fifteen-section outline, the comparison is genuinely like-for-like rather than a collage of whatever each government happens to publish.
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| Attribute | KuwaitReviewed | Saudi ArabiaReviewed |
|---|---|---|
| Legal family | Mixed (civil law and Islamic law) | Islamic law |
| System of government | Unitary constitutional monarchy | Unitary Islamic absolute monarchy |
| Constitution | Constitution of the State of Kuwait | Basic Law of Governance |
| In force since | 1962 | 1992 |
| Capital | Kuwait City | Riyadh |
| Official languagesIdentical | Arabic | Arabic |
| Currency | Kuwaiti dinar (KWD) | Saudi riyal (SAR) |
| Population | 4,300,000 | 36,900,000 |
| Division of powers | Unitary. Six governorates administered by appointed governors, with no legislative competence. | Unitary. Thirteen provinces headed by governors drawn from the royal family and appointed by the King, each with an appointed provincial council. No legislative competence exists below the national level. |
| How law is made | Under the constitution as designed, bills passed by the National Assembly required Emiri sanction, and the Emir could return a bill for reconsideration which the Assembly could override by a two-thirds majority. With the Assembly dissolved and the relevant articles suspended since May 2024, legislation is made by Emiri decree on the proposal of the Council of Ministers and published in the Official Gazette (Kuwait Al-Youm). | There is no legislature with power to enact law. Proposals originate in ministries or the Shura Council, are considered by the Council of Ministers, and take effect as royal decrees signed by the King and published in Umm al-Qura. The Shura Council may study and recommend but its resolutions require royal approval, and the King may legislate without consulting it. |
| Legal profession | Advocacy is reserved to Kuwaiti nationals enrolled with the Ministry of Justice and the Kuwait Bar Association, with foreign lawyers acting as consultants and unable to appear; pleadings are in Arabic. Judges are appointed by the Supreme Judicial Council, and a significant proportion of the bench has historically been seconded from other Arab states. Notarial authentication at the Ministry of Justice is required for powers of attorney, property transfers and company formation documents. | Advocates are licensed under the Code of Law Practice and must be Saudi nationals to appear in court, though licensed foreign firms may advise and now associate more freely following the 2024 opening. Judges are appointed from graduates of Sharia faculties by the Supreme Judicial Council and the King. Notarisation is a judicial function performed by notaries within the Ministry of Justice, and most commercial documentation must be executed in Arabic to be enforceable onshore. |
A comparison table flattens nuance by design. Where a difference matters to a decision you are making, open both portals and read the section in full — the constitutional detail behind a one-line summary is often the part that governs the outcome.