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Comparison of selected legal systems
AttributeUnited Arab EmiratesReviewedLibyaIndexed
Legal familyMixed (civil law and Islamic law, with common-law financial free zones)Civil law with Islamic law as a source
System of governmentFederal elective monarchyProvisional government with contested authority
ConstitutionConstitution of the United Arab EmiratesConstitutional Declaration (interim)
In force since19712011
CapitalAbu DhabiTripoli
Official languagesIdenticalArabicArabic
CurrencyUAE dirham (AED)Libyan dinar (LYD)
Population10,500,0006,900,000
Division of powersFederal, and asymmetric in practice. Seven emirates, of which Dubai and Ras Al Khaimah maintain their own separate local court systems outside the federal judiciary entirely, while the others are integrated into it. Each emirate legislates in its own sphere, and the two financial free zones are separate legal jurisdictions with civil and commercial competence.Nominally unitary with governorates and municipalities. In practice authority is divided between competing administrations and local armed actors, and municipal councils have in many places become the most functional layer of government.
How law is madeDraft federal legislation is prepared by the Council of Ministers, reviewed by the Federal National Council, approved by the Supreme Council of Rulers and ratified by the President before publication in the Official Gazette. The Federal National Council may propose amendments but the Supreme Council may enact legislation over its objection. Much regulation now issues as federal decree-laws. Free-zone legislation is enacted by the DIFC and ADGM authorities under their own procedures.There is no single functioning legislative process. The House of Representatives passes laws that the High Council of State contests, and the rival administrations issue decrees within their areas of control. Whether a given instrument is law therefore depends on which authority is recognised, which is exactly why this profile is marked as requiring research rather than described as settled.
Legal professionOnshore advocacy before the federal and local courts is reserved to UAE nationals licensed by the Ministry of Justice, with foreign lawyers practising as legal consultants; pleadings onshore must be in Arabic. The DIFC and ADGM courts, by contrast, admit registered practitioners from any common-law jurisdiction and conduct proceedings in English, which is the principal practical reason parties opt into them. Notarisation before a public notary is required for powers of attorney, share transfers and real property dispositions.Advocates are admitted through the Libyan Bar Association, and the profession has continued to function, including in human-rights litigation, despite serious risks to practitioners. Judicial appointments run through the Supreme Judicial Council. Reliable current information on admission requirements and numbers is limited, which is reflected in the verification status of this entry.

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.