ZRI 2016 (S. 275–303) Nicolas Bremer Abstract It would appear that management liability is regulated very differently among Saudi Arabia on the one hand and Qatar and the United Arab Emirates on the other hand. Unlike the civil and commercial laws of Qatar and the United Arab Emirates, which are strongly influenced by continental European law tradition, Saudi Arabian law is largely based on Islamic law. The resulting differences are, how- ever, not as pronounced in the area of management liability. This is largely due to the fact that cor- porate law in Saudi Arabia is predominantly governed by a comprehensive statute, which was drafted using inter alia the corporate regulations of Qatar, the UAE and Egypt as an example. However, certain particulars still remain. This article will highlight the differences and similarities among the manage- ment liability regulations of the three jurisdictions and introduce the reader to the relevant provisions. 1. Introduction Management liability is a central point of concern for investors. It provides a means of control over persons with wide authority to dispose over the investors’ assets by estab- lishing an accountability regime for manage- rial staff. Furthermore, understanding the relevant management liability regime in the country a manager or director is employed in is relevant to that director or manager as well. A review of the management liability regimes of the three jurisdictions Qatar, Saudi Arabia and the United Arab Emirates is currently of particular interest not only be- cause foreign investment is particularly high in these countries but also because all three passed new corporate laws, which came into force – in Qatar and the United Arab Emir- ates – in late 2015 and – in Saudi Arabia – in early 2016. The principal purpose of management li- ability provisions is to affect management conduct and induce desired behaviour. By virtue of their position and the authorities bestowed on them by law and agreement persons entrusted with the management of a corporation assume far reaching compe- tences with respect to the administration of assets of third parties; those being the share- holders of the relevant corporation and other investors. Consequently, the shareholders will have an interest in the corporation’s management using these competences dili- gently and responsibly. Still, since diligent management of the corporation and the as-