Royal Decree No. M/237 approves a new Enforcement Law that replaces the Kingdom's 2012 enforcement framework. Published in the Official Gazette on 1 1 May 2026, the law will enter into force 180 days after publication, on 28 October 2026. Businesses operating in Saudi Arabia should review their enforcement instruments and internal processes before this date.
Under Article 7(1)(d), bills of exchange and PN will only qualify as enforcement instruments if registered on the Nafith electronic platform.
Promissory notes and bills of exchange issued before 28 October 2026 may continue to be treated as enforcement instruments for one year after the New Enforcement Law comes into force, even if they have not been electronically registered.
Businesses holding PNs should identify them now, verify the maturity dates and determine whether registration, replacement, or other action is required during the transitional period.
Article 11 introduces a ten-year time bar for enforcement application, calculated from the maturity date of the enforcement instrument. This limit applies subject to any shorter limitation period under other applicable laws, such as the 5 year time bar for commercial dispute under the saudi commercial court law.
The law also introduces a developed asset-tracing regime, including investigatation of possible concealment or dissipation of assets and, in certain cases, engagement of licensed private-sector service providers to assist with tracing, including judicial sales, asset custody, asset tracing and recovery. Core judicial measures - including imprisonment, travel bans and the resolution of enforcement disputes - remain with the court.
Rather than proceeding immediately to a forced sale, the court may allow the debtor a grace period to sell certain assets voluntarily, subject to the applicable controls and where doing so serves the interests of enforcement.
If a debtor does not comply within five working days after being notified, compulsory enforcement measures may begin. These include reporting the debtor’s non-compliance to licensed credit information agencies and seizing existing and future assets.
A debtor may receive an additional ten-working-day period if it provides a bank guarantee sufficient to satisfy the debt.
The court may also impose a daily fine of up to 5,000 SAR for continued non-compliance, subject to the maximum limit that will be determined in the Implementing Regulations.
Travel ban are no longer an automatic consequence of default. They must be requested and are subject to clearer limits and safeguards.
A travel ban may be imposed for up to three (3) years and renewed once, for a total maximum of six (6) years period. The enforcement court judge has discretion to lift the ban where the debtor has proved one of the following:
- sufficient assets to cover the debt;
- a need to travel for medical treatment; or
- that maintaining the restriction would cause severe harm.
The New Enforcement Law establishes the framework for a more structured and digital enforcement process. Several operational and procedural details, however, remain to be clarified in the forthcoming Implementing Regulations. Creditors should be aware of the following areas where regulatory guidance will be essential:
The law requires promissory notes to be registered on the Nafith platform to qualify as enforcement instruments, but the mechanics of registering existing instruments—particularly where debtor cooperation may be required—have not yet been specified. The Implementing Regulations are expected to set out the registration process, including whether and how a creditor may register an instrument unilaterally or what steps to take if the debtor does not cooperate. Until then, creditors holding unregistered promissory notes should prepare for the possibility that, without a clear registration pathway, they may need to pursue standard commercial proceedings if Nafith registration proves impracticable.
The law provides that a travel ban may be lifted where the debtor demonstrates "sufficient assets to cover the debt," but it does not define how sufficiency is to be measured or verified. The Implementing Regulations will likely prescribe the evidentiary standards and valuation methods required, giving both creditors and debtors greater certainty as to when this exception applies.
While the law authorises daily fines of up to 5,000 SAR for continued non-compliance, it defers the overall maximum cap to the Implementing Regulations. Creditors and debtors alike will benefit from the clarity that the regulations provide on the total financial exposure under this provision.
The law introduces the concept of reverse enforcement—where a debtor may apply to compel a creditor to accept payment—but leaves the detailed procedure to the Implementing Regulations. The regulations are expected to clarify the filing requirements, evidentiary thresholds, and the precise measures the court may take to discharge the debtor's liability, ensuring the mechanism operates as intended without unduly delaying legitimate creditor claims.
Although the law mandates asset disclosure and empowers the court to investigate concealment, the specific consequences for false or materially incomplete declarations will likely be addressed in the Implementing Regulations. Clear sanctions are important to ensure the disclosure regime remains effective and credible.
The New Enforcement Law does not expressly state how enforcement proceedings initiated under the previous 2012 regime will transition once the new law enters into force. The Implementing Regulations are expected to provide transitional rules, giving parties with pending cases clarity on whether existing proceedings continue under the former framework or become subject to the new requirements.
The interaction between enforcement actions and parallel bankruptcy, protective settlement, or financial restructuring proceedings is not detailed in the new law. The Implementing Regulations—or subsequent regulatory guidance—will likely clarify how enforcement proceedings are to be coordinated with, or suspended in favour of, formal insolvency processes.
Abdulaziz Bin Ali Law Firm will continue to monitor the publication and entry into force of the Implementing Regulations and will issue a further legal alert once those regulations are issued, analysing their practical impact on the issues identified above.
