Edilizia nel Golfo e contratti di appalto. Studio comparativo tra codici civili del Golfo, diritto italiano e diritto inglese

This article examines selected developments introduced by the new Civil Transactions Law of the United Arab Emirates and the recent codification of civil law in Saudi Arabia in relation to construction contracts. Drawing on three recurring situations in construction projects—an unexpected increase in costs, defective or delayed performance, and termination by the employer—the authors compare the remedies available under these two legal systems with the approaches taken by Italian and English law. The analysis shows that the reforms make the mechanisms for restoring contractual equilibrium, intervening in performance, and obtaining compensation more explicit, while continuing to subject them to specific substantive and procedural requirements. Greater legislative clarity therefore does not diminish the importance of contractual terms, cost documentation, notices, and the rules governing performance and termination.