JURISDICTION WATCH - Middle East (Q3 2025)

Nithya Viswanathan
Nov 17, 2025
2 min read

Updated: Nov 27, 2025

Q3 activity has revealed how the Middle East is charting a distinct path amid global slowdown, with dealmaking, legal reform, and geopolitical shifts shaping the agenda.

Capital Markets and Deal Making

While global M&A activity declined by 9%, the Gulf pressed ahead. Anchored by Saudi Arabia and the UAE, activity was exemplified by ADNOC’s fundraising through its $317 million secondary share sale, reflecting a broader push to unlock value through stake flotations in state-owned enterprises, boosting liquidity while steadily thinning their own market footprint. This growth is increasingly driven by mid-market deals, which are faster to execute, more financeable, and aligned with national priorities in green energy, healthcare, and digital infrastructure.

Privatisation and localisation remain central, with over half of regional leaders planning acquisitions within three years under Saudi Vision 2030 and the UAE’s Net Zero 2050 agenda. Egypt also rebounded in H1 2025 with 86 deals across industrial, financial, and consumer sectors, as investor appetite returns amid reforms and IMF support.

Regulatory and Legal Development

Policy reform is only reinforcing this momentum. The Dubai International Financial Centre (DIFC) amended its Data Protection Law, introducing a landmark private right of action. Modelled on the GDPR, it allows data subjects to apply directly to court for financial or non-financial damages arising from contraventions. The reform broadens liability, clarifies extraterritorial scope, and raises litigation risks, pushing firms to improve complaint handling, consent management, incident response, and cross-border transfer controls.

Additionally, effective 2026, Saudi Arabia’s new Real Estate Ownership Law marks a decisive liberalisation, allowing foreign individuals, companies, and funds to directly acquire property and rights in rem within designated zones. Previously confined to narrow operational needs and indirect exposure via CMA-approved funds, foreign ownership is now liberalised to cover residential, commercial, and industrial assets, as well as transferable rights like leaseholds, usufructs, and easements. It enables joint ventures, REITs and cross-border M&A, supporting Vision 2030 and fuelling participation in giga-projects such as NEOM.

Logistics, Energy and Risk

Geopolitical volatility, however, casts a shadow. The Israel–Iran conflict and Houthi attacks in the Red Sea have disrupted two critical trade routes, the Gulf of Hormuz and the Red Sea. The sinking of two Greek vessels in July pushed war-risk insurance premiums from 0.3% to 1% of vessel value, driving up costs through rerouting and bottlenecks. Law firms are seeing a rising demand for force majeure, insurance, and compliance advice as disputes mount. More broadly, corporates are embedding geopolitical risk into supply chains, M&A strategies, and investment decisions, an approach which may become industry standard.

Looking forward, Q4 2025 will test if momentum survives new rules, regional risks, and localisation pressures.