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Add: if your counterparty is based in the DIFC, the DIFC Courts would likely accept jurisdiction for a 'Dubai' clause given DIFC's mature curial regime. Confirm where enforcement would ultimately happen before fighting the seat question.

For USD 3M with three arbitrators under DIAC 2022 Rules: institutional fees ~USD 55-75k (sliding scale on claim value), arbitrators' fees combined USD 250-400k depending on complexity, expert fees USD 80-150k, counsel fees USD 500k-1.2M for full hearing. Total realistic budget USD 900k-1.7M for a 12-month proceeding. Counsel fees dominate the budget — choose a counsel rate structure (fixed-fee phases or capped hourly) before engagement. Two-thirds of the spend is recoverable in the award if you prevail.

Federal Decree-Law 40 of 2023 on Mediation and Conciliation does not impose mandatory pre-arbitration mediation unless contractually required OR court-referred under the Civil Procedure rules. If your arbitration clause is silent on mediation, you can decline. If the other party files in UAE courts first, the court may refer to mediation under the 2023 law, but you can object on the basis of the arbitration clause. Strategically, a focused 1-2 day mediation often resolves 40-50% of B2B disputes for 1-2% of arbitration cost — worth considering even if not mandatory.