Enforcement of Awards

1.1. Key legislation

International arbitration in Australia is governed by the International Arbitration Act 1974 (Cth) (IAA). The Act gives effect to the New York Convention (annexed as an appendix; implemented by section 8), the UNCITRAL Model Law (given effect by section 16) and the ICSID Washington Convention. The federal legislation was originally enacted as the Arbitration (Foreign Awards and Agreements) Act 1974 and was renamed the IAA with effect from 12 June 1989.[1]

1.2. The New York Convention and its scope of application

Australia acceded to the New York Convention on 26 March 1975 without any reservations. Despite the absence of a reciprocity reservation, Article 8 of the IAA provides for the enforcement only of awards made in a State party to the Convention (other than Australia). Awards made in Australia are recognised and enforced under Articles 35 and 36 of the Model Law (or under the state commercial arbitration laws, in the case of domestic awards).[2]

2.1. The Court

Under Article 8(2)–(3) of the IAA, a foreign judgment may be enforced in the Federal Court of Australia or in a state or territory court as if it were a judgment of that court. The choice of court depends on the circumstances of the case. The High Court of Australia has confirmed the Federal Court’s jurisdiction to enforce international judgments and the constitutionality of the tribunal’s powers (TCL Air Conditioner (Zhongshan) Co Ltd v Judges of the Federal Court of Australia [2013] HCA 5).[3]

2.2. Absence of residual discretion

Article 8(3A) of the IAA specifies that the court has no residual discretion to refuse to enforce a foreign judgment on any grounds other than those provided for in Articles 8(5) and 8(7) of the IAA (which essentially reproduce Article V of the New York Convention).[4]

3.1. Required documents

In accordance with Article IV of the New York Convention (and Article 9 of the IAA), the following are attached:[5]

A certified original of the arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A certified translation, if the decision or agreement is not in English.

3.2. Partial and interim judgments

Australian courts will recognise and enforce a partial or interim award only if it definitively resolves a point of law, a claim or a defence in the arbitration.[6]

3.3. Legal costs

The court fee depends on the type of judgment and the court. A foreign judgment is enforced by filing an originating application with the Federal Court of Australia (section 8 of the IAA): the court fee for filing depends on the type of applicant — for individuals, approximately AUD ~1,500; for corporations, AUD ~5,000 and above (Federal Court rates for 2025–2026, subject to verification). A domestic (Australian) award is enforced under the state Commercial Arbitration Acts through the state Supreme Court (section 35 of the Model Act); court fees vary by state. Additionally: costs for certified translations and legal support. Figures are current as of mid-2026 and are subject to verification at the time of filing.[3]

The grounds for recognising foreign judgments are set out in Article 8(5)–(7A) of the IAA and correspond to Article V of the New York Convention; for judgments made in Australia, Article 36 of the Model Law applies.[7]

4.1. Grounds based on the debtor’s application (Article 8(5) / Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article 8(7) / Article V(2))

Non-arbitrability of the dispute;

Contrary to public policy. Section 8(7A) specifies that enforcement is contrary to public policy if the judgment was obtained by fraud or corruption, or in breach of the rules of natural justice. This is interpreted narrowly (TCL Air Conditioner v Judges of the Federal Court [2013] HCA 5).

If an application has been made in the issuing State to stay or set aside the judgment, an Australian court may, at its discretion, stay the enforcement proceedings (section 36(2) of the Model Law, section 8(8) of the IAA; ESCO Corporation v Bradken Resources Pty Ltd). In cases involving states, the Foreign States Immunity Act 1985 applies: The High Court rejected a reliance on sovereign immunity in relation to the recognition and enforcement of ICSID awards (Kingdom of Spain v Infrastructure Services Luxembourg Sàrl).[8]

Once a court order enforcing the judgment has been issued, enforcement is carried out by the usual means (writ of execution): the seizure and sale of property, and the attachment of the debtor’s bank accounts and assets.[9]

6.1. Tracing the debtor’s assets

Useful resources:

ASIC Companies Register: asic.gov.au;

Personal Property Security Register (PPSR): www.ppsr.gov.au;

State land registers (e.g. NSW LRS, Landgate WA).

6.2. Practical advantages and obstacles

There is no residual discretion: a refusal is possible only on the grounds set out in Article 8(5), (7) and (7A);[4]

Convention countries only: Article 8 of the IAA enforces decisions from States Parties to the Convention;[2]

State immunity: bear in mind the Foreign State Immunities Act 1985 and its exceptions.

7.1. Legislation and official sources

Federal Register of Legislation — IAA 1974: www.legislation.gov.au

New York Convention (Australia): newyorkconvention.org

7.2. Registers

ASIC Companies Register: asic.gov.au

PPSR: www.ppsr.gov.au

7.3. Arbitration institutions

Australian Centre for International Commercial Arbitration (ACICA): acica.org.au

7.4. Specialists in the enforcement of arbitral awards in Australia

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] International Arbitration Act 1974 (Cth) (IAA), sections 8, 9 and 16; formerly the Arbitration (Foreign Awards and Agreements) Act 1974 (renamed on 12 June 1989). legislation.gov.au

[2] The 1958 New York Convention (Australia — acceded on 26 March 1975, without reservations); Article 8 of the IAA (judgements from countries that are parties to the Convention); Model Law, Articles 35/36.

[4] IAA, section 8(3A) — absence of residual discretion (ACICA — International Arbitration Act 1974).

[5] Article IV of the New York Convention; IAA, Article 9 (documents; translation).

[7] IAA, Article 8(5)–(7A) (= Article V of the Convention); Article 36 of the Model Law.

Case law

[3] TCL Air Conditioner (Zhongshan) Co Ltd v Judges of the Federal Court of Australia [2013] HCA 5 (jurisdiction of the Federal Court; constitutionality).

[8] ESCO Corporation v Bradken Resources Pty Ltd (2011) 282 ALR 282 (stay of proceedings); Kingdom of Spain v Infrastructure Services Luxembourg Sàrl (immunity; ICSID); Foreign State Immunities Act 1985 (Cth).

Analytical and reference materials

[6] Global Arbitration Review — Australia (partial/interim awards; final determination of the claim).

[9] CMS Expert Guides — Australia; Align Law — Enforcing Arbitration Awards in Australia (Article 8(7A); writ of execution; narrow interpretation of public policy).

1.1. Key legislation

Austrian arbitration law is set out in §§ 577–618 of the Code of Civil Procedure (Zivilprozessordnung, ZPO). The law does not distinguish between domestic and international arbitration. The most recent significant change dates from 2013, when the Supreme Court (Oberster Gerichtshof, OGH) became the sole court with jurisdiction over actions for annulment (§ 615 ZPO).[1]

Enforcement proceedings are governed by the Enforcement Act (Exekutionsordnung, EO), section 403 et seq. Foreign awards are those where the place of arbitration is outside Austria. International treaties and EU law take precedence over the provisions of the EO (Section 614 of the Code of Civil Procedure (ZPO)).[2]

1.2. The New York Convention

Austria has been a party to the 1958 New York Convention since 31 July 1961. The original reservation regarding reciprocity was withdrawn in 1988; consequently, Austria enforces judgments from states that are not parties to the Convention.[3]

1.3. Other international treaties

The 1923 Geneva Protocol and the 1927 Geneva Convention;

The 1961 European Convention on Foreign Trade Arbitration (Article IX — limits the grounds for refusing to recognise set-aside awards);

The 1966 Washington Convention on ICSID and bilateral investment treaties.[4]

2.1. Automatic recognition

A distinctive feature of Austria is that no specific procedure for recognition is provided for — foreign arbitral awards are recognised automatically, without the need for a separate application. The grounds for refusal under Article V of the Convention are examined only if the opposing party raises an objection.[5] For enforcement, however, a declaration of enforceability (Vollstreckbarerklärung) must be obtained.

2.2. The Court

The application must be lodged with the District Court (Bezirksgericht) at the debtor’s place of business (registered office), domicile or habitual residence, or at the place where the enforcement measure is to be carried out (§ 409 EO).[6]

2.3. Nature of the proceedings: ex parte

Proceedings for a declaration of enforceability are conducted ex parte: these are unilateral documentary proceedings without an oral hearing and without the debtor being heard (§§ 54 and 410 EO). In practice, creditors combine the application for a declaration of enforceability with the application for the enforcement measure itself (§ 412(1) EO).[7]

2.4. Appeals

The debtor is entitled to appeal against the assessment once it has been issued:[8]

An appeal must be lodged with the competent Regional Court (Landesgericht) as the court of second instance, in accordance with the adversarial procedure, within 4 weeks (for a party based abroad, if this is the first opportunity to participate, the time limit is doubled to 8 weeks);

An appeal on points of law — to the Supreme Court (OGH) — may be lodged only on points of law of fundamental importance.

Until a final decision has been made on the appeal, no steps may be taken to realise the debtor’s assets; however, interim measures (such as attachment) are permissible (§ 412(2) EO). Decisions on appeals are usually made within 6–12 months.[8]

3.1. Required documents

The application must be accompanied by either ‘the duly authenticated original of the award’ or ‘a duly certified copy’ (§ 406 EO). By way of derogation from Article IV(1)(b) of the Convention, Austrian law expressly states that it is sufficient to submit only the award; it is not necessary to attach the arbitration agreement.[9]

According to the case law of the Supreme Court, the requirement for a ‘certified copy’ is deemed to have been met if the authenticity has been confirmed by an Austrian authority or by an authorised representative of the administering arbitral institution (OGH 3 Ob 65/11x, 3 Ob 208/15g; for example, Article 36(4) of the Vienna Rules). In the absence of a bilateral treaty, a certificate issued abroad requires an apostille or superlegalisation.[10]

Translation: if the court so requires, a full translation of the arbitration agreement must be provided; a translation of the entire contract containing the arbitration clause is not required.[11]

3.2. Legal costs

No separate court fee is payable for an application for a declaration of recognition and enforceability (Vollstreckbarerklärung) of a foreign judgment. A court fee is charged for the application for enforcement (Exekutionsantrag) itself — in accordance with the general rules for the enforcement of court decisions (Court Fees Act, GGG/GEG): the rate depends on the amount to be recovered (subject to verification). For a domestic (Austrian) judgment, no separate declaration of enforceability is required – it is enforced under the same rules as the EO; the difference from a foreign judgment lies solely in the need for a declaration of enforceability, not in the amount of the fee. In addition, there are costs for translation and apostille/legalisation, as well as lawyers’ fees. The amounts are subject to verification at the time of submission.[12]

3.3. Deadlines

Provided all the necessary documents are submitted, a decision at first instance is reached fairly quickly — usually within 2–4 weeks.[6]

3.4. Limitation period

Austrian law does not specify a particular time limit for applying for the recognition and enforcement of a foreign judgment. A cautious approach would be to apply, by analogy, the 30-year limitation period applicable to the enforcement of court judgments, calculated from the date of the judgment. The limitation period for the obligation itself is determined by the law applicable to that obligation (position of the OGH).[13]

In practice, the grounds set out in Article V of the New York Convention are the most important. Furthermore, § 408 of the EO lists the following: (i) the debtor’s inability to participate in the arbitration; (ii) the performance of an act that is unlawful or unenforceable under Austrian law; (iii) a violation of Austrian public policy.[14]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds examined by the court of its own motion (Article V(2))

Non-arbitrability of a dispute under Austrian law;

Breach of substantive public policy (ordre public).

The Supreme Court interprets public policy restrictively, taking into account only the fundamental principles of Austrian law.[15]

4.3. Special case: a decision set aside abroad

As a general rule, Austrian courts do not enforce an award that has been set aside by a court in the country where the award was made. However, if the award was set aside on the grounds that it was contrary to the public policy of the place of arbitration, the Austrian court will assess whether the award violates Austrian public policy: if not, enforcement is likely to be permitted.[16] For States party to the 1961 European Convention, Article IX(2) limits the grounds for refusal of set-aside awards solely to those set out in Article V(1)(a)–(d) of the Convention (i.e. setting aside on grounds of public policy at the seat of arbitration does not preclude enforcement).[16]

Once a declaration of enforceability has been obtained, the judgment is enforced in the same way as a domestic court judgment, through the court with jurisdiction over the debtor’s place of residence or the location of their assets. Pending a final decision on the debtor’s appeal, precautionary (protective) measures may be taken — such as the seizure of property — whilst the realisation of assets is suspended (§ 412(2) EO).[8]

Austrian courts are entitled to enforce interim measures ordered by arbitrators, including those not recognised under Austrian law: the court may reformulate the measure in order to preserve its purpose (§ 593(3) ZPO).[17]

6.1. Certification and translation of documents

A key practical consideration is the proper certification of the decision (apostille or legalisation where there is no bilateral treaty) and confirmation of its authenticity; any shortcomings at this stage lead to delays.

6.2. Tracing the debtor’s assets

Useful resources:

Commercial Register (Firmenbuch): justizonline.gv.at;

Land Register (Grundbuch) — via the same portal;

Ediktsdatei register (notices, insolvency): edikte.justiz.gv.at.

6.3. Practical advantages and obstacles

Speed and the absence of a declaration fee are significant advantages; a decision can be reached within 2–4 weeks;

Certificate/apostille: the requirement for superlegalisation of a foreign certificate is a common reason for refusal;[10]

The doubling of the appeal period for foreign debtors — this should be taken into account when planning.

7.1. Legislation and official sources

RIS — ZPO (Code of Civil Procedure) and EO (Enforcement Act): ris.bka.gv.at

New York Convention (Austria): newyorkconvention.org

7.2. Registers

Firmenbuch Commercial Register: justizonline.gv.at

Edict file: edikte.justiz.gv.at

7.3. Arbitration institutions

Vienna International Arbitration Centre (VIAC): www.viac.eu

7.4. Specialists in the enforcement of arbitral awards in Austria

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Austrian Code of Civil Procedure (Zivilprozessordnung, ZPO), §§ 577–618 (in particular § 593(3), § 614, § 615). RIS: ris.bka.gv.at

[2] Enforcement Act (Exekutionsordnung, EO), Sections 403, 406, 408, 409, 410, 411, 412.

[3] The 1958 New York Convention (Austria — from 31 July 1961; the reservation on reciprocity was withdrawn in 1988), Articles IV and V.

[4] The 1923 Geneva Protocol; the 1927 Geneva Convention; the 1961 European Convention (Article IX); the 1966 ICSID Washington Convention.

Case law

[10] OGH 3 Ob 65/11x; OGH 3 Ob 208/15g — requirements for the certification of a copy of a judgment.

[16] Lexology / ICC Country Answers: Austria — approach to judgments set aside abroad; Article IX of the 1961 European Convention

Analytical and reference materials

[5] Pitkowitz & Partners — Recognition and Enforcement of Foreign Arbitral Awards in Austria (automatic recognition; § 408 EO).

[6] Chambers — Enforcement of Judgments 2025, Austria (§ 406, 409 EO; timeframes of 2–4 weeks).

[7] Global Arbitration Review — Challenging and Enforcing Arbitration Awards: Austria (KNOETZL) — ex parte, § 412 EO.

[8] Pitkowitz / Legal500 — Austria (appeal/further appeal; § 412(2) EO; doubling of the time limit; time limits of 6–12 months).

[9] Chambers — Austria (§ 406 EO; derogation from Article IV(1)(b) of the Convention — no agreement required).

[11] Jus Mundi — Austria country publication (translation of an arbitration agreement at the court’s request).

[12] Chambers — Austria (no fee for a declaration of recognition and enforceability).

[13] Jus Mundi — Austria (a 30-year limitation period by analogy; the OGH’s position on the law of obligations).

[14] Pitkowitz — § 408 EO (grounds for refusal); Art. V NYC.

[15] Global Arbitration Review — Austria (the OGH’s restrictive interpretation of public policy).

[17] The Arbitrators — Commercial Arbitration: Austria (§ 593(3) ZPO, interim measures by arbitrators).

1.1. Key legislation

Belgian arbitration law is set out in Part VI of the Judicial Code (Code judiciaire / Gerechtelijk Wetboek; referred to in English-language sources as the Belgian Judicial Code, BJC), Articles 1676–1722. The current version was introduced by the Arbitration Act of 24 June 2013 (in force since 1 September 2013) and amended by the Acts of 25 December 2016 and 28 March 2024.[1] The Act is largely based on the UNCITRAL Model Law and applies to both domestic and international arbitration. Recognition and enforcement are governed by Chapter VIII (Articles 1719–1721 of the BJC).[2]

1.2. The New York Convention and the primacy of treaties

Belgium signed the 1958 New York Convention and ratified it in 1975, declaring that it would apply on a reciprocal basis.[3] Under Article 1721(3) of the Belgian Civil Code (BJC), an international treaty between Belgium and the country in which the judgment was given takes precedence over domestic law; this provision is to be read in conjunction with the Convention’s rule on the application of the more favourable law (Article VII).[1]

1.3. Other international treaties

The 1961 European Convention on Foreign Trade Arbitration;

The 1965 Washington Convention on ICSID;

Bilateral treaties (with Austria, France, Germany, the Netherlands and Switzerland).[4]

2.1. The Court

An application for recognition and enforcement is lodged with the Court of First Instance (tribunal de première instance / rechtbank van eerste aanleg). The applicant is required to elect domicile within the jurisdiction of the competent court (Article 1720(1)(1) of the Civil Code); foreign applicants usually elect the address of their solicitor’s office.[5]

If the debtor has no domicile, place of residence, registered office, place of business or branch in Belgium, the application must be lodged with the court of first instance in the court of appeal district where enforcement is sought (for example, where the assets are located).[6]

2.2. Nature of the proceedings: ex parte

An exequatur is sought by means of an ex parte application: the party against whom enforcement is sought is not invited to raise objections at this stage.[7] In this context, the court of first instance examines the application and is entitled to summon both the applicant and the debtor to the deliberation room. The debtor may lodge an objection (a third objection) against the exequatur order within one month of being notified of it.[8]

2.3. The position of the Belgian courts

The Belgian courts are favourable towards arbitration. However, recent case law in high-profile investment cases reveals a strict approach: in the case of Stati v Kazakhstan (Brussels Court of Appeal, 16 November 2021), enforcement was refused on the grounds of fraud; in the case of Diag Human v Czech Republic (Court of Cassation, February 2022), the order was set aside because the award had not become binding within the meaning of Article V(1)(e) of the Convention. The court of enforcement is not bound by a foreign decision refusing to set aside the judgment, but takes it into account as a legal fact.[9]

3.1. Required documents

In accordance with Article 1720(4) of the BJC, the following is attached:[10]

The original arbitration award or a duly certified copy thereof;

A certified (sworn) translation of the judgment into the language of the proceedings (French, Dutch or German, depending on the district), if the judgment is drafted in another language;[11]

The application must be submitted in triplicate and signed by a lawyer authorised to practise before the Belgian courts.

Important note: as of January 2017, it is NO LONGER necessary to submit the original or a copy of the arbitration agreement (in accordance with Article 35 of the UNCITRAL Model Law and Article 1681 of the BJC). The court shall stay the proceedings until a written award signed by the arbitrators has been submitted (Article 1721(2) of the BJC).[12]

3.2. Legal costs

The costs of obtaining an exequatur include fixed fees:[13]

3.3. Time limits for appeals and overlapping time limits

The time limit for challenging (setting aside) a decision is three months from the date of its notification, and for challenging an exequatur order, one month from the date of service. Article 1717(7) of the BJC provides for the extension of these time limits.[14]

Under Article 1721(1) of the BJC, the court of first instance shall refuse to recognise and declare a judgment enforceable only in the cases exhaustively listed therein, which are essentially mirror images of Article V of the New York Convention.[15]

4.1. Grounds based on the debtor’s application

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision has not become binding or has been set aside or suspended by a court in the country where it was made (Article 1721(1)(a)(vi)).

4.2. Grounds subject to judicial review

Non-arbitrability of a dispute under Belgian law;

Contrary to public order.

4.3. Special case: a decision set aside abroad

The setting aside of an award at the seat of arbitration constitutes grounds for refusal (Article 1721 §1(a)(vi) of the BJC; Article V(1)(e) of the Convention). A number of authoritative authors consider that the court of enforcement retains discretion under Article V of the Convention.[16] With the entry into force of the Act of 28 March 2024, Belgian law expressly provides that: a previously issued order of exequatur ceases to have effect if (or to the extent that) the award is subsequently set aside (Article 1720 §7 BJC). However, it remains a matter of debate whether the foreign decision on setting aside itself meets the conditions for its recognition in Belgium.[16]

Proceedings to set aside a judgment do not automatically suspend its enforcement. When deciding whether to grant a stay, the court hearing the application for enforcement takes into account the likelihood of success of the proceedings to set aside the judgment, as well as the ease or difficulty of enforcing the judgment. The judge responsible for attachments (juge des saisies) is entitled to suspend enforcement.[17]

Once an enforcement order has been obtained, enforcement measures may be carried out by a bailiff (huissier de justice / gerechtsdeurwaarder):

Seizure of movable property and bank accounts;

Foreclosure on property;

Attachment of accounts receivable. Enforcement against state assets (including those of foreign states) is restricted.[6]

6.1. Representation and language

The application must be signed by a Belgian lawyer. The language of the proceedings (French, Dutch or German) depends on the district; the translation of the judgment must be in the language of the chosen court.

6.2. Tracing the debtor’s assets

Useful resources:

Business Centre for Enterprises (BCE/KBO): kbopub.economie.fgov.be;

The Register of Legal Entities and publications in the ‘Belgian Gazette’: www.ejustice.just.fgov.be;

The Central Register of Arrests — via a bailiff.

6.3. Practical advantages and obstacles

Low fixed fees (€165 + €24) and the fact that there is no requirement to submit an arbitration agreement make the application process simpler;

Translation: the certified translation of the entire decision is the main item of expenditure;

Overturned/fraudulent judgements: Belgian courts are prepared to conduct a de novo review (Stati) and take the fact of the overturning into account.

7.1. Legislation and official sources

Justel — Code of Civil Procedure (Code judiciaire): ejustice.just.fgov.be

The New York Convention (Belgium): newyorkconvention.org

7.2. Registers

Business Centre for Enterprises (BCE/KBO): kbopub.economie.fgov.be

Belgian Official Gazette (Moniteur belge): www.ejustice.just.fgov.be

7.3. Arbitration institutions

CEPANI (Belgian Centre for Arbitration and Mediation): www.cepani.be

7.4. Specialists in the enforcement of arbitral awards in Belgium

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Belgian Judicial Code (Code judiciaire / Gerechtelijk Wetboek), Part VI, Articles 1676–1722, in particular Articles 1719–1721 (§3). Justel: ejustice.just.fgov.be

[2] The Arbitration Act of 24 June 2013 (in force since 1 September 2013); the Act of 25 December 2016; the Act of 28 March 2024.

[3] The 1958 New York Convention (Belgium — ratified in 1975, with a reservation regarding reciprocity), Articles V and VII.

[4] The 1961 European Convention; the 1965 ICSID Washington Convention; bilateral treaties (Austria, France, Germany, the Netherlands, Switzerland).

Case law

[9] Brussels Court of Appeal, 16 November 2021 (Stati v Kazakhstan) — dismissed on grounds of fraud; Court of Cassation, February 2022 (Diag Human v Czech Republic) — Article V(1)(e).

[16] Court of Cassation, 8 November 2024, C.20.0415.N (dismissal of the appeal); interpretation of Article 1720(7) of the Civil Code following the Act of 28 March 2024.

Analytical and reference materials

[5] Global Arbitration Review — The Guide to Challenging and Enforcing Arbitration Awards, 4th ed., Belgium (Loyens & Loeff).

[6] Delos — Guide to Arbitration Places (GAP), Belgium (Fieldfisher) — jurisdiction based on the location of the assets; restrictions on state-owned assets.

[7] Jus Mundi — Belgium country publication (ex parte proceedings, Article 1720 of the BJC).

[8] Jus Mundi / Keutgen & Dal — the debtor’s objection within one month (Article 1028 of the BJC).

[10] Lexology — In brief: arbitration formalities in Belgium (2023) — documents (Article 1720(4)).

[11] Arthur Marin — Exequatur in Belgium (2025) — sworn translation into FR/NL/DE.

[12] Global Arbitration Review — Belgium (abolition of the requirement for an arbitration agreement from 2017; Article 1721(2)).

[13] Global Arbitration Review — Belgium (fees: €165 + €24; translation as the main expense).

[14] Delos GAP, Belgium — coincidence of time limits (Article 1717(7) of the BJC).

[15] Kluwer Arbitration Blog — Belgium Adopts a New Law on Arbitration (text of Article 1721(1)).

[17] Lexology — A general introduction to international arbitration in Belgium (2023); suspension of enforcement.

1.1. Key legislation

The recognition and enforcement of foreign arbitral awards in Brazil are governed by the Arbitration Act No. 9,307 of 23 September 1996 (Articles 34–40), the New York Convention, the Code of Civil Procedure (Articles 963–964) and the Internal Regulations of the Supreme Court of Justice (Articles 216-A–216-N). A judgment rendered outside Brazil is regarded as a foreign judgment.[1]

Article 34 of the Act provides for the recognition and enforcement of foreign judgments in accordance with international treaties (the New York Convention), whilst Article 37 sets out the initial steps: the submission of an application to the STJ.[2]

1.2. ‘Simple recognition’ instead of double exequatur

Prior to the 1996 Act, ‘double recognition’ was required (first in the country where the judgment was given, then in Brazil). Following the enactment of the 1996 Act and the ratification of the New York Convention in 2002, ‘simple recognition’ in Brazil is sufficient.[3]

2.1. Supreme Court of Justice (STJ)

Following Constitutional Amendment No. 45 of 2004, the Supreme Court of Justice (Superior Tribunal de Justiça, STJ) — Brazil’s highest court for constitutional matters. Recognition is carried out through the homologação procedure.[4]

2.2. Review without substantive review

The STJ confines itself to verifying compliance with formal requirements and does not analyse the substance of the dispute. Following homologação, the enforcement of a foreign arbitral award takes place exclusively in the federal courts. In practice, the STJ grants the vast majority of applications.[5]

3.1. Required documents

An application is lodged with the STJ, accompanied by an annex (Article 37 of the Act and Article IV of the Convention):[6]

The original arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

An official (sworn) translation of each document into Portuguese. If the decision was issued in a state that is a party to the Hague Convention on Apostilles, certification is carried out by means of an apostille (otherwise, legalisation at a Brazilian consulate is required).

3.2. Legal costs

The court fee depends on the type of judgment. A foreign award undergoes recognition (homologação) at the Superior Court of Justice (STJ): STJ court fees (custas) are payable, after which enforcement takes place in the federal courts, which have their own fees (rates are subject to verification). A domestic (issued in Brazil) arbitral award does not require recognition — it constitutes a judicial enforcement order (título executivo judicial) and is enforced directly in the state courts. Additionally: costs for sworn translation into Portuguese, apostille/legalisation and legal support. The amounts are current as of mid-2026 and are subject to verification at the time of submission.[5]

The grounds are set out in Articles 38–39 of the Arbitration Act and are consistent with Article V of the New York Convention.[7]

4.1. Grounds based on the debtor’s application (Article 38 / Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to review by the court (Article 39 / Article V(2))

Non-arbitrability of a dispute under Brazilian law;

Contrary to national public policy.

Notification of the arbitration to the Brazilian party in the manner provided for in the agreement or by the procedural law of the place of arbitration (including by post with proof of delivery) shall not be regarded as a breach of public policy, provided that the party is given sufficient time to defend itself.[8]

Following homologation by the STJ, enforcement is carried out in the federal courts in accordance with the rules of the Code of Civil Procedure: seizure and sale of property, and attachment of the debtor’s bank accounts and assets. It should be noted that interim measures to support enforcement are granted on a limited basis until the recognition process is complete.[9]

6.1. Tracing the debtor’s assets

Useful resources:

Commercial Registers (Juntas Comerciais) and REDESIM: www.gov.br/empresas-e-negocios;

Land Registry (Cartórios de Registro de Imóveis);

Judicial enforcement systems (SisbaJud, RenaJud) — through the courts.

6.2. Practical advantages and obstacles

A two-stage process: first, homologação at the STJ, then enforcement in a federal court;[5]

Certified translation and apostille: prepare in advance — allow for the time and costs involved;[6]

High approval rate: STJ grants the majority of applications.

7.1. Legislation and official sources

Planalto — Law No. 9.307/1996: www.planalto.gov.br

New York Convention (Brazil): newyorkconvention.org

7.2. Registers

Register of Enterprises (REDESIM): www.gov.br/empresas-e-negocios

Supreme Court of Justice (STJ): www.stj.jus.br

7.3. Arbitration institutions

Arbitration Centre of the Brazil-Canada Chamber of Commerce (CAM-CCBC): www.ccbc.org.br

7.4. Specialists in the enforcement of arbitral awards in Brazil

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] Brazilian Arbitration Act No. 9,307 of 23 September 1996, Articles 34–40; Code of Civil Procedure, Articles 963–964; Internal Regulations of the STJ, Articles 216-A–216-N. planalto.gov.br

[2] Law No. 9.307/1996, Article 34 (recognition under international treaties), Article 37 (filing with the STJ).

[3] The 1958 New York Convention (Brazil – ratified in 2002); ‘simple recognition’ instead of double exequatur.

[4] Constitutional Amendment No. 45/2004 — conferring on the STJ the power to recognise foreign judgments; Article 105 of the Federal Constitution.

[7] Law No. 9.307/1996, Articles 38–39 (= Article V of the Convention).

[8] Law No. 9.307/1996, Article 39, sole paragraph (notification and public order).

Analytical and reference materials

[5] Lexology — First-step analysis: Brazil; Chambers — International Arbitration 2025, Brazil; Global Arbitration Review — Guide to Arbitration in Latin America: Brazil (recognition and enforcement; federal courts; high recognition rate).

[6] Kluwer Arbitration Blog — Legal Background to Arbitration and the Enforcement of Foreign Arbitral Awards in Brazil (Article 37; documents; apostille).

[9] Nadia de Araujo — International Judicial Cooperation in Brazil (Comverse Inc v American Telecommunications — the limitations on interim measures prior to recognition).

1.1. Key legislation

Domestic and international arbitration are governed by the Law on International Commercial Arbitration (ZMKA), which is based on the 1985 UNCITRAL Model Law. A major reform (LASICAA) came into force on 1 August 2025; the law was renamed the ‘Arbitration Act’. The recognition and enforcement of foreign awards are governed by the Code of Private International Law (PILC, Articles 117–122) and the New York Convention; issues of arbitrability and court proceedings are governed by the Code of Civil Procedure (CCP).[1]

1.2. The New York Convention

The 1958 New York Convention has been in force in Bulgaria since 1965. A reservation regarding reciprocity has been made: the Convention applies to judgments rendered in another Contracting State, and to judgments from non-Contracting States only to the extent of reciprocity.[2]

1.3. The 2025 Reform: The Register of Arbitration Proceedings

The reform of 1 August 2025 established the Register of Arbitration Institutions under the Ministry of Justice. Arbitration institutions with their seat in Bulgaria and arbitration proceedings where the seat of arbitration is in Bulgaria are subject to registration; an award made by an unregistered arbitral tribunal is deemed null and void. These requirements apply primarily to arbitrations with a seat in Bulgaria and are important when choosing Bulgaria as the seat of arbitration.[3]

1.4. Other international treaties

The 1961 European Convention (relevant to set-aside decisions);

The Washington Convention, ICSID and bilateral treaties.[4]

2.1. The Court

Unless otherwise provided for in an international treaty, an application for the recognition and enforcement of a foreign judgment must be lodged with the Sofia City Court (SCC) — the sole court with jurisdiction over foreign judgments. Articles 118–122 of the Code of Private International Law apply.[5]

2.2. Nature of the procedure

Unlike the enforcement of domestic judgments (ex parte), proceedings relating to foreign judgments are adversarial: the court verifies that the application has been served on the debtor and that the debtor has been notified of the proceedings, that there is no final Bulgarian judgment on the same dispute between the same parties, and that there are no parallel proceedings on the same dispute (Article 117 of the PILC). This verification is of a formal nature and does not address the substance of the dispute.[6]

2.3. Appeals

The decision of the Sofia City Court on recognition may be appealed to the Sofia Court of Appeal and subsequently to the Supreme Court of Cassation (SCC).[7]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are annexed:[8]

A certified original of the arbitration award or a certified copy thereof (in full);

The original arbitration agreement or a certified copy thereof (if the clause is contained in the contract, the entire contract must be submitted);

Translation into Bulgarian, if required.

The 2025 reform (Article 51(4) of the Act) removed the excessive formal requirements previously imposed by practice (notarisation of arbitrators’ signatures, apostille/legalisation of such notarisation): national legislation may not impose stricter requirements than those laid down in the Convention.[9]

3.2. Legal costs and time limits

The state fee for the recognition of a foreign judgment is 0.4 per cent of the amount awarded (adversarial proceedings before the Sofia City Court). A domestic (Bulgarian) judgment is enforced ex parte — by the district court issuing a writ of execution, subject to a separate (usually lower) court fee (subject to verification). The recognition procedure usually takes no more than 2–3 weeks; in the absence of an appeal, the enforcement order is issued within a further 3–4 weeks.[10]

The provisions of Article V of the New York Convention apply; Bulgarian courts interpret them strictly and very rarely refuse enforcement.[11]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to review by the court (Article V(2))

Non-arbitrability of a dispute under Bulgarian law;

Contrary to public policy in Bulgaria.

4.3. A decision set aside abroad

A judgment set aside by the court of the issuing State is not enforceable in Bulgaria (Article V(1)(e)); the Hilmarton/Chromalloy scenarios do not apply in Bulgaria. An exception may apply in circumstances where the 1961 European Convention applies.[12]

The filing of an application for annulment (in respect of awards where the place of arbitration is Bulgaria) does not automatically stay enforcement. The Supreme Court of Cassation may suspend enforcement upon application and subject to the provision of security (usually by transferring the amount of the award to a special court account). Once the decision recognising the award has entered into force, the Sofia City Court issues a writ of execution at the request of the claimant.[13]

Under a specific provision of the Code of Civil Procedure, monetary claims against state bodies may not be enforced — such claims are settled from budgetary funds.[11]

6.1. Tracing the debtor’s assets

Useful resources:

Commercial Register (Търговски регистър): portal.registryagency.bg;

Property Register (Imoten register) — via the Registry Agency;

Chamber of Private Bailiffs (KCHSI): www.bcpea.org.

6.2. Practical advantages and obstacles

A quick process (2–3 weeks) and a low fee (0.4 per cent);

Adversarial nature: the debtor takes part in the recognition proceedings;

State assets: enforcement proceedings against state bodies are not permitted.

7.1. Legislation and official sources

lex.bg — Arbitration Act (ZMKA): lex.bg

The New York Convention (Bulgaria): newyorkconvention.org

7.2. Registers

Commercial Register: portal.registryagency.bg

Chamber of Enforcement Officers of the KCHSI: www.bcpea.org

7.3. Arbitration institutions

Arbitration Court at the Bulgarian Chamber of Commerce and Industry (BCCI): www.bcci.bg

7.4. Specialists in the enforcement of arbitral awards in Bulgaria

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Bulgarian International Commercial Arbitration Act (ZMKA); the LASICAA reform (in force from 1 August 2025; new title: ‘The Arbitration Act’); Code of Private International Law (PILC), Articles 117–122; Code of Civil Procedure. lex.bg

[2] The 1958 New York Convention (Bulgaria — since 1965, with a reservation regarding reciprocity), Articles IV and V.

[3] Kinstellar — Bulgaria’s Arbitration Reform (2025); DGKV — LASICAA Overview (Register of Arbitration Tribunals; nullity of awards made by unregistered arbitration tribunals).

[4] The 1961 European Convention; the ICSID Washington Convention; bilateral treaties.

Case law

[12] Bulgarian practice under Article V(1)(e) (refusal to enforce set-aside awards; inapplicability of Hilmarton v Chromalloy).

Analytical and reference materials

[5] IBA — Bulgaria enacts substantial amendments to the ICAA (2025/2026): Article 51(4) of the AA; Sofia City Court.

[6] Jus Mundi — Bulgaria country publication (Article 117 of the PILC; adversarial review).

[7]

[8] ICC Country Answers / Jus Mundi — Bulgaria (Article IV of the Convention; full texts of the documents).

[9] IBA — Bulgaria (removal of excessive formal requirements; Article 51(4) of the AA).

[10] WAGNER Arbitration — Bulgaria (fee: 0.4%; duration: 2–3 weeks + 3–4 weeks).

[11] Global Arbitration Review — Commercial Arbitration: Bulgaria (Kinstellar); CMS Expert Guides — Bulgaria; state assets.

[13] CMS Expert Guides — Bulgaria; IBA Arbitration Guide: Bulgaria (stay of enforcement; interim relief).

Canada is a federation with shared jurisdiction; the procedure depends on the province or territory in which enforcement takes place. The general provisions and examples (Ontario, Quebec) are set out below.

1.1. Key legislation

As jurisdiction in the field of international commercial arbitration is shared between the federal government and the provinces, the implementation of the New York Convention required legislation at each level. Federal level: the United Nations Foreign Arbitral Awards Convention Act. Parliament (including the Yukon, the Northwest Territories and Nunavut) and all 10 provinces have enacted legislation implementing the Convention.[1]

The provinces are implementing the UNCITRAL Model Law through their International Commercial Arbitration Acts (ICAA). Ontario was the first to adopt a new ICAA in March 2017 (based on the ULCC Model Act, with a 10-year time limit for bringing proceedings for recognition or enforcement); British Columbia amended its legislation in May 2018; Prince Edward Island will do so in 2023.[2]

1.2. The New York Convention

The Convention entered into force for Canada on 10 August 1986. The reservation regarding the commercial nature of disputes, as permitted by the Convention, has been accepted by Parliament and all provinces except Quebec. Under federal law, the Convention applies only to disputes arising out of commercial legal relationships (Article 4(1)).[3]

2.1. The Court

Under federal law, an application for recognition and enforcement may be lodged with any Supreme Court, District Court or County Court (section 6). At the provincial level, jurisdiction generally lies with the provincial Superior Court. In Ontario, this is the Superior Court of Justice (Commercial List) — a specialised commercial court.[4]

2.2. Characteristics of Quebec

In Quebec, the Court of Quebec has exclusive jurisdiction over the recognition and enforcement of foreign awards where the value of the dispute referred to arbitration is less than 75,000 Canadian dollars; in all other cases, jurisdiction lies with the Superior Court. Recognition takes the form of homologation; the grounds for setting aside and for refusing homologation are the same (section 648 of the Quebec Code of Civil Procedure).[5]

2.3. Appeals and suspension

International decisions are generally not subject to appeal on the merits. Under the Model Law (Article 36), the grounds for refusal are of a permissive nature: in Ontario, a decision may be recognised regardless of whether revocation proceedings are pending; therefore, revocation does not necessarily entail a stay of proceedings. In Quebec, annulment proceedings do not have a suspensive effect; however, the court may, upon application, suspend recognition until the proceedings are concluded.[6]

3.1. Required documents

In accordance with the Model Law and Article IV of the New York Convention, the following are attached:[7]

The original arbitration agreement or a certified copy thereof;

A certified copy of the arbitral award; the award must state the grounds, unless the parties have agreed otherwise;

A certified translation, if the documents are not in English or French.

3.2. Limitation period

In Ontario, the time limit is 10 years from the date the judgment was obtained (or from the date the set-aside proceedings were concluded). In Quebec, an application for recognition and enforcement must be filed within 10 years of the date of the final judgment (Article of the Code of Civil Procedure; Itani v Société générale). Court costs depend on the province of enforcement: a foreign judgment is enforced by filing an application with the province’s Supreme Court (in Quebec — the Court of Quebec where the value of the claim is less than CAD 75,000, otherwise the Superior Court; homologation), and court fees are set by the relevant province’s schedule of fees (subject to verification). A domestic (rendered in Canada) arbitral award is enforced under the provincial law on domestic arbitration through the same Superior Court; the difference from a foreign award lies in the applicable law, not in the amount of the court fee. Additionally: costs for a certified translation and legal support. Amounts are subject to verification at the time of filing.[8]

The grounds are in accordance with Article V of the New York Convention and Article 36 of the Model Law; they are interpreted narrowly. In some provinces, domestic legislation does not provide an exhaustive list of grounds for refusal, leaving a wider margin of discretion.[9]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article V(2))

The dispute is not subject to arbitration under provincial law;

Contrary to public order.

Once recognised, the award is generally enforced in the same way as a court judgement (except in cases where the subject matter is not arbitrable, where an ‘unusual’ remedy is sought, or in family arbitration). Enforcement is carried out in accordance with provincial rules: seizure and sale of property, and attachment of the debtor’s accounts and assets.[10]

6.1. Tracing the debtor’s assets

Useful resources:

Federal Register of Companies (Corporations Canada): ised-isde.canada.ca;

Provincial registers (e.g. the Ontario Business Registry, the Registraire des entreprises du Québec);

PPSA / RDPRM registers — security interests (provincial).

6.2. Practical advantages and obstacles

Selection of province: the rules depend on the place of performance (Ontario, Quebec, BC, etc.);[2]

Quebec — no commercial restrictions: a broader scope of recognised solutions;[3]

A 10-year term: one of the longest among the key jurisdictions.

7.1. Legislation and official sources

Justice Laws — UN Convention on the Recognition and Enforcement of Foreign Arbitral Awards Act: laws-lois.justice.gc.ca

New York Convention (Canada): newyorkconvention.org

7.2. Registers

Corporations Canada: ised-isde.canada.ca

Ontario Business Registry: www.ontario.ca/businessregistry

7.3. Arbitration institutions

Canadian Arbitration Centre (ADRIC): adric.ca

Vancouver International Arbitration Centre (VanIAC): vaniac.org

7.4. Specialists in the enforcement of arbitral awards in Canada

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards Act (R.S.C., 1985, c. 16 (2nd Supp.)), sections 4 and 6; implemented at federal level and in all 10 provinces and territories. laws-lois.justice.gc.ca

[2] Provincial International Commercial Arbitration Acts (ICAA) based on the UNCITRAL Model Law; Ontario ICAA (March 2017), British Columbia (May 2018), Prince Edward Island (2023); ULCC Model Act.

[3] The 1958 New York Convention (Canada — in force since 10 August 1986); the reservation regarding commercial matters has been accepted by all provinces except Quebec; federal law, section 4(1).

[5] The Civil Procedure Code of Quebec (CCP), Article 648 (recognition; grounds for revocation or refusal).

Case law

[8] Itani v Société générale de Banque au Liban SAL (Quebec — 10-year limitation period); Ontario — 10 years from the date of the judgment.

Analytical and reference materials

[4] Lexology — In brief: enforcing and challenging arbitral awards in Canada (Superior Court; Commercial List in Ontario).

[6] Global Arbitration Review — Challenging and Enforcing Arbitration Awards: Canada (Article 36 of the Model Law — discretionary nature; Quebec — suspension upon application).

[7] Article IV of the New York Convention; Lexology — A Guide to the Enforcement of Arbitral Awards in Canada (documents; reasoned decision).

[9] Lexology — Arbitration awards in Canada (narrow grounds; in some provinces, the scope of discretion is broader).

[10] Global Arbitration Review — Canada (enforcement as a court judgement; exceptions).

These guidelines apply to mainland China; Hong Kong and Macau have separate arrangements.

1.1. Key legislation

The recognition and enforcement of foreign arbitral awards in mainland China are governed by the Civil Procedure Law of the People’s Republic of China (CPL) — in particular Article 290 (formerly Article 283) — in conjunction with the New York Convention. Article 290 of the CPL establishes the primacy of international treaties in the event of a conflict with domestic law; therefore, the New York Convention is directly applicable.[1]

The application of the Convention is set out in detail in the acts of the Supreme People’s Court (SPC): the 1987 Notice (Fafa [1987] No. 5), the 2015 Interpretation of the Civil Procedure Code, and the Rules/Regulations on Judicial Review in Arbitration-Related Cases, 2017–2018.[2]

1.2. The New York Convention

China acceded to the 1958 New York Convention on 22 January 1987 (effective from 22 April 1987), making two reservations: on reciprocity (only judgments from contracting states) and on commercial matters (only commercial disputes, excluding non-commercial disputes, such as family matters).[3]

2.1. The Court

The application is lodged directly with the Intermediate People’s Court at the debtor’s place of residence or where their property is situated (Article 290 of the Civil Procedure Code). In practice, the case is heard by the civil division of the court, and once the judgment has been declared enforceable, enforcement is handled by the enforcement division of the same court.[4]

2.2. The VNS Early Warning System

A key feature of the Chinese system is the prior-notification (prior-reporting / report-and-verification) system. If a Intermediate People’s Court intends to refuse to recognise or enforce a foreign judgment, it is obliged to refer the case for review to the higher-level Higher People’s Court and, ultimately, to the Supreme People’s Court. Only with the approval of the Supreme People’s Court may the refusal take place. This mechanism ensures consistency and curbs local protectionism.[5]

2.3. Nature of the procedure and appeals

The first decision is made in adversarial proceedings (inter partes; Article 548 of the 2015 Interpretation of the Code of Civil Procedure). As a rule, a ruling on enforcement is not subject to appeal on the merits; a refusal, however, requires mandatory review under the pre-notification procedure.[6]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are annexed:[7]

A certified original of the arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A translation into Chinese certified by an official/sworn translator or a diplomatic/consular officer. Documents bearing an apostille (China has been a party to the Apostille Convention since 2023) are accepted without further legalisation.

3.2. Deadlines

If the decision is favourable, the Civil Division will approve it within approximately 2 months (a refusal requires review by the Supreme Court), and the Enforcement Division must enforce it within approximately 6 months. The time limit for applying for enforcement is two years (the general time limit under the Code of Civil Procedure). Court costs: upon filing the application, a court fee (application fee) is payable to the Intermediate People’s Court, the amount of which is calculated in accordance with the Regulations on Court Costs depending on the amount to be recovered (for substantial sums, on a regressive scale; subject to verification). A domestic (rendered in China) arbitral award does not require separate recognition — it is enforced directly by the same Intermediate People’s Court; the difference from a foreign award lies in the existence of a recognition stage and the system of prior notification to the Supreme People’s Court, rather than in the amount of the fee. Additionally: costs for a certified translation into Chinese and legal support. Amounts are subject to verification at the time of filing.[8]

The grounds are limited by Article V of the New York Convention; the people’s courts interpret them narrowly, and any refusal is subject to review by the Supreme People’s Court.[9]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to review by the court (Article V(2))

The dispute is non-arbitrable under the law of the People’s Republic of China;

Contrary to public order in the People’s Republic of China (interpreted narrowly).

Once the judgment has been recognised, enforcement is carried out by the enforcement panel of the court of intermediate jurisdiction: seizure and sale of property, and attachment of the debtor’s bank accounts and other assets. Measures to preserve property (property preservation) may be applied during the proceedings.[10]

6.1. Tracing the debtor’s assets

Useful resources:

National Business Credit Information System (GSXT): www.gsxt.gov.cn;

VNS Register of Unscrupulous Debtors (list of defaulters): zxgk.court.gov.cn;

China Judgements Online database: wenshu.court.gov.cn.

6.2. Practical advantages and obstacles

Advance notice to the VNS: a refusal is not possible without the approval of a higher authority — strong protection for the claimant;[5]

Apostille: from 2023, the process of certifying documents has been simplified;[7]

Translation into Chinese: this is essential — allow for the time and costs involved.

7.1. Legislation and official sources

Supreme People’s Court of the People’s Republic of China: www.court.gov.cn

New York Convention (China): newyorkconvention.org

7.2. Registers

GSXT Business Register: www.gsxt.gov.cn

VNS Debtors’ Register: zxgk.court.gov.cn

7.3. Arbitration institutions

China International Economic and Trade Arbitration Commission (CIETAC): www.cietac.org

Beijing Arbitration Centre (BAC): www.bjac.org.cn

7.4. Specialists in the enforcement of arbitral awards in China

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] Civil Procedure Law of the People’s Republic of China (CPL), Article 290 (precedence of international treaties). court.gov.cn

[2] Supreme People’s Court of the People’s Republic of China: Notice of 1987 (Fafa [1987] No. 5); Interpretation of the Civil Procedure Law of 2015 (Article 548); Provisions on Judicial Review of Cases Involving Arbitration (2017–2018).

[3] The 1958 New York Convention (China — acceded on 22 January 1987, in force since 22 April 1987; reservations regarding reciprocity and commercial nature).

[7] Article IV of the New York Convention (documents; Chinese translation); the Apostille Convention (China — from 2023).

Analytical and reference materials

[4] China Law Vision — Overview: Recognition and Enforcement of Foreign Arbitral Awards in China (Article 290 of the Civil Procedure Code; court of second instance; civil and enforcement divisions).

[5] Kluwer Arbitration Blog — Reflections on the 30th Anniversary of China’s Prior Reporting Mechanism; Jus Mundi — China (prior notification system; VNS).

[6] Jus Mundi — China (Article 548 of the 2015 Civil Procedure Code — inter partes; appeal against/review of a refusal).

[8] GBA IP Lawyer — Guide to the Recognition and Enforcement of Foreign Arbitral Awards in China (processing times: ~2 months/~6 months; Apostille).

[9] Lexology — Recognition and Enforcement of Foreign Arbitral Awards in Mainland China (narrow interpretation of Article V; prior notification).

[10] Global Arbitration Review — Challenging and Enforcing Arbitration Awards: China (Executive Committee; measures to preserve assets).

1.1. Key legislation

Arbitration in Croatia is governed by the Arbitration Act (Zakon o arbitraži), which came into force in 2001 and is modelled on the structure and principles of the 1985 UNCITRAL Model Law. The Act governs domestic arbitration (any arbitration with a seat in Croatia, including cases with a foreign element), as well as the recognition and enforcement of domestic and foreign awards and the powers of the courts.[1]

Enforcement proceedings themselves are conducted in accordance with the Enforcement Act (Ovršni zakon).[2]

1.2. The New York Convention

Croatia has been a party to the New York Convention for over 30 years (by virtue of succession). Two reservations have been entered: one on reciprocity (awards from other contracting states are recognised) and one on commercial matters (awards in disputes classified as commercial under Croatian law are recognised). The Arbitration Act has incorporated all the provisions of Article V of the Convention.[3]

1.3. Other international treaties

The Washington Convention, the ICSID Convention and bilateral treaties. EU Regulation No 1215/2012 does not apply to arbitral awards.[4]

2.1. The Court

The application is lodged with the competent court: for commercial arbitration cases, the Zagreb Commercial Court (Trgovački sud u Zagrebu); for non-commercial cases, the Zagreb County Court (Županijski sud). Jurisdiction over specific enforcement measures is determined in accordance with the Enforcement Act (Article 43 of the Arbitration Act).[5]

2.2. Two paths to recognition

Recognition of a foreign judgment may be sought by means of a separate application or as a preliminary issue within the framework of enforcement proceedings (the court grants authorisation for enforcement whilst, at the same time, ruling on the issue of recognition).[6]

2.3. The position of the Croatian courts

Croatian courts play a supportive, non-interfering role and are generally favourable towards arbitration.[1]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are annexed:[7]

The original arbitration award or a duly certified copy thereof;

The original arbitration agreement or a certified copy thereof;

Translation into Croatian, if required.

If a judgment has been given in a State that is a party to the 1961 Hague Convention on the Apostille, judicial practice generally requires that the judgment and the agreement be certified with an apostille.[8]

3.2. Legal costs

The state fee depends on the type of judgment. A foreign judgment is recognised by the Zagreb Commercial Court (for commercial disputes) or the County Court (for non-commercial disputes): A court fee is payable under the Court Fees Act (Zakon o sudskim pristojbama), calculated on the basis of the value of the claim (subject to verification). A domestic (Croatian) judgment does not require separate recognition — it is enforced under the Enforcement Act (Ovršni zakon); recognition of a foreign judgment, unlike a domestic one, must be sought separately or as a preliminary issue in enforcement proceedings. Additionally: costs for translation into Croatian, an apostille and legal support. The amounts are current as of mid-2026 and are subject to verification at the time of submission.[5]

The Arbitration Act has incorporated the grounds set out in Article V of the Convention; a distinction is made between grounds for relative invalidity (which must be proved by the objecting party) and grounds for absolute invalidity (which are examined by the court ex officio, even if the parties do not invoke them). A proper application is required for a set-aside on grounds dependent on a party.[9]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision has not become binding, or has been set aside or suspended by a court in the country where it was made.

4.2. Grounds subject to review by the court (Article V(2))

Non-arbitrability of the dispute under Croatian law;

Contrary to public policy in Croatia.

An application to set aside an award (in respect of awards where the place of arbitration is Croatia) must be lodged within three months of receipt of the award; this is the sole remedy available. The court may, if necessary or at the request of a party, stay the annulment proceedings to allow the tribunal the opportunity to remedy the defect.[10]

Once the order has been granted, enforcement is carried out in accordance with the Enforcement Act through a bailiff: seizure of property and bank accounts, and the realisation of assets. Measures that are contrary to Croatian public policy shall not be enforced.[11]

6.1. Tracing the debtor’s assets

Useful resources:

Court Register (Sudski registar): sudreg.pravosudje.hr;

Land Registers (Zemljišne knjige): oss.uredjenazemlja.hr;

Financial Agency (FINA) — account details and registers: www.fina.hr.

6.2. Practical advantages and obstacles

Flexibility of recognition: separately or as a preliminary issue in enforcement proceedings;[6]

Apostille: in practice, this is usually required for decisions from countries that are parties to the 1961 Hague Convention;[8]

Commercial nature clause: decisions on disputes of a commercial nature under Croatian law shall be recognised.

7.1. Legislation and official sources

Narodne novine — Arbitration Act (Zakon o arbitraži): narodne-novine.nn.hr

The New York Convention (Croatia): newyorkconvention.org

7.2. Registers

Court Register: sudreg.pravosudje.hr

Land registers: oss.uredjenazemlja.hr

7.3. Arbitration institutions

Permanent Arbitration Court at the Croatian Chamber of Commerce and Industry (HGK): www.hgk.hr

7.4. Specialists in the enforcement of arbitral awards in Croatia

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] Croatian Arbitration Act (Zakon o arbitraži, in force since 2001; based on the 1985 UNCITRAL Model Law), Article 43. narodne-novine.nn.hr

[2] The Enforcement Act (Ovršni zakon).

[3] The 1958 New York Convention (Croatia — succession; reservations regarding reciprocity and commercial nature), Articles IV and V.

[4] The Washington Convention on ICSID; bilateral treaties; EU Regulation No 1215/2012 (which does not apply to arbitral awards).

Analytical and reference materials

[5] Mondaq — Croatia International Arbitration Comparative Guide (Zagreb Commercial Court / County Court; Enforcement Act).

[6] Mondaq — Croatia (recognition either on its own or as a preliminary issue in enforcement proceedings).

[7] Jus Mundi / ICC Country Answers — Croatia (Article IV of the Convention; documents).

[8] Jus Mundi — Croatia (requirement for an apostille under the 1961 Hague Convention).

[9] CMS Expert Guides — Croatia; Aceris Law — Arbitration in Croatia (relative and absolute invalidity; Article V of the Convention).

[10] Aceris Law — Arbitration in Croatia (3-month cancellation period; suspension to allow for the rectification of a defect).

[11] Mondaq — Croatia (enforcement under the Enforcement Act; public order).

1.1. Key legislation

The recognition and enforcement of foreign arbitral awards in Cyprus are governed by the Law on the Ratification of the New York Convention No. 84/1979, the Law on International Commercial Arbitration No. 101/1987 (ICAL, based on the 1985 UNCITRAL Model Law; the 2006 amendments have not been implemented) and the Law on the Recognition, Registration and Enforcement of Foreign Court Judgments No. 121(I)/2000, which sets out the procedure (the term ‘award’ is broadly defined therein and covers arbitral awards).[1]

Domestic arbitration is governed by separate legislation (the Arbitration Act, Cap. 4).[2]

1.2. The New York Convention

Cyprus is a party to the 1958 New York Convention (ratified by Law 84/1979) and applies it on a reciprocal basis — that is, to the recognition and enforcement of judgments rendered in other contracting states, and in respect of disputes considered to be commercial under Cypriot law.[3]

1.3. Other international treaties

The 1965 Washington Convention on ICSID;

The 1992 CSCE Convention on Conciliation and Arbitration; bilateral treaties.[4]

2.1. The Court

An application for the recognition and enforcement of a foreign arbitral award must be lodged with the District Court. Under Article 2 of Law 121(I)/2000, jurisdiction lies with the District Court of the district in which the debtor is domiciled; if the debtor is domiciled abroad, jurisdiction lies with the District Court of the applicant’s place of residence.[5]

2.2. Nature of the procedure

The application is filed by summons, accompanied by an affidavit, in accordance with the Rules of Civil Procedure; the court sets a hearing date within four weeks of the date of filing, and a copy of the application is served on the debtor. The Supreme Court of Cyprus has confirmed that, in appropriate cases, the application may also be filed ex parte (the case of Udruzena Beogradska Banka v Westacre Investment Inc.).[6]

3.1. Required documents

In accordance with Article IV of the New York Convention and Article 35(1) of the ICAL, the following are attached:[7]

A certified original of the arbitral award or a duly certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A translation into Greek certified (by a sworn translator or a consular or diplomatic official), if the documents are in another language.

3.2. Limitation period

Cypriot legislation does not specify a specific time limit for lodging an application for the recognition and enforcement of a foreign judgment.[8]

3.3. Legal costs

The court fee depends on the type of judgment. A foreign judgment is recognised and enforced by the District Court under Law No. 121(I)/2000 and the Convention: Court fees are payable in accordance with the rules of Cypriot court proceedings (generally, fixed/stamp duties for filing and affidavits; subject to verification). A domestic (rendered in Cyprus) arbitral award is enforced under the Arbitration Law (Cap. 4) through the same District Court; the difference from a foreign award lies in the applicable law, not in the amount of the fee. Additionally: costs for a certified translation into Greek and legal support. The amounts are current as of mid-2026 and are subject to verification at the time of filing.[5]

The provisions of Article V of the New York Convention apply; the Cypriot courts adopt a pro-enforcement approach (Beogradska Banka DD (1995) 1 A.A.D. 737).[9]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article V(2))

The dispute is not subject to arbitration under Cypriot law;

Contrary to public policy in Cyprus.

Certain first-instance decisions had previously adopted a restrictive approach to the issue of jurisdiction (refusing jurisdiction where the parties were not domiciled in Cyprus), which was criticised as not being entirely in line with the Convention.[10]

Cypriot courts actively apply interim measures, including Mareva-type injunctions (asset freezes), to support arbitration and enforcement. Once recognised, the award is enforced in the same way as a judgment of a Cypriot court: seizure of property and bank accounts, and the realisation of assets.[11]

6.1. Tracing the debtor’s assets

Useful resources:

Register of Companies (Department of the Registrar of Companies): www.companies.gov.cy;

Land Registry (Department of Lands and Surveys);

The Cypriot judicial system: www.cylaw.org (case law).

6.2. Practical advantages and obstacles

A major asset holding centre: Cyprus is home to the assets of many international entities, which is important for enforcement;

Mareva injunctions: available for freezing a debtor’s assets;[11]

Jurisdiction: please bear in mind the rule regarding the place of residence of the debtor/applicant (Law 121(I)/2000).

7.1. Legislation and official sources

CyLaw — Legislation and Practice: cylaw.org

The New York Convention (Cyprus): newyorkconvention.org

7.2. Registers

Company Register: www.companies.gov.cy

Case law: www.cylaw.org

7.3. Arbitration institutions

Cyprus Arbitration and Mediation Centre (CAMC): www.camc.com.cy

7.4. Specialists in the enforcement of arbitral awards in Cyprus

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] Act No. 84/1979 ratifying the New York Convention; Law on International Commercial Arbitration No. 101/1987 (ICAL); Law No. 121(I)/2000 (recognition, registration and enforcement). cylaw.org

[2] The Cyprus Arbitration Law, Cap. 4 (domestic arbitration).

[3] The 1958 New York Convention (Cyprus — Law 84/1979; reservations regarding reciprocity and commercial nature), Articles IV and V.

[4] The 1965 Washington Convention on ICSID; the 1992 CSCE Convention on Conciliation and Arbitration; bilateral treaties.

Case law

[6] Supreme Court of Cyprus — Udruzena Beogradska Banka v Westacre Investment Inc. (ex parte proceedings permitted); Beogradska Banka DD (1995) 1 A.A.D. 737.

[10] Nicosia District Court, 8 April 2011 (per Parparinos, PDC) — a restrictive approach to jurisdiction (criticism); Kluwer Arbitration Blog.

Analytical and reference materials

[5] Kluwer Arbitration Blog — Recognition of Arbitral Awards under the New York Convention by Cypriot Courts (Section 2 of Law 121(I)/2000; the competent District Court).

[7] ICC Country Answers: Cyprus; Legal500 — Cyprus: International Arbitration (Article 35(1) of the ICAL; Article IV of the Convention; translation into Greek).

[8] ICC Country Answers: Cyprus (no specific limitation period).

[9] Economou & Co — Arbitration in Cyprus, Part I; Legal500 — Cyprus (pro-enforcement approach; Beogradska Banka).

[11] Economou & Co — Arbitration in Cyprus (Mareva injunctions; enforcement of LCIA awards); Nasos A. Kyriakides & Partners — Recognition and Enforcement.

1.1. Key legislation

Arbitration in the Czech Republic is governed by Act No. 216/1994 Coll. on Arbitration Proceedings and the Enforcement of Arbitral Awards (Zákon o rozhodčím řízení a o výkonu rozhodčích nálezů), which has been in force since 1 November 1994, as amended (in particular, Act No. 19/2012 Coll. — consumer protection; amendments of 2016 and 2022).[1]

The recognition and enforcement of foreign judgments are governed by the Act on Private International Law No. 91/2012 Coll. (PILA, §§ 16(3), 120, 122(3)), whilst the enforcement procedure itself is governed by the Code of Civil Procedure No. 99/1963 Coll. and the Enforcement Code No. 120/2001 Coll. (private bailiffs).[2]

1.2. The New York Convention

Czechoslovakia was one of the first countries to ratify the 1958 New York Convention (27 April 1959); The Czech Republic is a party by virtue of state succession (since 1993). A reservation regarding reciprocity has been made (Article I(3)).[3]

1.3. Other international treaties

The 1961 European Convention and the 1927 Geneva Convention;

The Washington Convention, the ICSID Convention and the Energy Charter Treaty; bilateral treaties (including those with Slovakia).[4]

2.1. Two design variants

According to the case law of the Czech Supreme Court, a foreign judgment may be enforced in two ways, with one important difference:[5]

Enforcement of court judgments (Code of Civil Procedure, bailiffs): no separate recognition procedure is required — the court informally recognises the judgment by issuing a reasoned order for enforcement;

Enforcement by a private bailiff (Enforcement Code): a separate prior decision recognising the foreign judgment is required. The 2022 amendment to the PILA and the Enforcement Code expressly permitted enforcement by a bailiff where such a decision exists.[5]

2.2. The Court

As a general rule, an application for recognition and enforcement is lodged with the general court having jurisdiction over the debtor. An application for annulment (in respect of Czech judgments) must be lodged with the regional court (krajský soud) within three months of the date on which the judgment was served.[6]

2.3. The requirement for justification

Unlike decisions on the enforcement of domestic instruments, all decisions on the enforcement of foreign judgments (both court and arbitral) must state the grounds for the decision (§ 16(3) PILA; § 122(3) PILA – the enforcement of a foreign judgment is ordered by a reasoned decision of a Czech court).[7]

3.1. Required documents

In accordance with Article IV of the New York Convention and section 38 of the Arbitration Act, the following are attached:[8]

The original arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A certified translation into Czech, if the documents are in another language.

3.2. Limitation period

If, under conflict-of-laws rules, Czech substantive law applies, the limitation period is 10 years and begins to run from the moment the award becomes enforceable (calculated from the day following the expiry of the time limit for enforcement set by the arbitrators, usually 3–15 days). The court does not examine the expiry of the limitation period on its own initiative, but only upon objection by the debtor (Articles 640–642 and 648 of the Civil Code No. 89/2012 Coll.).[9]

3.3. Legal costs

In the case of judicial enforcement, court fees are levied in accordance with the Law on Court Fees (as a rule, a fixed fee for the application for enforcement; subject to verification); enforcement through a private bailiff is generally quicker and more effective (the bailiff takes the initiative in tracing the debtor’s assets), and the bailiff’s fee is determined by the bailiff’s tariff. For a foreign judgment, recognition takes place either informally as part of judicial enforcement or by a separate order (required for enforcement by a bailiff). A domestic (issued in the Czech Republic) arbitral award does not require separate recognition and is enforced directly under the same rules; the difference from a foreign award lies in the need for recognition, not in the amount of the fee. Specific rates are subject to verification.[5]

The provisions of Article V of the New York Convention apply; Czech courts interpret them restrictively and, in most cases, permit enforcement provided that the formal requirements are met.[10]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to review by the court (Article V(2))

The dispute is not subject to arbitration (since 2016, consumer disputes have not been subject to arbitration);

Contravention of public policy (to be interpreted narrowly; errors of law or fact do not in themselves constitute a contravention).

Upon the filing of an application for a stay of enforcement, the court shall stay the proceedings and order the applicant to file an application for setting aside within 30 days; if no such application is filed, enforcement shall continue. If the award is set aside, the parties are entitled to apply to the court for a fresh hearing of the dispute (section 31 et seq. of the Arbitration Act).[11]

Once enforcement has been authorised, the debt is recovered from the debtor’s property, bank accounts and other assets through a court enforcement officer or a private bailiff.

6.1. Tracing the debtor’s assets

Useful resources:

Commercial Register (Obchodní rejstřík): or.justice.cz;

Land Registry (Katastr nemovitostí): nahlizenidokn.cuzk.cz;

Central Register of Enforcement Proceedings: www.ceecr.cz.

6.2. Practical advantages and obstacles

Choosing the procedure: a private bailiff requires a preliminary decision on recognition — bear this in mind when formulating your strategy;[5]

Translation into Czech is compulsory; please allow for the time and costs involved;

Cancellation period (3 months): a strict cut-off date — important in the event of a parallel challenge.

7.1. Legislation and official sources

Laws for the People — Act No. 216/1994 Coll.: zakonyprolidi.cz

New York Convention (Czech Republic): newyorkconvention.org

7.2. Registers

Commercial Register: or.justice.cz

Land Registry: nahlizenidokn.cuzk.cz

7.3. Arbitration institutions

Arbitration Court attached to the Economic Chamber and the Agricultural Chamber of the Czech Republic: www.soud.cz

7.4. Specialists in the enforcement of arbitral awards in the Czech Republic

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] Act No. 216/1994 Coll. on Arbitration Proceedings and the Enforcement of Arbitral Awards (in force since 1 November 1994; amended by Acts No. 19/2012, 2016 and 2022). zakonyprolidi.cz

[2] Act No. 91/2012 Coll. on Private International Law (PILA), Sections 16(3), 120 and 122(3); Code of Civil Procedure No. 99/1963 Coll.; Enforcement Code No. 120/2001 Coll.

[3] The 1958 New York Convention (Czechoslovakia – ratified on 27 April 1959; the Czech Republic – succession since 1993; reservation regarding reciprocity).

[4] The 1961 European Convention; the 1927 Geneva Convention; the ICSID Washington Convention; the Energy Charter Treaty; bilateral treaties.

[9] Civil Code No. 89/2012 Coll., Articles 640–642 and 648 — 10-year limitation period.

Case law

[5] Nejvyšší soud (Supreme Court of the Czech Republic) — case law on the enforcement of foreign judgments by bailiffs (requirement for prior recognition); Kluwer Arbitration Blog — ‘double standard’ (2019).

Analytical and reference materials

[6] VLO Law Firm — Czech Republic Arbitration (Regional Court; 3-month period for setting aside the award).

[7] Ministry of Industry and Trade (MPO) — Recognition and enforcement of foreign arbitral awards in the Czech Republic (Section 122(3) of the PILA).

[8] Section 38 of the Czech Arbitration Act; Article IV of the New York Convention.

[10] CMS Expert Guides — Czech Republic; Aceris Law — International Arbitration in the Czech Republic (Section 31 of the Act).

[11] Mondaq — International Arbitration Comparative Guide: Czech Republic (two enforcement mechanisms; § 31).

1.1. Key legislation

Arbitration in Denmark is governed by the Arbitration Act (Voldgiftsloven, Act No. 553 of 24 June 2005, as amended on 26 February 2008, hereinafter referred to as the DAA), which is based on the 1985 UNCITRAL Model Law. The 2006 amendments to the Model Law have not been adopted.[1]

Recognition and enforcement are governed by Chapter 9 (§§ 38–39 DAA), which essentially does not deviate from Articles 35–36 of the Model Law. These rules are mandatory — the parties may not derogate from them by agreement (§ 2(1) DAA). The procedure for enforcement itself is set out in the Administration of Justice Act (Retsplejeloven, AJA), Chapter 46.[2]

1.2. The New York Convention and a broader scope

Denmark ratified the 1958 New York Convention in 1972 (since 1976, it has also applied to the Faroe Islands and Greenland). Reservations were initially entered (regarding reciprocity and the commercial nature of the Convention), but Danish law now fully incorporates the Convention.[3]

A key feature: Section 38 of the DAA goes further than the Convention — Danish courts recognise and enforce any foreign arbitral awards, regardless of the country in which they were made.[4]

1.3. Other international treaties

The 1961 European Convention on Foreign Trade Arbitration;

The Nordic Convention on the Recognition and Enforcement of Judgments (simplified procedure for Sweden, Norway, Finland and Iceland).[5]

2.1. Direct enforcement without a separate writ of execution

Under § 38 of the DAA, an arbitral award, regardless of the country in which it was made, is recognised as binding and enforced in accordance with the procedure laid down in the Administration of Justice Act for the enforcement of court judgments. No separate exequatur procedure is required.[6]

2.2. The Court

Enforcement proceedings are initiated by filing an application with the competent Enforcement Court (Fogedret) — a division of the local city court — in accordance with Chapter 46 of the AJA (§ 487). The court with jurisdiction is that of the debtor’s place of residence, place of business or the location of their assets.[7]

2.3. The position of the Danish courts

Danish courts are favourable towards enforcement: the grounds for refusal set out in § 39 of the DAA are exhaustive and interpreted narrowly. The Supreme Court (the ‘Taewoong’ case) confirmed that set-aside is possible only in exceptional circumstances involving a clear breach of public policy.[8]

3.1. Required documents

The application must be submitted in writing to the Enforcement Court with jurisdiction over the debtor’s place of residence or the location of their assets. The following must be attached:[9]

A duly certified copy of the arbitral award;

An arbitration agreement (if concluded in writing);

A certified translation into Danish, if the documents are in another language (as required by the court).

3.2. Commencement of performance

Enforcement proceedings against the debtor’s assets may be commenced two weeks after the date of the judgment (for example, in the case of a judgment dated 1 March, no earlier than 16 March), unless the judgment itself specifies a different time limit. The enforcement court attaches the property and, in the case of monetary claims, sells it at auction.[10]

3.3. Legal costs

The general rules on court fees (retsafgift) apply when applying to the Enforcement Court (Fogedret) under the Administration of Justice Act — as a rule, a fixed fee for enforcement proceedings, depending on the amount of the claim (subject to verification). As there is no separate exequatur procedure, foreign and domestic (Danish) arbitral awards are enforced in the same way and directly through the Enforcement Court — there is no difference in the amount of the fee between them. In addition, there are costs for a certified translation and legal assistance. Specific rates are subject to verification at the time of submission.[7]

The grounds are set out exhaustively in § 39 of the DAA and correspond to Article V of the New York Convention (Article 36 of the Model Law).[11]

4.1. Grounds based on the debtor’s application

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds to be examined by the court

The dispute is not arbitrable under Danish law (§ 39(1) No. 2(a) of the DAA);

A clear breach of public order in Denmark.

4.3. Suspension in the event of a dispute

An application for the setting aside of a decision does not, as a rule, suspend its enforcement. However, enforcement may be suspended where there are compelling grounds — for example, if there is a reasonable likelihood that the decision will be set aside.[12]

Upon application by a party, a state court is entitled to grant interim measures notwithstanding the existence of an arbitration agreement (§ 9 DAA); arbitrators are also entitled to grant interim measures (§ 17 DAA).[13]

Once recognised, the decision is enforced as a Danish court judgment through the Enforcement Court (Fogedret):

Enforcement (udlæg) against movable and immovable property;

Freezing of bank accounts and receivables;

Sale of assets by auction to satisfy monetary claims.

6.1. Tracing the debtor’s assets

Useful resources:

Central Business Register (CVR): datacvr.virk.dk;

Land Register (Tinglysning): www.tinglysning.dk;

The State Register of Debtors — via the Enforcement Court.

6.2. Northern regime

For decisions from Sweden, Norway, Finland and Iceland, a simplified procedure under the Nordic Convention may apply — this is worth bearing in mind when choosing a strategy.[5]

6.3. Practical advantages and obstacles

Direct enforcement without a separate exequatur procedure — significantly speeds up the process;

Broad scope: decisions from any country are enforced, not just those of States Parties to the Convention;[4]

Translation: a certified Danish translation as required by the court — allow for the time and costs involved.

7.1. Legislation and official sources

Legal Information — The Arbitration Act and the Administration of Justice Act: retsinformation.dk

The New York Convention (Denmark): newyorkconvention.org

The courts of Denmark: domstol.dk

7.2. Registers

CVR Business Register: datacvr.virk.dk

Land Register: www.tinglysning.dk

7.3. Arbitration institutions

The Danish Institute of Arbitration (DIA), Copenhagen: voldgiftsinstituttet.dk

7.4. Specialists in the enforcement of arbitral awards in Denmark

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Danish Arbitration Act (Voldgiftsloven, Act No. 553 of 24 June 2005, as amended 26 February 2008), based on the 1985 UNCITRAL Model Law. retsinformation.dk

[2] DAA, sections 2(1), 38 and 39 (Chapter 9); the Administration of Justice Act (Retsplejeloven), Chapter 46, sections 480 and 487.

[3] The 1958 New York Convention (Denmark – ratified in 1972; the Faroe Islands and Greenland since 1976); Government Notice No. 58 of 19 June 1973.

[4] DAA § 38(1) — enforcement of all foreign judgments, regardless of the country in which they were made (a broader scope than that of the Convention).

[5] The 1961 European Convention; the Nordic Convention on the Recognition and Enforcement of Judgments (Act on Nordic Civil Judgments).

Case law

[8] Højesteret (the Danish Supreme Court), the ‘Taewoong’ case — annulment only in the event of a clear breach of ordre public.

Analytical and reference materials

[6] Aceris Law — International Arbitration in Denmark (Section 38 of the DAA, direct enforcement).

[7] Chambers — International Arbitration 2025, Denmark (Fogedret, Chapter 46 AJA; jurisdiction based on the debtor’s place of business).

[9] Lexology — In brief: arbitration formalities in Denmark (documents; translated into Danish).

[10] Jus Mundi — Denmark country publication (§ 480 AJA — two-week period; sale by auction).

[11] Lexology / Chambers — § 39 DAA (exhaustive grounds, Article 36 of the UNCITRAL Model Law / Article V of the Convention).

[12] Chambers — Denmark (suspension of enforcement pending a possible reversal).

[13] Lexology — Denmark (§ 9, § 17 DAA — interim measures ordered by courts and arbitrators).

1.1. Key legislation

Arbitration and the recognition of awards are governed by the Estonian Code of Civil Procedure (Tsiviilkohtumenetluse seadustik, TsMS). The legal basis for the recognition and enforcement of foreign awards is set out in Chapters 62, 77 and 78 of the TsMS (as well as Articles 619–627 on the recognition of foreign court and arbitral awards).[1]

There is a distinction between the recognition of domestic and foreign awards. An award made by an arbitral tribunal seated in Estonia is enforceable once a court has recognised it and declared it enforceable; whilst awards of the Arbitration Court of the Estonian Chamber of Commerce and Industry (ECCI) and the Arbitration Court of the Chamber of Notaries are recognised and enforced without any separate procedure. Foreign arbitral awards are recognised and enforced exclusively in accordance with the New York Convention.[2]

1.2. The New York Convention and other treaties

Estonia is a party to the 1958 New York Convention, the ICSID Washington Convention and the Energy Charter Treaty. All awards made outside Estonia are considered foreign.[3]

2.1. The Court

The court of first instance with jurisdiction is the county court (maakohus). In practice, applications for recognition and enforcement are submitted to the Harju County Court (Harju Maakohus) in Tallinn, which handles the largest volume of commercial cases. The application is submitted to the county court specified in the arbitration agreement or, in the absence of such a provision, to the county court at the place of arbitration.[4]

2.2. The position of the Estonian courts

Estonian courts have consistently taken a favourable view of arbitration. The Supreme Court has recognised foreign awards even where there were formal discrepancies with the requirements of the Convention (for example, where a copy was certified by a legal adviser to an institution), stating that, for recognition to be granted, it is sufficient for the form of the award to comply with the requirements of Estonian procedural law, provided the debtor does not contest the existence of the award.[5]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are annexed:[6]

Arbitration award (original or certified copy);

Arbitration agreement;

Full translation of the decision: a translation of the entire decision is required.

3.2. Limitation period

Estonian arbitration law does not contain any specific provisions regarding the time limit for applying for the recognition and enforcement of a foreign award. As a general rule, a claim confirmed by an enforceable instrument is time-barred after 10 years (Article 157(1)–(2) of the General Part of the Civil Code); where this limitation period applies, it is calculated from the date on which the award was made. There is as yet no case law on this matter.[7]

3.3. Legal costs

A state fee (riigilõiv) is payable when submitting an application to a county court (usually the Harju County Court) under the State Fees Act — the rate depends on the amount of the claim (subject to verification). A domestic (rendered in Estonia) decision of the Permanent Arbitration Court (ECCI, the Arbitration Court of the Chamber of Notaries) is enforced directly without a separate recognition procedure; a foreign award, unlike a domestic one, requires recognition under the New York Convention. Additionally, there are costs for a full translation of the award and legal support. Specific rates are subject to verification at the time of filing.[4]

The grounds set out in Article V of the New York Convention apply; the list is exhaustive, and the Estonian courts interpret them strictly.[8]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to review by the court (Article V(2))

Disputes that cannot be settled by arbitration under Estonian law (for example, disputes relating to residential tenancies, the termination of employment relationships, and consumer credit — Articles 718 and 718.1 of the TsMS);

Contrary to public order in Estonia.

The Supreme Court interprets public policy narrowly: it encompasses only those rules that reflect the fundamental values of the legal system (for example, the independence and impartiality of the arbitrator, and the non-arbitrability of certain categories of disputes). Failure to comply with other mandatory rules (including Estonian rules on service of process) does not in itself constitute a breach of public policy.[9]

The court is entitled (but not obliged) to stay proceedings for the recognition and enforcement of an award until the procedure for setting aside or staying the award at the seat of arbitration has been completed (Articles V(1)(e) and VI of the Convention). No other grounds for suspension are provided for.[10]

ECCI’s domestic decisions are enforced directly; once recognised, a foreign decision is enforced through a bailiff (kohtutäitur): seizure of property and bank accounts, and the realisation of assets.[11]

6.1. Tracing the debtor’s assets

Useful resources:

Commercial Register (e-Business Register): ariregister.rik.ee;

The Land Register (Kinnistusraamat) — a register of immovable property;

Chamber of Bailiffs and Insolvency Administrators: www.kpkoda.ee.

6.2. Practical advantages and obstacles

Narrow public order: a high degree of predictability in enforcement;[9]

Full translation: a translation of the entire decision is required — please allow for the time and costs involved;

The digital environment: Estonian registers and e-File simplify asset tracing and filing.

7.1. Legislation and official sources

Riigi Teataja — TsMS (Civil Procedure Code): riigiteataja.ee

The New York Convention (Estonia): newyorkconvention.org

7.2. Registers

Commercial Register: ariregister.rik.ee

Chamber of Executors: www.kpkoda.ee

7.3. Arbitration institutions

Arbitration Court of the Estonian Chamber of Commerce and Industry (ECCI): www.koda.ee

7.4. Specialists in the enforcement of arbitral awards in Estonia

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] Estonian Code of Civil Procedure (Tsiviilkohtumenetluse seadustik, TsMS), Chapters 62, 77 and 78; Articles 619–627. riigiteataja.ee

[2] TsMS — distinction between domestic and foreign judgments; direct enforcement of ECCI judgments; foreign judgments — under the New York Convention.

[3] The 1958 New York Convention; the ICSID Washington Convention; the Energy Charter Treaty (Estonia is a party to it).

[7] General Part of the Civil Code (TsÜS), Article 157(1)–(2) — a 10-year limitation period.

Case law

[5] Estonian Supreme Court, June 2017 — recognition of the SCC award despite a formal discrepancy with the Convention; NJORD — Estonia’s arbitration friendliness.

[9] Estonian Supreme Court, cases 2-18-4731, 2-16-15675, 3-2-1-186-15 — a narrow interpretation of public policy (Kluwer Arbitration Blog).

Analytical and reference materials

[4] VLO Law Firm — Litigation & Arbitration in Estonia (Harju County Court); IBA Arbitration Guide: Estonia (2024) — jurisdiction by agreement/place of arbitration.

[6] ICC Country Answers: Estonia (Article IV of the Convention; full translation of the decision).

[8] VLO Law Firm / ICC — grounds under Article V of the Convention (exhaustive list, strict application).

[10] ICC Country Answers: Estonia — stay of proceedings (at the court’s discretion; Article VI of the Convention).

[11] Estonian Chamber of Commerce and Industry (ECCI) — Resolving disputes in the Court of Arbitration; IBA Arbitration Guide: Estonia (enforcement).

1.1. Key legislation

Arbitration is governed by the Finnish Arbitration Act (967/1992, FAA), which came into force on 1 December 1992. The Act applies to both domestic and international arbitration. It is largely compatible with the 1985 UNCITRAL Model Law, but Finland is not formally a party to the Model Law; the 2006 amendments have not been implemented. The recognition and enforcement of foreign awards are governed by §§ 52–55 of the FAA.[1]

Enforcement itself is carried out in accordance with the Enforcement Code (705/2007): a recognised judgment is enforced in the same way as a final court judgment.[2]

1.2. The New York Convention

Finland ratified the 1958 New York Convention without any reservations; most of its provisions have been incorporated into the FAA. Consequently, all foreign judgements are recognised and enforced in accordance with the Convention.[3]

1.3. Other international treaties

The 1965 Washington Convention on ICSID (since 1969);

More than 60 bilateral investment agreements.[4]

2.1. The Court

An application for enforcement is submitted to the district court (käräjäoikeus) — the court of first instance (§§ 43, 54 FAA). Jurisdiction is determined by the place of residence or habitual abode of a debtor who is a natural person; by the place of registration, principal place of business or branch of a debtor who is a legal person; by the court agreed in writing by the parties; or by the location of the debtor’s assets.[5]

2.2. Nature of the procedure

As a general rule, proceedings are adversarial: the court is obliged to give the debtor the opportunity to present explanations and evidence. The case is heard in chambers unless it is necessary to hear a witness. The court may declare a foreign judgment enforceable on an ex parte basis where there is a specific obstacle to hearing the debtor (for example, their whereabouts are unknown).[6]

2.3. Appeals

There are two levels of appeal: a decision of the district court may be appealed to the Court of Appeal (subject to leave to appeal being granted), and subsequently to the Supreme Court (subject to leave to appeal being granted).[7]

3.1. Required documents

In accordance with Article IV of the New York Convention and Sections 52–54 of the FAA, the following are attached:[8]

The original arbitration award or a certified copy thereof;

A copy of the arbitration agreement;

A certified translation, if the documents are not in Finnish or Swedish (the court may waive this requirement).[8]

3.2. Legal costs

A court fee (oikeudenkäyntimaksu) is payable when bringing a case before a district court under the Court Fees Act — as a rule, this is a fixed fee per case in the district court (subject to verification). A domestic (issued in Finland) arbitral award is declared enforceable by the same district court following the same procedure (§ 43 FAA); the difference compared with a foreign award lies in the applicable grounds (for a foreign award: Article V of the Convention / Section 53 of the FAA), rather than in the amount of the fee. In addition, there are costs for translation (into Finnish or Swedish) and legal assistance. Specific rates are subject to verification at the time of submission.[5]

3.3. Limitation period

Under the Enforcement Code, an arbitral award may, as a general rule, be enforced within 15 years of the date on which it was made, provided that it imposes a payment obligation on a natural person (in specified cases, this period may be extended). The applicable time limits should be clarified taking into account the nature of the debtor.[9]

The grounds are exhaustive and comply with Article V of the New York Convention (§ 53 of the FAA). The Finnish courts take a favourable view of enforcement.[10]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review

Non-arbitrability of the dispute;

Contrary to public policy in Finland (the breach must have a material impact on the outcome).

4.3. A decision set aside abroad

If a party proves that the award has been set aside or annulled at the seat of arbitration, it shall not be enforced (§ 53 FAA). A court may also stay enforcement of the award if a party invokes an application for annulment or declaration of nullity filed at the place of arbitration (§ 55 FAA).[11]

The FAA does not contain provisions on interim measures; therefore, applications for such measures are made under the Code of Civil Procedure (4/1734); state courts are empowered to grant interim measures prior to and during arbitration. Once recognised, the award is enforced through the Enforcement Service (ulosotto) in the same way as a court judgement: seizure of property and bank accounts, and the realisation of assets.[12]

6.1. Tracing the debtor’s assets

Useful resources:

Trade Register (PRH, Finnish Patent and Registration Office): www.prh.fi;

Business Information System (YTJ): www.ytj.fi;

Enforcement Service (Ulosotto): ulosotto.fi.

6.2. Practical advantages and obstacles

Translation into Finnish OR Swedish — flexibility (Swedish is the second official language);

Adversarial nature: the debtor is involved in the proceedings — allow for this;

Set-aside awards: where an award is set aside at the place of arbitration, enforcement is not possible.

7.1. Legislation and official sources

Finlex — Arbitration Act 967/1992: finlex.fi

New York Convention (Finland): newyorkconvention.org

7.2. Registers

PRH Commercial Register: www.prh.fi

YTJ: www.ytj.fi

7.3. Arbitration institutions

The Arbitration Institute of the Finnish Chamber of Commerce (FAI): arbitration.fi

7.4. Specialists in the enforcement of arbitral awards in Finland

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Finnish Arbitration Act (Laki välimiesmenettelystä, 967/1992), in force since 1 December 1992, sections 43, 52–55. Finlex: finlex.fi

[2] The Finnish Enforcement Code (Ulosottokaari, 705/2007), § 19.

[3] The 1958 New York Convention (Finland — ratification without reservations), Articles IV and V.

[4] The 1965 ICSID Washington Convention (since 1969); bilateral investment treaties (60+).

[9] The Enforcement Code — 15-year limitation period (payment obligation of a natural person); the Limitation of Debts Act 728/2003.

Analytical and reference materials

[5] Lexology — First-step analysis: arbitration in Finland (jurisdiction of the district court; §§ 43, 54 FAA).

[6] Jus Mundi — Finland country publication (adversarial proceedings; ex parte in cases of impediment).

[7] Jus Mundi — Finland (two levels of appeal).

[8] ICLG — International Arbitration 2025, Finland; Lexology — documents and translation (Finnish/Swedish).

[10] Lexology — A general introduction to international arbitration in Finland (pro-arbitration approach; § 53 FAA).

[11] Lexology — Arbitration in Finland (§ 53, § 55 FAA — set-aside of awards, adjournment).

[12] IBA Arbitration Guide: Finland; Lexology — interim measures (Code of Civil Procedure 4/1734).

1.1. Key legislation

The recognition and enforcement of arbitral awards made abroad, as well as those made in France in the context of international arbitration, are governed by Articles 1514–1527 of the French Code of Civil Procedure (Code de procédure civile, CPC).[1] These provisions were introduced by Decree No. 2011-48 of 13 January 2011 and have been in force since 1 May 2011.[2] For purely domestic (internal) arbitral awards, Articles 1487 et seq. of the CPC apply; the regime for foreign and international awards is more favourable.

Enforcement following the issue of an enforcement order is governed by the Code of Civil Enforcement Procedures (Code des procédures civiles d'exécution).[3]

1.2. The New York Convention and the principle of the more favourable law

France is a party to the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (ratified in 1959, without reservations).[4] Key feature: by virtue of the ‘more favourable law’ rule (Article VII(1) of the Convention), the French provisions of the Code of Civil Procedure (CPC) take precedence over the Convention, as they are more liberal.[4]

1.3. Other international treaties

France is also a participant in:

the 1965 Washington Convention on the Settlement of Investment Disputes (ICSID);

the 1961 European Convention on Foreign Trade Arbitration (ECICA).[1]

1.4. The principle of ‘autonomy’ of an arbitral award

French doctrine regards an international arbitral award as a ‘decision of international justice not rooted in any national legal system’, the validity of which is assessed in accordance with the laws of the country where enforcement is sought.[5] Practical consequence: France enforces arbitral awards that have been set aside by the court of the place where the award was made (see section 4.3).

2.1. The court of first instance

For judgments delivered abroad, the President of the Paris Court (Tribunal judiciaire de Paris) has exclusive jurisdiction to grant exequatur — Article 1516 of the Code of Civil Procedure (CPC).[6] For international judgments delivered in France, the Tribunal judiciaire at the place where the judgment was delivered has jurisdiction.

2.2. The nature of the exequatur procedure

The exequatur procedure is not adversarial (ex parte) — Article 1516(2) of the CPC.[6] The application is lodged by the party with the greatest interest with the court registry. The presiding judge carries out a prima facie review to ensure compliance with public international law; the case is not reviewed on its merits.[7]

2.3. The position of the French courts

France consistently ranks among the top three most enforcement-friendly jurisdictions in the world.[8] French courts show a high degree of respect for arbitral awards, which are set aside only in extremely rare cases — namely, where there is a lack of jurisdiction, a breach of the rules governing the composition of the tribunal, an abuse of power, or a breach of the adversarial principle.[9]

3.1. Procedure

An application for enforcement must be submitted in writing (in practice, a few lines requesting that the judgment be enforced) to the registry of the Paris Court, together with the necessary documents.[10] The debtor is not notified or heard at this stage. If the application is successful, the exequatur formula is affixed to the original (or a certified copy) of the judgment — Article 1517 of the CPC.[11]

3.2. Required documents

In accordance with Articles 1515 and 1516 of the CPC, the following are attached:

The original arbitration award (or a duly certified copy thereof);

Arbitration agreement (original or certified copy);

A certified translation into French, if the documents are in another language (by a translator from the list of court-appointed experts or an accredited translator);[12]

Proof of notification of the decision and a power of attorney for the French representative (in practice).[8]

In practice, the Secretariat of the President of the Paris Court requires either the original award together with a certified copy, or the original arbitration agreement.[13]

3.3. Legal costs

There are no state court fees for the exequatur procedure.[10] The applicant’s main costs are the French solicitor’s fees (legal representation is mandatory) and the costs of sworn translation. In the event of an appeal, the costs of the appeal proceedings are added. There is no state fee for either foreign and international judgments (Article 1516 of the CPC) or domestic judgments (Article 1487 of the CPC) – there is no difference in the amount of the state fee between them; the cost is determined by the lawyer’s fees and the services of the judicial officer (commissaire de justice) at the enforcement stage.

3.4. Deadlines

If there are no objections, the presiding judge issues an enforcement order within approximately 15 days (according to other estimates, between 4 and 12 weeks).[10] In the event of an appeal, proceedings before the Paris Court of Appeal usually last around 18 months.[10]

3.5. Limitation period

French arbitration law does not expressly set a time limit for filing an application for recognition and enforcement. However, the general five-year limitation period provided for in the French Civil Code for personal claims applies.[14] Important: the decision of the Versailles Court of Appeal of 10 December 2024 has drawn the courts’ attention more strongly to compliance with this five-year time limit — it is advisable not to delay in filing an application.[15]

The list of grounds for refusal in France is narrower than that set out in Article V of the New York Convention. According to Articles 1520 and 1525 of the CPC, recognition and enforcement may be refused on only five grounds:[16]

1) the arbitral tribunal erred in accepting or declining jurisdiction;

2) the arbitral tribunal was constituted in breach of the rules;

3) the tribunal exceeded the powers (mandate) conferred upon it;

4) the principle of due process has been breached;

5) recognition or enforcement would be manifestly contrary to France’s public international order.

4.1. A restrictive interpretation of public policy

A breach of international public policy must be ‘manifest, genuine and specific’. In particular, the incompatibility of an arbitral award with a judicial decision previously recognised in France may constitute a breach of public policy only where there are mutually exclusive legal consequences.[17]

4.2. Special case: a judgment set aside in the country where it was given

A key difference in France is that Articles 1520 and 1525 of the Code of Civil Procedure (CPC) do NOT include the setting aside of an award by a court at the place of arbitration amongst the grounds for refusal.[18] French courts have consistently recognised and enforced awards set aside abroad, starting with the Norsolor (1984), Hilmarton (1994) and Putrabali (2007) cases.[18] This approach also applies to domestic awards rendered and set aside abroad (Court of Cassation, 13 January 2021).[19]

In the case of judgments handed down abroad, an order granting OR refusing exequatur may be appealed against — Article 1525 of the CPC.[20] An appeal must be lodged with the Paris Court of Appeal within one month of the official service (signification) of the order and is considered on the same five grounds set out in Article 1520 of the CPC.

Important: neither an action to set aside a judgment nor an appeal against an enforcement order automatically suspends the enforcement of the judgment — Article 1526(1) of the CPC.[20] A party may apply for a stay of enforcement or for interim measures if enforcement is likely to seriously prejudice its rights.

Once an exequatur has been granted, the decision becomes enforceable in France ‘on a par with a court judgement’ and may be enforced by means of coercive measures.[7] The available instruments include:

Seizure (saisie) of the debtor’s movable property and bank accounts by a bailiff (commissaire de justice, formerly huissier);

Seizure of accounts receivable and other property rights;

Precautionary (conservative) measures — may be imposed on a temporary basis, including where enforcement is suspended.[9]

An arbitral tribunal sitting in international arbitration in France has broad powers to order interim and provisional measures, including under threat of a penalty payment (astreinte) — Article 1468 of the Code of Civil Procedure (CPC).[21]

7.1. Mandatory representation

A French lawyer (avocat) is required to file a claim and, in particular, to conduct appeal proceedings. For a foreign claimant, engaging a local representative is a practical necessity.

7.2. Tracing the debtor’s assets

Before submitting an application, it is advisable to establish whether the debtor has any assets in France. Useful resources:

Infogreffe (business register): www.infogreffe.fr;

The register of beneficial owners and companies’ financial statements are available via the same portal;

BODACC Official Gazette: www.bodacc.fr (information on insolvency and liquidation).

7.3. Practical obstacles

Despite the jurisdiction’s high level of business-friendliness, in practice the following situations are encountered:

Five-year limitation period: following the tightening of the rules (Versailles, 2024), any delay in submitting an application poses a real risk of rejection;[15]

Translation requirements: the translation must be carried out by a sworn or accredited translator;

Asset tracing: if the debtor has no assets in France, the exequatur has no practical value.

8.1. Legislation and official sources

Legifrance — CPC (Articles 1514–1527): legifrance.gouv.fr

New York Convention (France): newyorkconvention.org

8.2. Registers

Infogreffe Business Register: www.infogreffe.fr

BODACC Official Gazette: www.bodacc.fr

8.3. Arbitration institutions

ICC International Court of Arbitration (Paris): iccwbo.org

French Arbitration Association (AFA): afa-arbitrage.com

8.4. Specialists in the enforcement of arbitral awards in France

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] French Code of Civil Procedure (Code de procédure civile), Articles 1487 et seq., 1514–1527. Legifrance: legifrance.gouv.fr

[2] Decree No. 2011-48 of 13 January 2011 on the reform of arbitration law (effective from 1 May 2011).

[3] Code of Civil Enforcement Procedures (Code des procédures civiles d'exécution).

[4] The 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (Article VII(1) — the rule of the more favourable law).

Case law

[5] Court of Cassation, 1st Civil Chamber, 29 June 2007, No. 05-18.053 (Putrabali) — the autonomy of international arbitral awards.

[9] Court of Cassation, 1st Civil Chamber: Norsolor (9 October 1984, No. 83-11.355); Hilmarton (23 March 1994, No. 92-15.137).

[15] Versailles Court of Appeal, 10 December 2024 — stricter application of the five-year limitation period.

[17] Paris Court of Appeal, 12 July 2021, No. 19/11413; 11 January 2022, No. 20/17923 — interpretation of public international order.

[19] Court of Cassation, 1st Civil Chamber, 13 January 2021, No. 19-22.932 — extension of the principle to judgments set aside abroad.

Analytical and reference materials

[6] Global Arbitration Review — The Guide to Challenging and Enforcing Arbitration Awards, 4th ed., France (Freshfields: C. Seraglini, Q. Herruel).

[8] Global Law Experts — How to Enforce a Foreign Arbitral Award in France (2026).

[10] Baker McKenzie — Cross-Border Enforcement Centre, France: Arbitration Awards (time limits, no fees).

[12] IBA Arbitration Committee — Arbitration Guide: France (Articles 1514–1517 of the Code of Civil Procedure).

[16] Clyde & Co — Can you still enforce awards in France that have been set aside? (2022) — the five grounds set out in Articles 1520 and 1525 of the CPC.

[18] Clyde & Co / Jus Mundi (Daily Jus) — Spotlight on France: Enforcement of Annulled Awards (2025).

[20] Global Legal Insights — International Arbitration Laws & Regulations 2026, France.

[21] Jus Mundi — France country publication (Article 1468 of the Code of Civil Procedure, interim measures; five-year time limit).

1.1. Key legislation

Arbitration in Georgia is governed by the Georgian Arbitration Act, which was adopted in 2009 and came into force in 2010 (the ‘2010 Act’), which largely follows the UNCITRAL Model Law (as amended in 2006) and covers both domestic and international arbitration. The procedural rules governing recognition and enforcement are supplemented by the Civil Procedure Code of Georgia.[1]

Under Georgian law, an arbitral award is binding regardless of the country in which it was made, and Georgian courts may refuse to recognise and enforce it only on the basis of a limited list of grounds.[2]

1.2. The New York Convention and its broad scope

Georgia is a party to the 1958 New York Convention and did not make any reservations upon ratification. Furthermore, Georgian courts enforce awards made in states that are not parties to the Convention (the Arbitration Act applies regardless of the country in which the award was made).[3]

1.3. Other international treaties

The 1965 Washington Convention on ICSID (ratified on 21 September 1993); bilateral treaties.[4]

2.1. Foreign judgements

The competent authority for the recognition and enforcement of foreign arbitral awards is the Supreme Court of Georgia (Article 2(1)(a) of the Arbitration Act, read in conjunction with Articles 44–45).[5]

2.2. Internal decisions

With regard to domestic awards (made in Georgia), the courts of appeal have jurisdiction over their recognition and enforcement, as well as over their annulment (Articles 42–43 of the Arbitration Act).[6]

2.3. Absence of a review on the merits and appeals

The Arbitration Act does not provide for a right of appeal on the merits, but does provide for the right to seek the setting aside of an award. When considering an application for setting aside, the court does not examine the merits of the case, does not establish the facts, and does not assess the evidence. The filing of an application for setting aside does not automatically stay the recognition and enforcement of the award — the judge makes the relevant decision upon a party’s application.[7]

3.1. Required documents

In accordance with Article IV of the New York Convention and the Arbitration Act, the following are attached:[8]

A duly certified original of the decision (for decisions made outside Georgia) or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

Translation into Georgian — the court requests this if a judgment or agreement is drawn up in a foreign language.

3.2. Timelines and costs

Proceedings usually last up to several months. A court fee (state duty) is payable in accordance with the Code of Civil Procedure — the rate depends on the amount of the claim (subject to verification). A foreign judgment is recognised and enforced by the Supreme Court of Georgia, whilst a domestic judgment (handed down in Georgia) is recognised and enforced by the courts of appeal; the difference between them lies in the competent court, rather than in the fundamental amount of the fee. In addition, there are costs for translation into Georgian and legal support. Specific rates are subject to verification at the time of filing.[9]

The grounds are limited and set out in Article 45 of the Arbitration Act (which mirrors Article V of the New York Convention).[10]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to review by the court (Article V(2))

Non-arbitrability of a dispute under Georgian law;

Contrary to public order in Georgia.

A practical point: the courts of appeal have partially enforced judgments awarding excessive liquidated damages against an individual under a loan agreement (for example, exceeding approximately 130 per cent of the principal debt), considering this a breach of public policy — in such cases, enforcement was granted only in reduced amounts. Georgian courts are unlikely to enforce punitive damages.[11]

When recognising and enforcing an arbitral award, the court issues an enforcement order together with the award. Enforcement is carried out through the National Bureau of Enforcement: seizure of property and bank accounts, and the realisation of the debtor’s assets.[12]

6.1. Tracing the debtor’s assets

Useful resources:

Register of Entrepreneurs and Non-Entrepreneurial Entities (NAPR): napr.gov.ge;

Public Land Registry — via the National Agency for Property Registration;

National Enforcement Bureau: nbe.gov.ge.

6.2. Practical advantages and obstacles

Broad scope: decisions from countries that are not parties to the Convention are also enforced;[3]

The Supreme Court for foreign judgments: recognition and enforcement are concentrated at the highest level;[5]

Excessive penalty / punitive: partial performance may be permitted on grounds of public policy.

7.1. Legislation and official sources

matsne.gov.ge — The Georgian Arbitration Act: matsne.gov.ge

New York Convention (Georgia): newyorkconvention.org

7.2. Registers

NAPR Register: napr.gov.ge

Enforcement Agency: nbe.gov.ge

7.3. Arbitration institutions

Georgian International Arbitration Centre (GIAC): www.giac.ge

Tbilisi Arbitration Institute; DRC.

7.4. Specialists in the enforcement of arbitral awards in Georgia

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Georgian Arbitration Act (enacted in 2009, in force since 2010; based on the UNCITRAL Model Law, as amended in 2006); The Civil Procedure Code of Georgia. matsne.gov.ge

[2] The Georgian Arbitration Act — awards are binding regardless of the country in which they are made; there is a limited list of grounds for setting aside an award.

[3] The 1958 New York Convention (Georgia is a party to the Convention, having ratified it without reservations); enforcement of judgments from non-party states.

[4] The 1965 Washington Convention on the Settlement of Investment Disputes (ratified by Georgia on 21 September 1993); bilateral treaties.

[5] The Georgian Arbitration Act, Articles 2(1)(a), 44–45 — Supreme Court of Georgia (foreign awards).

[6] The Georgian Arbitration Act, Articles 42–43 — courts of appeal (domestic awards; setting aside).

[10] The Georgian Arbitration Act, Article 45 (grounds for refusal, mirroring Article V of the Convention).

Case law

[11] IBA Arbitration Guide: Georgia — partial performance where the liquidated damages are excessive (>~130% of the principal debt); likely refusal to award punitive damages.

Analytical and reference materials

[7] Chambers — International Arbitration 2025, Georgia; IBA Arbitration Guide: Georgia (no review on the merits; annulment; non-automatic suspension).

[8] Chambers — Georgia; IBA Arbitration Guide: Georgia (documents; translation into Georgian upon the court’s request).

[9] IBA Arbitration Guide: Georgia (duration: up to several months).

[12] IBA Arbitration Guide: Georgia (issuance of an enforcement order); National Enforcement Bureau.

[5] Kluwer Arbitration Blog — New Arbitration Law in the Republic of Georgia (the Supreme Court’s jurisdiction over foreign awards).

1.1. Key legislation

The recognition and enforcement of foreign arbitral awards in Germany are governed by Book Ten of the Code of Civil Procedure (Zivilprozessordnung, ZPO) — §§ 1025–1066, in particular § 1061, which fully incorporates the 1958 New York Convention. Section 1060 of the ZPO applies to domestic (German) arbitral awards, whilst Section 1061 of the ZPO applies to foreign arbitral awards.

The current version of the ZPO is available free of charge on the official legal portal: www.gesetze-im-internet.de

Source: Section 1061(1) of the ZPO; ICLG Germany 2025–2026; Chambers International Arbitration 2025, Germany

1.2. The New York Convention

Germany is a party to the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards. The Convention was signed in 1958, ratified on 30 June 1961, and entered into force on 28 September 1961. In 1998, Germany withdrew its original reservation on reciprocity (Article I(3) of the Convention). Consequently, German courts are entitled to enforce arbitral awards made in states that are not parties to the Convention.

Source: Section 1061(1) of the ZPO; GAR Guide, 4th ed., Germany; ICLG Germany 2025–2026

1.3. Other international conventions

Germany is also a participant in:

the 1961 European Convention on International Commercial Arbitration (ECICA) — since 27 October 1964. The Convention restricts the application of the ground for refusal under Article V(1)(e) of the New York Convention (set-aside of an award): refusal is possible only on the four exhaustive grounds set out in Article IX of the ECICA;

the 1965 Washington Convention on ICSID — since 18 April 1969;

The Energy Charter Treaty (ECT) — the formal withdrawal came into force on 21 December 2023.

Source: GAR Guide, 4th ed., Germany; Chambers Investor-State 2025, Germany

1.4. Reform of arbitration legislation (2024–2026)

In June 2024, the German Federal Ministry of Justice introduced a bill to modernise arbitration law (Entwurf eines Gesetzes zur Modernisierung des Schiedsverfahrensrechts). The bill was not passed due to the snap elections in February 2025. On 27 January 2026, the Ministry resumed the legislative process by publishing an updated draft. As at the date of this guidance, the reform has not yet come into force. The 1997 version of the ZPO (as last amended) remains the legislation in force. Key proposed changes directly affecting the enforcement of awards:

Simplification of the requirements regarding the form of arbitration agreements (waiver of the requirement for written form, subject to certain conditions for commercial transactions);

The possibility of conducting related legal proceedings in English within the Commercial Courts;

Extension of the powers of German courts to enforce interim measures ordered by foreign arbitral tribunals.

Source: DIS — Modernisation of arbitration law (disarb.org); Reed Smith, March 2026; Hogan Lovells, February 2026; Freshfields, February 2026

2.1. The court of first instance

Applications for the recognition and enforcement of foreign arbitral awards are heard by the Higher Regional Courts (Oberlandesgericht, OLG) — § 1062(1) ZPO. These are regional courts (the appellate instance within the system of regional courts); there are 24 OLGs in Germany in total.

Source: § 1062(1)–(2) ZPO; trans-lex.org (English translation of the ZPO); GAR Guide, 4th ed., Germany

2.2. Determining jurisdiction in respect of foreign judgments

For foreign arbitral awards, jurisdiction is determined in accordance with the following rules (§ 1062(2) ZPO):

The court expressly specified in the arbitration agreement (if the parties have so agreed);

In the absence of any agreement — the OLG at the defendant’s place of business, place of residence or location of the defendant’s assets;

Where it is not possible to apply the above criteria, the Berlin Higher Regional Court (Kammergericht, KG Berlin) has subsidiary jurisdiction.

The provisions of Section 1062(2) of the ZPO are exhaustive: there are no other grounds for determining jurisdiction (BayObLG, judgment of 20 December 2023 — 102 SchH 218/23).

Source: Section 1062(2) of the ZPO; GAR Guide, 4th ed., Germany; Lexology

2.3. The position of the German courts

Germany is widely recognised as a pro-enforcement jurisdiction. German courts consistently:

uphold the prohibition on reviewing the decision on the merits (révision au fond) — BGH, SchiedsVZ 2024, 115;

place the burden of proving the grounds for refusal on the party objecting to enforcement — OLG Brandenburg, SchiedsVZ 2016, 43;

It is recognised that objections which could have been raised during the recognition proceedings but were not raised due to negligence cannot subsequently be raised in enforcement proceedings — LG Frankfurt, SchiedsVZ 2017, 206.

Source: GAR Guide, 4th ed., Germany; ICLG Germany 2025–2026

2.4. The Court of Appeal

A decision by the OLG may be appealed against on legal grounds only (Rechtsbeschwerde) to the Federal Court of Justice (Bundesgerichtshof, BGH) — Section 1065(1) of the Code of Civil Procedure (ZPO). Appeals based on the facts of the case are not permitted.

Source: Section 1065(1) of the ZPO; ICLG Germany 2025–2026

3.1. Production procedure

Proceedings for the recognition and issuance of a declaration of enforceability (Vollstreckbarerklärung) are initiated by the filing of an application (Antrag) — not a statement of claim — with the competent Higher Regional Court (OLG). The proceedings are not ex parte: the respondent must be notified and is entitled to raise objections — § 1063(1) ZPO.

Stages of implementation:

Stage 4: Initiating enforcement proceedings through the competent authorities (bailiff, Vollstreckungsgericht) in relation to a specific type of asset.

Source: GAR Guide, 4th ed., Germany; Chambers Enforcement of Judgments 2025

3.2. Required documents

The following documents are attached to the application pursuant to § 1064(1) of the ZPO and Article IV of the New York Convention:

The original of the arbitral award or a duly certified copy thereof — Section 1064(1) of the ZPO;

The original arbitration agreement (or a certified copy thereof) — Article IV(1)(b) of the Convention;

A certified translation of all documents into German, if the decision was issued in another language — Article IV(2) of the Convention, Section 1064(1) of the ZPO;

Signed copies of the application, one for each defendant, as well as ordinary copies — Section 1063(4) of the ZPO.

It should be noted that the application must be submitted in writing or recorded in the court registry’s minutes — § 1063(4) ZPO. The court is entitled, at the request of the claimant, to order interim measures — § 1063(3) ZPO.

Source: Sections 1063(4) and 1064(1) of the ZPO; Article IV of the New York Convention; iclg.com Germany 2025

3.3. Translation requirements

Translation of documents into German is mandatory — Article IV(2) of the New York Convention. The translation must be certified by an official or sworn translator, or by a diplomatic or consular authority. Uncertified translations will not be accepted.

Important: The proposed reform for 2024–2026 provided for the possibility of submitting documents in English without translation in proceedings before commercial courts. At present, this provision has not yet been adopted.

Source: Article IV(2) of the New York Convention; Cleary Gottlieb, July 2024; Norton Rose Fulbright

3.4. Legal costs

Court fees are determined in accordance with the Court Costs Act (Gerichtskostengesetz, GKG) and are calculated on a sliding scale depending on the value of the claim (proceedings for the enforcement of a judgment are subject to a court fee of 2.0 times the rate specified in No. 1620 KV GKG). The amount of the fee is the same for domestic (§ 1060 ZPO) and foreign (§ 1061 ZPO) judgments — there are no differences based on the type of judgment; the fee depends solely on the value of the claim. The ‘loser pays’ principle applies (§ 91 ZPO): the losing party must reimburse court fees and lawyers’ fees (within the limits of the statutory rates under the RVG).

Indicative amounts of court fees for the OLG at first instance:

Important: a claimant domiciled outside the EU/EEA is obliged, at the defendant’s request, to provide security for costs (§ 110 ZPO by analogy) — BGH, judgment of 12 January 2023 — I ZB 33/22. This rule applies, inter alia, to proceedings for the enforcement of an arbitral award.

Source: Lexology (Enforcement costs); APOS Legal 2026; Noerr, BGH I ZB 33/22 (2023); § 91 ZPO

3.5. Time limits for submitting an application and limitation periods

German law does not specify a specific time limit for lodging an application for the recognition and enforcement of a foreign arbitral award.

However, the general limitation period applicable to enforcement proceedings must be taken into account: pursuant to Section 197(1) of the BGB (German Civil Code), the limitation period for enforcement proceedings is 30 years from the date on which the judgment becomes final. Once an enforcement order has been issued in Germany, a separate 30-year period for its enforcement begins to run.

Source: Section 197(1) of the German Civil Code (BGB); GAR Guide, 4th ed., Germany (no time limit for application)

Pursuant to § 1061(1) of the ZPO, the grounds for refusal set out in Article V of the New York Convention apply exclusively to foreign judgments. The list is exhaustive.

4.1. Pleas raised by the respondent (Article V(1) of the Convention)

The court is entitled to refuse to recognise and enforce a judgment at the request of the defendant where there is evidence:

(a) The legal incapacity of a party to the arbitration agreement or the invalidity of the agreement under applicable law;

(b) Failure to provide proper notice of the appointment of an arbitrator or of the progress of the proceedings, or any other inability to present one’s case;

(c) the arbitral award going beyond the scope of the dispute as set out in the arbitration agreement;

(d) The composition of the arbitral tribunal or the procedure for the proceedings is not in accordance with the parties’ agreement;

(e) The decision has not yet taken legal effect, or has been set aside or suspended by the competent authority of the State in which it was made.

Important: the burden of proof regarding the grounds specified lies exclusively with the respondent — OLG Brandenburg, SchiedsVZ 2016, 43. Grounds which could have been raised during the recognition proceedings but were not raised due to negligence cannot subsequently be relied upon — LG Frankfurt, SchiedsVZ 2017, 206.

Source: Article V(1) of the New York Convention; § 1061(1) of the ZPO; GAR Guide, 4th ed.

4.2. Grounds examined by the court of its own motion (Article V(2) of the Convention)

(a) The subject matter of the dispute cannot be referred to arbitration under German law (non-arbitrability);

(b) Recognition or enforcement would be contrary to German public policy (ordre public).

German courts interpret the concept of a breach of public policy narrowly. The court considers only the most significant procedural irregularities that have influenced the outcome of the case — OLG Karlsruhe, SchiedsVZ 2022, 291.

Source: Article V(2) of the New York Convention; § 1061(1) of the ZPO

4.3. Special case: a judgment set aside in the country in which it was made

If a judgment has been set aside by a competent authority in the State in which it was given (Article V(1)(e) of the Convention), a German court will, as a rule, refuse to enforce such a judgment. However, the court is not limited to merely noting the fact of the setting aside — it may carry out its own assessment of the lawfulness of the setting aside: In the case BGH III ZB 14/07 of 21 May 2008, the OLG Dresden carried out a substantive review and refused to enforce the judgment.

However, where both parties are situated in States party to the 1961 European Convention (ECICA), the grounds for refusal under Article V(1)(e) of the Convention are limited to the four exhaustive grounds set out in Article IX of the ECICA.

Source: Clyde & Co, April 2022; BGH III ZB 14/07; GAR Guide, 4th ed.

A decision by the Higher Regional Court (OLG) on matters of arbitration, including a refusal to declare a foreign award enforceable, may be appealed on points of law (Rechtsbeschwerde) exclusively to the Federal Court of Justice (BGH) — Section 1065(1) of the Code of Civil Procedure (ZPO). There is no provision for an appeal on the facts of the case.

The lodging of a Rechtsbeschwerde does not automatically suspend enforcement. The court is entitled, at its discretion, to suspend proceedings until the case has been decided on its merits — § 148 ZPO. In doing so, the court weighs up the prospects of success of the appeal against the harm caused by a delay in enforcement — BGH, NJW-RR 1992, 1149.

Source: Section 1065(1) of the ZPO; GAR Guide, 4th ed., Germany

At the request of the claimant, the OLG is entitled to order interim measures during proceedings to declare a judgment enforceable — § 1063(3) ZPO. This power rests with the presiding judge of the relevant panel of the OLG. The court exercises its discretion, taking into account:

The prospects of success for an application for a declaration of enforceability;

Potential damage to the debtor;

The risk of the debtor taking action to obstruct enforcement.

Once the decision to give legal effect to the judgement has come into force, enforcement is carried out through the following authorities (depending on the type of assets):

Immovable property: a charge for the purposes of enforcement, registered in the land register (§ 867 ZPO); the amount to be recovered must exceed €750, excluding interest (§ 866(3) ZPO);

Movable property: the bailiff at the location of the property (Section 808 of the ZPO);

Bank accounts, accounts receivable: attachment and assignment of claims (Pfändungs- und Überweisungsbeschluss) through the enforcement court — Section 828 of the Code of Civil Procedure (ZPO).

Source: § 1063(3) ZPO; §§ 866–867 ZPO; §§ 808, 828 ZPO; Chambers Enforcement 2025

7.1. Indicative timelines

There are no specific official statistics on cases concerning the recognition of foreign arbitral awards available to the public. According to a study by Professor Reinmar Wolf (data from 2012–2016, commissioned by the Federal Ministry of Justice), the average duration of arbitration cases in German courts was 172.9 days (~5–6 months). In practice, straightforward cases can be resolved within 3–4 months, whilst more complex cases may take 9 months or longer.

Source: Legal500 Germany International Arbitration; Chambers 2025

7.2. Mandatory legal representation

Legal representation (Anwaltszwang) is mandatory before the Higher Regional Court (OLG) and the Federal Court of Justice (BGH) — Section 78 of the Code of Civil Procedure (ZPO). For foreign parties, this means that they must engage a German lawyer (Rechtsanwalt) who is authorised to practise before the relevant court.

Source: Section 78 of the ZPO; se-legal.de, German Civil Procedure Guide 2026

7.3. Enforcement in respect of natural persons

Enforcement against individuals is possible, but there are significant particularities:

In order to determine the competent court under Section 1062(2) of the ZPO, it is necessary to establish the debtor’s place of residence or the location of their assets in Germany;

A German bailiff (Gerichtsvollzieher) carries out enforcement proceedings in respect of movable property at the debtor’s place of residence;

Data from the Population Register (Einwohnermeldeamt) makes it possible to establish an individual’s official residential address;

A special procedure applies to wage garnishment, based on the tables setting out the minimum subsistence allowance (Pfändungsfreigrenzen).

Source: Sections 808, 828 and 850 of the ZPO; Chambers Enforcement 2025

7.4. Payment of legal costs by a foreign claimant

If the claimant is domiciled outside the EU/EEA, the defendant is entitled to demand security for legal costs (Sicherheitsleistung) — §§ 110 et seq. ZPO by analogy. This rule was confirmed by the Federal Court of Justice (BGH) in its judgment of 12 January 2023 (I ZB 33/22) and applies to proceedings for the enforcement of an arbitral award.

Source: BGH, I ZB 33/22, 12 January 2023; Noerr Client Alert

7.5. Use of information from commercial registers

To establish the location, registered office or registration details of a corporate debtor, please consult Germany’s Federal Electronic Commercial Register:

Commercial Register: www.handelsregister.de (free access to basic data);

Electronic extract from the register (ZEFIX equivalent): www.unternehmensregister.de;

Official Gazette: www.bundesanzeiger.de.

Source: handelsregister.de; unternehmensregister.de

7.6. Practical obstacles

Despite the high degree of legal certainty, practice has revealed a number of typical difficulties:

Apostille requirement: The New York Convention does not require an apostille for an arbitral award; however, in practice, a number of German courts may request further information regarding the authenticity of documents. It is advisable to check the requirements of the specific OLG in good time;

Notarisation of translations: translations may be certified by either an official or a sworn translator; requirements may vary depending on the OLG;

Advance payment of legal costs for claimants from countries outside the EU/EEA: see section 7.4 of these guidelines;

Where the debtor has no assets in Germany: it is advisable to carry out a preliminary search for assets (bank accounts, property, shares in companies) with the assistance of a local solicitor before filing the application.

8.1. Legislation

ZPO (GPK) in German: www.gesetze-im-internet.de/zpo/

ZPO (English translation): www.trans-lex.org/600550

The New York Convention: www.newyorkconvention.org/countries/germany

Court costs (GKG): www.gesetze-im-internet.de/gkg_2004/

8.2. Registers and databases

German Commercial Register: www.handelsregister.de

Unified Register of Enterprises: www.unternehmensregister.de

Federal Gazette: www.bundesanzeiger.de

Legal costs calculator: www.e-justice.europa.eu (Germany section)

8.3. Leading arbitration institutions

German Arbitration Institute (DIS): www.disarb.org

International Chamber of Commerce in Germany (ICC): www.iccgermany.de

8.4. Specialists in the enforcement of arbitral awards in Germany

A list of recommended specialists in the recognition and enforcement of arbitral awards in Germany is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

1.1. The dualistic system

Greek law distinguishes between domestic and international arbitration. International commercial arbitration with a seat in Greece is governed by Law 5016/2023 (in force since the beginning of 2023), which replaced Law 2735/1999 and is based on the 2006 version of the UNCITRAL Model Law. Domestic arbitration is governed by Book VII of the Code of Civil Procedure (CCP), Articles 867–903.[1]

The recognition and enforcement of foreign judgments are governed by the New York Convention, in conjunction with Articles 903, 905 and 906 of the Code of Civil Procedure.[2]

1.2. The New York Convention

Greece ratified the 1958 New York Convention by Legislative Decree 4220/1961 (accession — 14 October 1962), whilst retaining reservations regarding reciprocity and the commercial nature of the Convention. Pursuant to Article 28 of the Constitution, the Convention has the force of law and takes precedence over Articles 903, 905 and 906 of the Code of Civil Procedure.[3]

A key feature: Article 45 of Law 5016/2023 extends the application of the Convention to the enforcement of any foreign arbitral award, including those not falling within its scope (for example, those rendered in a state that is not a party to the Convention), which negates the effect of the reciprocity clause.[4]

1.3. Other international treaties

The 1923 Geneva Protocol and the 1927 Geneva Convention (L. 5013/1931);

The 1965 Washington Convention on ICSID; bilateral treaties. Greece is NOT a party to the 1961 European Convention.[5]

2.1. The Court

An application for the recognition and enforcement of a foreign judgment is lodged with the single-judge court of first instance (μονομελές πρωτοδικείο) at the debtor’s place of residence or abode. If the debtor has no domicile or place of residence in Greece, the Court of First Instance of Athens has jurisdiction (Articles 905(1) and 906 of the Code of Civil Procedure).[6]

2.2. Nature of the procedure

The proceedings are conducted as special (non-contentious) proceedings under Articles 740–781 of the Code of Civil Procedure; that is to say, as a rule, on an ex parte basis. The court is not entitled to review the case on its merits (prohibition of révision au fond).[7]

2.3. Appeals

A decision by a single-judge court of first instance may be appealed in accordance with the general rules (Court of Appeal, hereinafter referred to as the Supreme Court, Άρειος Πάγος).[8]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are annexed:[9]

A certified original of the arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A duly certified translation of all documents into Greek.

The application must comply with the requirements of Articles 68, 73, 118 and 216 of the Code of Civil Procedure (identification and standing of the parties, etc.).[9]

3.2. Legal costs

Court fees and stamp duty are payable in accordance with the general rules when filing a claim with a single-judge court of first instance (subject to verification). A domestic (rendered in Greece) arbitral award is an enforceable document under the Code of Civil Procedure and is enforced in accordance with the same rules of enforcement; the difference compared with a foreign award lies in the need for a declaration of enforceability under the New York Convention (Articles 903, 905 and 906 of the Code of Civil Procedure), rather than in the fundamental amount of the fees. In addition, there are costs for certified translations of all documents into Greek and legal support. The specific amounts are subject to verification at the time of submission.[6]

The grounds set out in Article V of the New York Convention apply: the party against whom the award is made is entitled to adduce evidence in support of the grounds under Article V(1), whilst the court examines the grounds under Article V(2) of its own motion. Pursuant to Articles 903, 905(1), 906 of the Code of Civil Procedure, the court shall also examine the validity of the arbitration agreement, the arbitrability of the claim, the absence of any conflict with a Greek court judgment having the force of res judicata, and compliance with public policy and public morals.[10]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or failure to state one’s position;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to review by the court (Article V(2))

Non-arbitrability of a dispute under Greek law;

Contrary to public order (and public morality).

4.3. A decision set aside abroad

There is no published case law on the enforcement of judgments set aside abroad; the prevailing view in Greek legal doctrine is that such judgments are not subject to recognition.[11]

Under Law 5016/2023, an arbitral tribunal is entitled to order interim measures; the grounds for refusing to recognise or enforce such measures are limited to a breach of public policy. Interim measures ordered by arbitrators are enforced through the state courts.[12]

Once the judgment has been declared enforceable, it is enforced in accordance with the rules on enforcement set out in the Code of Civil Procedure, through a bailiff (δικαστικός επιμελητής): seizure of property and bank accounts, and the realisation of assets.

6.1. Tracing the debtor’s assets

Useful resources:

General Commercial Register (ΓΕΜΗ / GEMI): www.businessportal.gr;

Land Registry (Κτηματολόγιο): www.ktimatologio.gr;

Register of mortgages and encumbrances — via mortgage bureaux/the Land Registry.

6.2. Practical advantages and obstacles

Broad scope: Article 45 of Law 5016/2023 extends the Convention’s regime to all foreign judgments;[4]

Translation: a certified translation of all documents into Greek is required — please allow for the time and cost involved;

The 2023 reform: a modern pro-arbitration law enhances predictability.

7.1. Legislation and official sources

National Printing House — Law 5016/2023: et.gr

The New York Convention (Greece): newyorkconvention.org

7.2. Registers

GEMI Commercial Register: www.businessportal.gr

Cadastral register: www.ktimatologio.gr

7.3. Arbitration institutions

Athens Chamber of Commerce and Industry (Arbitration): www.acci.gr

Piraeus Maritime Arbitration Association: www.pamaclub.gr

7.4. Specialists in the enforcement of arbitral awards in Greece

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] Law 5016/2023 on International Commercial Arbitration (in force since 2023, based on the 2006 UNCITRAL Model Law); Greek Code of Civil Procedure, Book VII, Articles 867–903. et.gr

[2] The Greek Code of Civil Procedure, Articles 903, 905 and 906 (as well as Articles 68, 73, 118, 216 and 740–781).

[3] The 1958 New York Convention (Greece — Legislative Decree 4220/1961, accession 14 October 1962; reservations regarding reciprocity and commercial matters); Article 28 of the Constitution.

[4] Article 45 of Law 5016/2023 — extension of the Convention’s scope to all foreign judgments.

[5] The 1923 Geneva Protocol, the 1927 Geneva Convention (L. 5013/1931); the 1965 ICSID Washington Convention

Case law

[11] The Greek doctrine (the prevailing view) — non-recognition of judgments set aside abroad; no published case law.

Analytical and reference materials

[6] IBA Arbitration Guide: Greece (2025); Lexology — Arbitration awards in Greece (competent court, Articles 905 and 906 of the Code of Civil Procedure).

[7] Lexology — Litigation: Enforcement of foreign judgments in Greece (ex parte, Articles 740–781 of the Code of Civil Procedure).

[8] Chambers — International Arbitration 2025, Greece (appeal; prohibition on révision au fond).

[9] Lexology — Comprehensive guidance on the recognition and enforcement of foreign arbitral awards (Article IV of the Convention; Articles 68, 73, 118 and 216 of the Code of Civil Procedure).

[10] Lexology — Greece (based on Articles 903, 905(1) and 906 of the Code of Civil Procedure and Article V of the Convention).

[12] Global Legal Insights — International Arbitration 2026, Greece; American Review of International Arbitration — Unpacking the New Greek Law (interim measures; Article 45).

1.1. Key legislation

Arbitration in Hong Kong is governed by the Arbitration Ordinance (Cap. 609, HKAO), which is based on the UNCITRAL Model Law and applies a single regime to both domestic and international arbitration. The recognition and enforcement of awards are governed by Part 10 of the HKAO.[1]

The HKAO sets out procedures for four categories of awards: those made in Hong Kong; awards under the New York Convention (Convention awards); awards from mainland China (Mainland awards); and awards from Macao. All of these are enforced in the same way as Hong Kong court judgments.[2]

1.2. The New York Convention

Hong Kong applies the New York Convention through the participation of the People’s Republic of China (subject to reservations regarding reciprocity and the commercial nature of the award). The procedure for enforcing a Convention award is set out in Section 2 of Part 10 of the HKAO. The grounds for refusal correspond to Article V of the Convention and are interpreted narrowly by the Hong Kong courts; consequently, awards are generally enforced.[3]

1.3. Mainland China and Macao

Decisions made by mainland China are implemented in accordance with a special arrangement between Hong Kong and the PRC. The Supplemental Arrangement, which was fully implemented by the Arbitration (Amendment) Ordinance 2021 (in force since 19 May 2021), has removed the previous ban on parallel applications for enforcement: it is now possible to pursue enforcement simultaneously in the courts of mainland China and Hong Kong, which helps in recovering debts from debtors with assets in both jurisdictions.[4]

2.1. The Court

An application for an enforcement order is filed with the Court of First Instance of the High Court of Hong Kong.[5]

2.2. Nature of the procedure

An application for enforcement is made on an ex parte basis; where necessary, the court may summon the other party to take part in an inter partes hearing. The proceedings for recognition and enforcement are themselves adversarial in nature.[6]

3.1. Required documents

In accordance with Article 85 of the HKAO (for Convention awards — Article 88; for mainland awards — Article 94; for Macau awards — Article 98C), the following are attached:[7]

A certified original of the arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A translation into one of Hong Kong’s official languages (English or Chinese), certified by an official or sworn translator or by a diplomatic or consular officer, if the decision is drawn up in another language.

3.2. Limitation period

Under section 4(1) of the Limitation Ordinance, the limitation period is six years if the arbitration agreement is not ‘sealed’; if it is sealed, the period is twelve years (Wang Peiji v Wei Zhiyong [2019] HKCFI 2593).[8]

3.3. Legal costs

A court fee is payable when applying to the Court of First Instance for a declaration of enforceability, in accordance with the Hong Kong High Court’s scale of fees (usually a fixed fee; subject to verification). Judgments in all four categories (those made in Hong Kong, Convention awards, and those from Mainland China and Macau) are enforced under the uniform regime of Part 10 of the HKAO as judicial orders — there is no difference in the amount of the fee between domestic and foreign judgments. In addition, there are costs for translation (into English or Chinese) and legal assistance. Specific rates are subject to verification at the time of filing.[5]

The grounds are in accordance with Article V of the New York Convention and are interpreted narrowly.[9]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or failure to state one’s position;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article V(2))

The dispute is not subject to arbitration under Hong Kong law;

Contrary to public policy in Hong Kong (section 95(3) of the HKAO).

A key advantage of Hong Kong is the Interim Measures Arrangement with the PRC: the parties to arbitration administered by recognised Hong Kong institutions (in particular the HKIAC) may apply to the courts of mainland China for interim measures. Once a decision has been made, enforcement in Hong Kong is carried out in accordance with a court order: seizure of property and bank accounts, and the realisation of the debtor’s assets.[10]

6.1. Tracing the debtor’s assets

Useful resources:

Companies Registry: www.cr.gov.hk;

Land Registry: www.landreg.gov.hk;

The Hong Kong judicial system (in practice): www.judiciary.hk.

6.2. Practical advantages and obstacles

Gateway to the Chinese market: parallel operations in Hong Kong and mainland China;[4]

Interim measures in the PRC: available in arbitration under the auspices of the HKIAC;[10]

Limitation period: allow for 6 years (or 12 years if the agreement is ‘under seal’).

7.1. Legislation and official sources

Hong Kong e-Legislation — Cap. 609: www.elegislation.gov.hk

The New York Convention (Hong Kong/PRC): newyorkconvention.org

7.2. Registers

Company Register: www.cr.gov.hk

Land Registry: www.landreg.gov.hk

7.3. Arbitration institutions

Hong Kong International Arbitration Centre (HKIAC): www.hkiac.org

7.4. Specialists in the enforcement of arbitral awards in Hong Kong

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] Hong Kong Arbitration Ordinance (Cap. 609, HKAO), Part 10; based on the UNCITRAL Model Law. elegislation.gov.hk

[2] HKAO — four categories of awards (Hong Kong, Convention award, Mainland award, Macau); Article 2 (definitions).

[3] The 1958 New York Convention (via the PRC; reservations regarding reciprocity and commercial matters); Section 2 of Part 10 of the HKAO; Article 95(3) of the HKAO (public policy).

[4] Arbitration (Amendment) Ordinance 2021 (in force since 19 May 2021) — repeal of section 93 of the HKAO; parallel enforcement in Hong Kong and mainland China (Supplemental Arrangement).

[7] HKAO, section 85 (documents), 88 (Convention award), 94 (Mainland award), 98C (Macao).

Case law

[8] Wang Peiji v Wei Zhiyong [2019] HKCFI 2593 — limitation period of 6/12 years (Limitation Ordinance, section 4(1)).

Analytical and reference materials

[5] CMS Expert Guides — Hong Kong (Court of First Instance; unified system).

[6] Global Arbitration Review — Hong Kong (ex parte; inter partes; adversarial).

[9] Lexology — In brief: enforcing and challenging arbitral awards in Hong Kong (grounds under Article V of the Convention; narrow interpretation).

[10] Global Arbitration Review — Hong Kong; Interim Measures Arrangement between Hong Kong and the People’s Republic of China (HKIAC).

1.1. Key legislation

Arbitration is governed by Act LX of 2017 on Arbitration (Act LX of 2017 on Arbitration), which came into force on 1 January 2018 and is based on the 2006 version of the UNCITRAL Model Law. The recognition and enforcement of foreign awards are also governed by Act XXVIII of 2017 on Private International Law (Conflict of Laws Code) and the New York Convention.[1]

Under Section 205 of the Enforcement Act (Vht.), foreign judgments, including arbitral awards, are enforced on the basis of the law, an international treaty or the principle of reciprocity. The Enforcement Act applies in the same way as it does to the enforcement of final court judgments.[2]

1.2. The New York Convention

Hungary acceded to the New York Convention in 1962 (incorporated by Decree-Law No. 25 of 1962), entering reservations regarding reciprocity and the commercial nature of the relationship (Article I(3)). Following the 2017 reform, the term ‘commercial’ is interpreted broadly — to cover virtually any relationship connected with trade or business, in accordance with the 2006 Model Law.[3]

1.3. Other international treaties

Hungary ratified the 1961 European Convention (Decree-Law No. 8 of 1964). Article IX thereof, in relations between States Parties to both Conventions, limits the application of Article V(1)(e) of the New York Convention to the cases listed in Article IX(1) of the European Convention.[4]

2.1. Recognition and Exequatur

The recognition of a foreign judgment does not require a separate procedure. An exequatur is required for enforcement: pursuant to Section 208 of the Enforcement Act, provided the conditions for recognition are met, the court shall attach a certificate of enforceability (exequatur) to the original judgment, confirming that the judgment is enforceable in Hungary in the same way as a domestic judgment.[5]

2.2. The Court

An application for recognition and enforcement must be lodged with the competent regional court (törvényszék). The initial decision to grant or refuse exequatur may be appealed to the Regional Court of Appeal (ítélőtábla) in the jurisdiction of the relevant regional court.[6]

2.3. Separate enforcement proceedings

Once the exequatur becomes final, the claimant initiates separate enforcement proceedings and applies to the court for an enforcement order authorising the attachment of the debtor’s assets.[6]

3.1. Required documents

Pursuant to section 207 of the Enforcement Act and Article IV of the New York Convention, the following are attached:[7]

The original arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A certified translation into Hungarian, if the documents are in another language.

Hungarian courts take a formalistic approach to compliance with the formal requirements of Article IV and to translation; however, any defects can generally be remedied (the court orders the lower court to conduct a new hearing, during which the claimant rectifies the deficiencies). On the grounds of Article V, the approach is consistently pro-arbitration.[8]

3.2. Timeframe and costs

There is no time limit for lodging an application for recognition; the limitation period applicable to the principal claim applies to enforcement. The procedural fee for enforcement is 1 per cent of the amount of the claim (minimum 5,000, maximum 350,000 forints), plus the enforcement officer’s fees. This fee is the same for domestic (judgements rendered in Hungary) and foreign judgements; the difference being that a foreign judgment requires exequatur (a certificate of enforceability under Section 208 of the Vht.), whereas a domestic judgment is directly enforceable. In addition, there are costs for a certified translation into Hungarian and legal support.[9]

For foreign awards, the grounds set out in Article V of the New York Convention (incorporated by Decree-Law No. 25 of 1962) apply. Hungarian courts interpret these provisions in a pro-arbitration manner.[10]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or failure to state one’s position;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to review by the court (Article V(2))

Non-arbitrability of the dispute under Hungarian law;

Contrary to public order.

According to established practice, a refusal on grounds of public policy is possible only if recognition would have consequences beyond the relationship between the parties and would manifestly or seriously infringe fundamental rights, public values or the socio-economic order. The mere fact of challenging an award at the seat of arbitration (without suspending its enforceability) does not constitute grounds for a ‘suspended award’ under Article V(1)(e).[11]

Once the enforcement order has been obtained, enforcement is carried out by a court enforcement officer (önálló bírósági végrehajtó): seizure of property and bank accounts, and the realisation of the debtor’s assets.[6]

Practical recommendation: when selecting Hungary as the place of arbitration, consideration should be given to the possibility of a ‘retrial’ provided for in Chapter IX of Act LX of 2017, which is not in line with international practice; given its questionable impact on the enforceability of final awards, it is recommended that its application be excluded in the arbitration agreement.[12]

6.1. Tracing the debtor’s assets

Useful resources:

Company Register (Cégjegyzék): www.e-cegjegyzek.hu;

Land Registry (Földhivatal / Takarnet) — via the authorised bodies;

Chamber of Bailiffs (MBVK): www.mbvk.hu.

6.2. Practical advantages and obstacles

Formalism regarding documents: a strict approach to the formalities of Article IV and the translation — this can be remedied, but it causes delays;[8]

Certificate on the original: the exequatur is issued as a certificate attached to the original decision;

Chapter IX (retrial): It is recommended that Hungary be excluded as a possible place of arbitration.

7.1. Legislation and official sources

National Legislation Database — Act LX of 2017: njt.hu

New York Convention (Hungary): newyorkconvention.org

7.2. Registers

Company Register: www.e-cegjegyzek.hu

MBVK Performers’ Chamber: www.mbvk.hu

7.3. Arbitration institutions

Commercial Arbitration Court attached to the Hungarian Chamber of Commerce and Industry: mkik.hu

7.4. Specialists in the enforcement of arbitral awards in Hungary

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] Act LX of 2017 on Arbitration (2017. évi LX. törvény, in force since 1 January 2018); Act XXVIII of 2017 (Private International Law). njt.hu

[2] Enforcement Act (Vht.), §§ 205, 207, 208; Act CXXX of 2016 (Civil Procedure Code); Act V of 2013 (Civil Code).

[3] The 1958 New York Convention (Hungary — accession in 1962; Decree-Law No. 25 of 1962; reservations regarding reciprocity and commercial matters).

[4] The 1961 European Convention (Decree-Law No. 8 of 1964), Article IX.

Case law

[11] Hungarian case law on Article V of the Convention (public policy; ‘suspended decision’); review by the Kluwer Arbitration Blog (2019).

Analytical and reference materials

[5] Jus Mundi — Enforcement of Foreign Arbitral Awards in Hungary (Section 208 of the Hungarian Code of Civil Procedure; certificate of enforceability).

[6]

[7] Jus Mundi — Hungary (Section 207 of the Civil Code; Article IV of the Convention).

[8] Kluwer Arbitration Blog — The New York Convention in Hungarian Court Practice (formalism under Article IV; remediability of defects).

[9] Lexology — First-step analysis: arbitration in Hungary (1% enforcement fee; time limits).

[10] Global Arbitration Review — Commercial Arbitration: Hungary (DLA Piper); Article V of the Convention.

[12] Global Arbitration Review — Hungary (Chapter IX of Act LX of 2017 — recommendation to exclude retrials).

1.1. Key legislation

The recognition and enforcement of foreign arbitral awards in India are governed by the Arbitration and Conciliation Act, 1996, Part II. Chapter I (sections 44–52) gives effect to awards under the New York Convention; Chapter II – to awards under the 1927 Geneva Convention.[1]

Article 44 defines a ‘foreign award’ as an arbitral award in disputes arising out of legal relationships (whether contractual or not) deemed to be commercial under Indian law, provided that: (i) the award is made pursuant to a written arbitration agreement to which the Convention applies; and (ii) it is made in a territory ‘notified’ by the Central Government as a territory party to the Convention (the requirement of reciprocity).[2]

1.2. The New York Convention

India is a party to the 1958 New York Convention, subject to reservations regarding reciprocity and the commercial nature of the matter. A judgment is recognised as foreign only if it was given in a country classified by the Central Government as a participating territory.[3]

2.1. The Court

Following the 2015 amendments, the High Court of the relevant state is the competent authority for the enforcement of foreign judgments (section 2(1)(e)). The procedure generally consists of a single composite proceeding combining recognition and enforcement (Fuerst Day Lawson Ltd v Jindal Exports Ltd), without the need for several separate stages.[4]

2.2. No review on the merits

When considering objections under Article 48, an Indian court does not review the merits of the dispute and does not act as an appellate court in relation to the courts of the place of arbitration; it merely examines, on its own, whether there are grounds for refusal (Vijay Karia v Prysmian Cavi). If the award is declared enforceable, it is deemed to be a decree of the court under Article 49.[5]

3.1. Required documents

In accordance with Article 47 of the Act (and Article IV of the Convention), the following must be attached to the application:[6]

The original arbitration award or a duly certified copy thereof;

The original arbitration agreement or a certified copy thereof;

Evidence that the decision was made abroad and, where necessary, a certified translation into English.

The Supreme Court (P.E.C. Limited v Austbulk Shipping, 2018) held that the word ‘shall’ in Article 47(1) should be interpreted as ‘may’ at the stage of filing — a lack of documents at the initial stage does not necessarily lead to a refusal.[7]

3.2. Limitation period

The Arbitration Act does not specify a time limit; however, the Supreme Court has clarified that Article 137 of the Schedule to the Limitation of Actions Act 1963 applies — three years from the date on which the right to enforcement arose. Court costs: when filing an application with the High Court, a court fee is payable in accordance with the relevant state’s Court Fees and Tariffs Act — usually an ad valorem charge based on the amount of the claim, often subject to a cap (rates vary by state; subject to verification). A foreign judgment is recognised and enforced through a single consolidated proceeding in the High Court of the state; a domestic (Indian) judgment does not require separate recognition — it is enforced as a decree under section 36 of the 1996 Act in the ordinary enforcement court. Additionally: costs for a certified translation into English and legal assistance. Amounts are subject to verification at the time of filing.[8]

The grounds are set out in Article 48 and are consistent with Article V of the New York Convention; they are interpreted narrowly.[9]

4.1. Grounds based on the debtor’s application (Article 48(1) / Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or failure to state one’s position;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article 48(2) / Article V(2))

Non-arbitrability of a dispute under Indian law;

Contrary to public policy in India (narrow interpretation; the word ‘otherwise’ in Article 48(1)(b) is not interpreted broadly under the ejusdem generis principle).

Provisional protection of assets may be granted pending enforcement: the courts have permitted the application of Article 9 to preserve assets in the run-up to enforcement under Article 48 (Aircon Beibars FZE v Heligo Charters), so that the claimant is not left without a means of redress due to the removal of assets. Once a judgment has been declared enforceable, it is enforced in the same way as a court order: seizure and realisation of property, and attachment of the debtor’s accounts and assets.[10]

6.1. Tracing the debtor’s assets

Useful resources:

Ministry of Corporate Affairs (MCA21): www.mca.gov.in;

CERSAI Register of Security Interests: www.cersai.org.in;

eCourts judicial database: ecourts.gov.in.

6.2. Practical advantages and obstacles

Requirement for a ‘notified’ territory: check whether the country where the arbitration is to take place is classified as a Convention territory;[2]

Unified proceedings: recognition and enforcement are combined;[4]

3-year time limit: please observe the time limit set out in section 137 of the Limitation Act.

7.1. Legislation and official sources

India Code — Arbitration and Conciliation Act, 1996: www.indiacode.nic.in

The New York Convention (India): newyorkconvention.org

7.2. Registers

Ministry of Corporate Affairs: www.mca.gov.in

CERSAI: www.cersai.org.in

7.3. Arbitration institutions

Indian Council of Arbitration (ICA): www.icaindia.co.in

Mumbai Centre for International Arbitration (MCIA): www.mcia.org.in

7.4. Specialists in the enforcement of arbitral awards in India

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Arbitration and Conciliation Act, 1996, Part II, Chapter I (sections 44–52). indiacode.nic.in

[2] The 1996 Act, section 44 (definition of ‘foreign award’; commercial nature; ‘notified’ territory).

[3] The 1958 New York Convention (India — reservations regarding reciprocity and commercial matters).

[6] The 1996 Act, section 47 (documents); Article IV of the New York Convention.

[8] The Limitation Act 1963, Article 137 of the Schedule (3 years) — interpretation by the Supreme Court.

Case law

[4] Fuerst Day Lawson Ltd v Jindal Exports Ltd (joined proceedings); 2015 amendments (High Court).

[5] Vijay Karia v Prysmian Cavi e Sistemi SRL (2020 SCC OnLine SC 177) — no review on the merits; section 49.

[7] P.E.C. Limited v Austbulk Shipping (2018) — interpretation of ‘shall’ in Article 47(1) as ‘may’.

[10] Aircon Beibars FZE v Heligo Charters Pvt Ltd (application of Article 9 to protect assets).

Analytical and reference materials

[9] Bar and Bench; SCC Times; ATB Legal — Enforcement of Foreign Arbitral Awards in India (Article 48 = Article V of the Convention; narrow interpretation).

1.1. Key legislation

Arbitration in Ireland is governed by the Arbitration Act 2010, which came into force on 8 June 2010 and repealed the previous Acts of 1954, 1980 and 1998. The Act applies to both domestic and international arbitration.[1]

The UNCITRAL Model Law (as amended in 2006) is incorporated in full as Annex 1; Article 6 of the Act confers the force of law upon it within the State. The recognition and enforcement of foreign judgments are governed by Articles 35 and 36 of the Model Law and the New York Convention, whilst the procedure is set out in Article 23 of the 2010 Act.[2]

1.2. The New York Convention

Ireland acceded to the 1958 New York Convention in 1981, without any reservations. The Convention was brought into force by Schedule 2 to the Act of 2010; section 24(1) confirms its force of law.[3]

1.3. Other international treaties

The 1923 Geneva Protocol (Annex 5) and the 1927 Geneva Convention (Annex 4);

The 1965 Washington Convention on ICSID (Annex 3).[4]

1.4. Domestic and foreign rulings

The rules governing the enforcement of domestic and foreign judgments are the same (Article 35 of the Model Law). However, Articles 35 and 36 of the Model Law do not apply to judgments given in Ireland (Article 23(4) of the Act): in the case of a domestic judgment, the only remedy available to an aggrieved party is an application for setting aside under Article 34 of the Model Law.[5]

2.1. The Court

The High Court has jurisdiction. It maintains a specialised Arbitration List, which is administered by the President of the High Court or a judge appointed by him (section 9 of the Act). The procedure is also governed by Order 56, Rule 3 of the Rules of the Superior Courts.[6]

2.2. Method of performance

Under Article 23(1) the 2010 Act, an arbitral award is enforceable in the State either by bringing an action or with the leave of the High Court — in the same manner as a judgment or order of that court, and with the same effect; where leave is granted, a court judgment may be made in the terms of the arbitral award.[7]

An application for leave is made by way of an originating notice of motion, accompanied by an affidavit setting out the grounds for the jurisdiction of the Irish courts to enforce the judgment.[8]

2.3. The position of the Irish courts

The Irish courts have consistently upheld the enforcement of arbitral awards; most objections are dismissed, and there is a strong presumption in favour of the award. Recent High Court decisions have reaffirmed Ireland’s reputation as a reliable pro-arbitration jurisdiction.[9]

3.1. Required documents

In accordance with Article 35(2) of the Model Law and Article IV of the New York Convention, the following shall be attached to the application:[2]

The original arbitration award or a certified copy thereof;

Arbitration agreement (original or certified copy);

An affidavit establishing jurisdiction and the grounds for enforcement;

A certified translation into English (or Irish), if the documents are in another language.

3.2. Legal costs

Enforcement entails legal costs, as well as court fees upon filing. As a general rule, costs are awarded to the successful party (section 169 of the Legal Services Regulation Act 2015); where enforcement proceedings are necessary, the costs of such proceedings are usually awarded to the claimant.[10]

3.3. Deadlines

Timeframes depend on the judges’ workload; for comparable arbitration cases (for example, those concerning annulment), the typical timeframe is 4–9 months. In the absence of objections, enforcement does not, as a rule, present any difficulties.[11]

3.4. Limitation period

The Limitation Act 1957 applies. Under section 11(1)(d), a six-year limitation period applies to the enforcement of an arbitral award not made ‘under seal’, running from the date on which the right to claim arose. Once a court judgement has been made in the terms of an arbitral award (pursuant to section 23 of the 2010 Act), the claimant has 12 years from the date on which the court judgement became enforceable (section 11(6)(a)).[12]

The grounds for refusal are set out in Article 36 of the Model Law (which mirrors Article V of the New York Convention) and are interpreted narrowly.[13]

4.1. Grounds based on the debtor’s application (Article 36(1)(a) / Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article 36(1)(b) / Article V(2))

Non-arbitrability of the dispute;

Contrary to public order.

4.3. Rejection on the grounds of lack of practical utility

Irish courts may refuse to enforce a foreign judgment if it is shown that there is no practical benefit to be derived from such enforcement in Ireland — that is, where there are no assets and no likelihood of any such assets appearing within the jurisdiction.[14]

4.4. Special case: a decision set aside abroad

Under Article 36(1) of the Model Law and Article V(1)(e) of the Convention, where a decision has been set aside or suspended in the State of origin, the court is ENTITLED to refuse enforcement, but is not obliged to do so — the court retains its discretion.[15]

If an application to set aside or stay the award has been lodged at the place of arbitration, the enforcing court is entitled, under Article 36(2) of the Model Law (and Article VI of the Convention), to stay proceedings and may require the objecting party to provide appropriate security.[16] However, the mere existence of a challenge is not usually sufficient grounds for a stay: the court must be satisfied that there are well-founded grounds for believing that the challenge may be successful (Danish Polish Telecommunication Group v Telekomunikacja Polska, [2011] IEHC 369; Project Solartechnik v Solas Bond, [2025] IEHC 64).[16]

Once a court judgment has been issued in the form of an arbitral award, enforcement proceeds in the same way as for an ordinary High Court judgment (seizure of property, bank accounts, shares, etc.). The High Court also has jurisdiction to recognise and enforce interim measures ordered by arbitrators (Articles 17H and 17J of the Model Law).[17]

6.1. The advantage of an English-speaking jurisdiction

Ireland is an English-speaking common law jurisdiction within the EU, making it a convenient alternative to London for enforcement following Brexit, particularly where the debtor has assets in Ireland.

6.2. Tracing the debtor’s assets

Useful resources:

Companies Registration Office (CRO): www.cro.ie;

Land Registry (Tailte Éireann): www.tailte.ie;

Register of Court Decisions (Central Office of the High Court) — information on enforcement proceedings.

6.3. Practical obstacles

Lack of assets: the court may refuse to enforce a judgment if there is no practical benefit — it is advisable to carry out a preliminary search for assets;[14]

Limitation periods: please note the six-year limitation period (section 11(1)(d) of the 1957 Act);

Finality: the High Court’s decision to set aside the order under Article 34 is final and not subject to appeal.

7.1. Legislation and official sources

→ Irish Statute Book — Arbitration Act 2010: irishstatutebook.ie

→ The New York Convention (Ireland): newyorkconvention.org

→ Courts in Ireland: courts.ie

7.2. Registers

CRO company register: www.cro.ie

Tailte Éireann Land Register: www.tailte.ie

7.3. Arbitration institutions

Arbitration Ireland: www.arbitrationireland.com

Chartered Institute of Arbitrators (Irish Branch): www.ciarb.ie

7.4. Specialists in the enforcement of arbitral awards in Ireland

A list of recommended experts is available on the official website of the Riga Arbitration Court:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] Arbitration Act 2010 (Act No. 1 of 2010), in force since 8 June 2010. Irish Statute Book: irishstatutebook.ie; WIPO Lex.

[2] UNCITRAL Model Law (2006 edition), Annex 1, Articles 6, 23, 35 and 36; Article IV of the New York Convention.

[3] The 1958 New York Convention (Ireland — accession in 1981, without reservations), Annex 2, Article 24(1) of the Act.

[4] The 1923 Geneva Protocol (Appendix 5); the 1927 Geneva Convention (Appendix 4); the 1965 ICSID Washington Convention (Appendix 3).

[12] Statute of Limitations 1957, section 11(1)(d) (6 years) and section 11(6)(a) (12 years); Order 56, Rule 3 of the Rules of the Supreme Court.

Case law

[16] Danish Polish Telecommunication Group I/S v Telekomunikacja Polska S.A. [2011] IEHC 369; Project Solartechnik v Solas Bond Company DAC [2025] IEHC 64.

Analytical and reference materials

[5] Aceris Law — International Commercial Arbitration in Ireland (section 23(4) of the Act; section 9).

[6] Mondaq / Mason Hayes & Curran — Ireland’s Pro-Enforcement Approach to Foreign Arbitral Awards (2026); Arbitration List of the High Court.

[7] WIPO Lex / Irish Statute Book — Arbitration Act 2010, section 23(1)–(3).

[8] Mondaq — procedure for filing (originating notice of motion + affidavit).

[9] CMS Expert Guides — International arbitration law and rules in Ireland (pro-arbitration approach).

[10] Lexology — In brief: arbitration formalities in Ireland; section 169 of the Legal Services Regulation Act 2015.

[11] Lexology — In brief: enforcing and challenging arbitral awards in Ireland (timeframes: 4–9 months).

[13] CMS Expert Guides / Lexology — Article 36 of the Model Law; a narrow interpretation of the grounds.

[14] Lexology — rejection on the grounds of lack of practical benefit (no assets in Ireland).

[15] Lexology — the court’s discretion under Article V(1)(e) / Article 36(1) (the court is not obliged to refuse).

[17] CMS Expert Guides — Articles 17H and 17J of the Model Act (interim measures).

1.1. Key legislation

The recognition and enforcement of foreign arbitral awards in Israel are governed by the Arbitration Law 1968 (Arbitration Law 1968) and the Arbitration Regulations 1968, and, in relation to the New York Convention, by the Regulations on Recognition and Enforcement under the New York Convention 1978 (New York Convention Regulations 1978).[1]

A distinction is made between domestic arbitration and international arbitration. In domestic arbitration, the court may, upon application by a party, confirm the award, thereby giving it the force of a court judgement (with the exception of the right of appeal). In international arbitration, awards are recognised as binding and enforced by a court upon a written application — regardless of the country in which the award was made.[2]

1.2. The New York Convention

Israel is a party to the 1958 New York Convention. The recognition and enforcement of foreign judgments under the Convention are carried out in accordance with the Convention and the 1978 Regulations.[3]

2.1. The Court

Israel is divided into six districts, each of which has a District Court and Magistrates’ Courts. Each of the six District Courts is authorised to hear cases concerning the recognition and enforcement of foreign judgments.[4]

2.2. Time limit and good faith

No specific strict time limit is laid down by law; however, the procedural duty of good faith requires that an application be lodged within a reasonable time, to be assessed on a case-by-case basis. The Supreme Court refused to recognise the application where 30 years had elapsed between the date of the judgment and the filing of the application (the case concerned a local judgment, not an application under the New York Convention).[5]

3.1. Required documents

Under section 44 of the International Commercial Arbitration Act (and Article IV of the Convention), a party seeking enforcement shall submit:[6]

The original arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

Translation into Hebrew — if required by the court (section 44(b)).

3.2. Legal costs

A court fee is payable when filing an application with the district court in accordance with the Court Fees Regulations — as a rule, a fixed fee for an application for recognition or enforcement (subject to verification). A foreign judgment is recognised under the New York Convention and the 1978 Regulations; a domestic (local, issued in Israel) award is confirmed by the court (section 23 of the Arbitration Act 1968), thereby acquiring the force of a court judgment — the difference lies in the procedure, not in the fundamental amount of the fee. In addition, there are costs for translation into Hebrew (as required by the court) and legal support. Specific rates are subject to verification at the time of submission.[4]

The grounds are limited and are in accordance with Article V of the New York Convention; the burden of proof lies with the objecting party.[7]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article V(2))

Non-arbitrability of the dispute under Israeli law;

Contrary to public order in Israel.

The court is entitled to refuse to recognise or enforce a foreign award that has been set aside by the courts at the place of arbitration. If an application for setting aside is pending at the place of arbitration, the court may stay the enforcement proceedings and require the provision of security (section 45 of the International Commercial Arbitration Act and the Rules under the 1978 New York Convention, § 4).[8]

Once a judgement has been recognised, enforcement is carried out through the Enforcement Authority (Hotsaa la-Poal): seizure and sale of property, and attachment of the debtor’s bank accounts and assets.[9]

6.1. Tracing the debtor’s assets

Useful resources:

Company Register (Rasham ha-Hevrot): www.gov.il;

Land Registry (Tabu) — via gov.il;

Enforcement Authority (Hotsaa la-Poal): www.eca.gov.il.

6.2. Practical advantages and obstacles

Any of the six county courts: choose the one with jurisdiction over the location of the assets or the debtor;[4]

A reasonable timeframe: do not delay your application — the principle of good faith applies;[5]

Translation into Hebrew: may be required by the court.

7.1. Legislation and official sources

Israeli Government Portal: www.gov.il

The New York Convention (Israel): newyorkconvention.org

7.2. Registers

Company Register: www.gov.il

Enforcement agency: www.eca.gov.il

7.3. Arbitration institutions

Israeli Institute of Commercial Arbitration (IICA): www.iica.co.il

7.4. Specialists in the enforcement of arbitral awards in Israel

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Israeli Arbitration Law 1968 (Arbitration Law 1968); Arbitration Rules 1968; Rules on the Recognition and Enforcement of Awards under the New York Convention 1978. gov.il

[2] The International Commercial Arbitration Act (ICAL), section 44 (recognition of international awards regardless of the country); the Arbitration Act 1968, section 23 (confirmation of domestic awards).

[3] The 1958 New York Convention (Israel is a party to it).

[6] ICAL, Section 44(a)–(b) (documents; translation into Hebrew on request); Article IV of the New York Convention.

[8] ICAL, Section 45; Regulations under the 1978 New York Convention, § 4 (set-off; suspension; security).

Case law

[5] Supreme Court of Israel — The Major Synagogue ‘Shore Halachot’ v. Netanya Municipality (11 September 2007) — reasonable time; good faith.

Analytical and reference materials

[4] Jus Mundi — Israel (six district courts; jurisdiction over the recognition and enforcement of judgments).

[7] Lexology — In brief: enforcing and challenging arbitral awards in Israel (limited grounds under Article V; burden of proof).

[9] Lexology — Israel; Enforcement Authority (Hotsaa la-Poal) — enforcement procedure.

1.1. Key legislation

The recognition and enforcement of foreign arbitral awards in Italy are governed by Articles 839 and 840 of the Italian Code of Civil Procedure (Codice di procedura civile, CPC), which, for the most part, reproduce the provisions of the New York Convention word for word (Article 839 of the CPC reproduces Article IV of the Convention, and Article 840 reproduces Article V).[1]

The term ‘foreign’ refers to an award made in arbitration where the seat of arbitration (sede dell’arbitrato) is outside Italy. Awards made in Italy are considered domestic and are enforced under different rules (Articles 824-bis and 825 of the CPC).[2]

1.2. The New York Convention

Italy ratified the 1958 New York Convention by Law No. 62 of 19 January 1968, without any reservations.[3] The Convention has been directly incorporated (ordine esecutivo) and takes precedence; Articles 839–840 of the CPC apply in matters not covered by the Convention, or where they are more favourable to enforcement (Rule VII of the Convention).[4]

1.3. The Kartabia Reform (2022–2023)

Legislative Decree No. 149/2022 (the Cartabia reform), which came into force on 1 March 2023, has significantly modernised Italian arbitration law.[5] Key changes affecting enforcement:

Immediate enforceability of the decree granting enforcement of a foreign judgment (amended Article 839(4) of the CPC) — the judgment is enforceable immediately upon the issuance of the decree;[6]

Granting arbitrators the power to order interim measures (the new version of Article 818 of the CPC) — previously, this was the exclusive prerogative of the state courts.[7]

1.4. Other international treaties

The 1927 Geneva Convention on the Enforcement of Foreign Arbitral Awards;

The 1961 European Convention on Foreign Trade Arbitration (Article IX — in respect of set-aside awards).

2.1. The court of first instance

An application for recognition and enforcement must be lodged with the President of the Court of Appeal (Corte d'Appello) of the district in which the debtor has their place of residence, registration or registered office. If the debtor has no domicile in Italy, the Court of Appeal of Rome has jurisdiction.[8]

2.2. Two-stage procedure

Stage 1 (ex parte): the claimant lodges an application (ricorso) with the President of the Court of Appeal. The court checks that the award is in order and, of its own motion, examines the grounds set out in Article V(2) of the Convention (arbitrability, public policy). If the outcome is favourable, a decree of exequatur is issued.[9]

Stage 2 (inter partes): the order is served on the debtor, who is entitled to lodge an objection with the same court (sitting as a panel) within 30 days. Adversarial proceedings are instituted on the grounds set out in Article 840 of the CPC. As a rule, the judgment is already enforceable before the expiry of the 30-day period.[10]

2.3. The position of the Italian courts

Italian courts apply the New York Convention in accordance with international standards and demonstrate a favourable approach to the recognition of foreign judgments.[11] The Cartabia reform has further enhanced Italy’s appeal as a jurisdiction for enforcement.

2.4. Appeal on points of law

A decision of the Court of Appeal following adversarial proceedings may be appealed to the Court of Cassation (Corte di Cassazione). The Court of Cassation’s review is limited to points of law; the facts of the case are not reviewed.[12]

3.1. Required documents

In accordance with Article 839 of the CPC and Article IV of the New York Convention, the following are attached:[1]

The original arbitration award (or a duly certified copy thereof);

The original arbitration agreement (or a certified copy thereof);

Certified translation into Italian: a translation of the entire award and the arbitration clause (not the entire contract) is required, carried out by a certified translator.[13]

3.2. Legal costs

Court fees for filing an application are low and fixed:[14]

In addition: the cost of a certified translation and the Italian solicitor’s fees. Registration tax is levied after the issuance of the enforcement order and depends on the nature of the award (assessed on a case-by-case basis). By way of comparison, in the case of a domestic (Italian) arbitral award, enforceability is conferred by a decree of the tribunal (Article 825 of the CPC) and is subject to a single fee (contributo unificato) of the same amount — approximately €98; the key difference from a foreign award lies in the competent court (the tribunal rather than the Court of Appeal), rather than the amount of the fee.[15]

3.3. Deadlines

The ex parte stage (issuing the exequatur decree) is completed fairly quickly — sometimes in less than a month. The adversarial stage (where an objection is lodged) can take a year or more.[14]

3.4. Limitation period

The Convention and the CPC do not expressly provide for a specific limitation period for foreign judgments. By analogy with domestic judgments, the general ten-year limitation period applies (Article 2946 of the Italian Civil Code).[14]

4.1. Grounds examined by the court of its own motion (stage 1)

Even at the ex parte stage, the presiding judge is entitled to refuse if: (1) the subject-matter of the dispute could not be referred to arbitration under Italian law (non-arbitrability); or (2) the award is contrary to public policy, including a breach of the adversarial principle in arbitration.[9]

4.2. Grounds raised by the debtor (Stage 2, Article 840 of the CPC)

When lodging an objection, the debtor is entitled to rely on grounds which, in substance, mirror Article V(1) of the Convention:[16]

The legal incapacity of the parties or the invalidity of the arbitration agreement;

Failure to give proper notice of the appointment of an arbitrator or of the proceedings, or the inability to present one’s case;

The award going beyond the scope of the arbitration agreement (partial recognition of a severable part may be possible — Article 840(3)(3) of the CPC);

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision has not yet become binding, or has been set aside or suspended in the country where it was made.

4.3. Special case: a decision set aside abroad

Unlike France, Italy does NOT enforce judgments that have been set aside by the competent authority of the issuing country: pursuant to Article 840(3), No. 5 of the CPC, recognition will be refused in the event of the total or partial setting aside of a foreign award (subject to Article IX of the 1961 Geneva Convention, where applicable).[17] If the award has been amended or set aside by a court at the place of arbitration, the claimant may no longer seek enforcement of the arbitral award itself, but rather the judicial decision of that foreign court — in accordance with the rules on the recognition of foreign court judgments (Regulation (EU) No 1215/2012 for the EU or Act No 218/1995 for non-EU countries).

Once the recognition procedure has been completed, the exequatur decree, together with the arbitral award, constitutes an enforceable title (titolo esecutivo), enabling enforcement proceedings to be brought against the debtor’s assets pursuant to Article 474 of the CPC.[18]

Available performance instruments:

Seizure (pignoramento) of movable property and bank accounts;

Seizure of property — the court with jurisdiction over the location of the property has jurisdiction;[8]

Security at the claimant’s request: the court may order a party to provide security (Article 840(4) of the CPC).[19]

6.1. Mandatory representation

The proceedings are being conducted through an Italian lawyer (avvocato). A foreign claimant must engage a local representative.

6.2. Tracing the debtor’s assets

The jurisdiction for enforcement proceedings depends on the type of assets. Useful resources for identifying the debtor’s assets and status:

Register of Companies (Registro Imprese): www.registroimprese.it;

Search for companies and financial statements: www.infocamere.it;

Land Register / Cadastre (Agenzia delle Entrate) — for property.

6.3. Practical obstacles

Registration tax: up to 3 per cent of the awarded amount — a significant expense that should be taken into account in advance;[15]

Translation: a certified translation of the entire decision is required — this is time-consuming and costly;

Set-aside decisions: where a decision has been set aside in the country in which it was made, enforcement in Italy is not possible — it is necessary to seek recognition of the foreign court order instead.

7.1. Legislation and official sources

Normattiva — CPC (Articles 806–840): normattiva.it

The New York Convention (Italy): newyorkconvention1958.org

7.2. Registers

Register of businesses: www.registroimprese.it

InfoCamere: www.infocamere.it

7.3. Arbitration institutions

Milan Chamber of Arbitration (CAM): www.camera-arbitrale.it

7.4. Specialists in the enforcement of arbitral awards in Italy

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Italian Code of Civil Procedure (Codice di procedura civile), Articles 806–840, in particular Articles 839–840. Normattiva: normattiva.it

[2] Italian Code of Civil Procedure, Articles 824-bis and 825 (domestic judgments); Article 474 (enforcement order); Article 2946 of the Italian Civil Code (limitation period).

[3] Act No. 62 of 19 January 1968 — ratification of the 1958 New York Convention (without reservations).

[4] The 1958 New York Convention (Articles IV, V and VII); the 1927 Geneva Convention; the 1961 European Convention.

[5] Legislative Decree No. 149/2022 (the Kartabia Reform) came into force on 1 March 2023.

Case law

[17] The application of Article 840(3)(5) of the CPC to judgments set aside abroad (IBA Review, 2023).

Analytical and reference materials

[6] Osborne Clarke — Italy enters a new era of ‘arbitration-friendliness’ (2025) — immediate enforceability under Article 839(4) of the CPC.

[8] Global Arbitration Review — The Guide to Challenging and Enforcing Arbitration Awards, 4th ed., Italy (LCA Studio Legale).

[9] Global Legal Post — Law Over Borders: Arbitration, Italy (two-stage procedure, Articles 839–840 of the CPC).

[10] Norton Rose Fulbright — Recognition and enforcement in Italy of civil and commercial judgments and arbitral awards.

[11] Daily Jus (Jus Mundi) — The Art of Enforcement: How Italian Courts Support Arbitration (2025).

[14] Chambers — Enforcement of Judgments 2025, Italy (fees: €98 + €27; time limits; Article 2946 of the Civil Code).

[15] Baker McKenzie — Cross-Border Enforcement Centre, Italy (registration tax; translation).

[16] Lexology — In brief: enforcing and challenging arbitral awards in Italy (2023); ICC Digital Library, Country Answers: Italy.

[18] Jus Mundi — Italy country publication (enforceable title, Article 474 of the Code of Civil Procedure).

[19] ICC Digital Library — Italy (Article 840(4) of the CPC, security).

1.1. Key legislation

Arbitration in Japan is governed by the Arbitration Act (Act No. 138 of 2003, as amended), which is based on the UNCITRAL Model Law (1985 version, as amended in 2006). The amendments reflecting the 2006 revision came into force in April 2024 and, in particular, strengthened the mechanism for enforcing interim measures ordered by the tribunal. The enforcement procedure is supplemented by the Civil Enforcement Act and the Supreme Court Rules on Procedures in Arbitration Cases (No. 27 of 2003).[1]

The provisions of the Arbitration Act concerning recognition and enforcement apply equally to awards where the place of arbitration is in Japan or abroad: the place of arbitration is irrelevant for the purposes of recognition and enforcement. The rules apply even to awards from states that are not parties to the Convention.[2]

1.2. The New York Convention

The 1958 New York Convention entered into force for Japan on 18 September 1961; only a reservation regarding reciprocity has been made (Article I(3)). Foreign judgments rendered in Contracting States are enforced in accordance with the Convention.[3]

2.1. Automatic recognition

Both domestic and foreign awards are automatically recognised in Japan, without the need to initiate separate legal proceedings, and have the force of a final court judgement (Article 45 of the Arbitration Act). An enforcement order is required for enforcement (Article 46).[4]

2.2. The Court

An application for enforcement is filed with the district court at the debtor’s place of residence or domicile, or at the location of their property. International cases are primarily heard by the Tokyo District Court and the Osaka District Court, which have specialised expertise.[5]

2.3. Procedure for consideration

Once the application has been filed, the court notifies the other party. If the debtor raises substantive objections, the court may hold a hearing; in the absence of objections, an enforcement order is often issued on the basis of the documents alone. The burden of proving grounds for refusal lies with the objecting party; the court may, on its own initiative, examine only two grounds (non-arbitrability and public policy).[6]

3.1. Required documents

Pursuant to Article 46(2) of the Arbitration Act, the following are attached:[7]

A full, certified copy of the arbitration award;

A full translation of the decision into Japanese, if it is drafted in another language (other evidence not in Japanese must also be accompanied by a translation).

Once the amendments have come into force, the court is entitled, after hearing the debtor’s views, either not to require a translation or to allow a partial translation of the documents.[8]

3.2. Legal costs

A court fee is payable when filing an application for an enforcement order with the district court under the Court Costs Act (usually a fixed application fee; subject to verification). The provisions on recognition and enforcement apply equally to awards where the place of arbitration is in Japan or abroad (uniform regime, Articles 45–46 of the Act) — there is no difference in the amount of the fee between domestic and foreign awards. In addition, there are costs for translation into Japanese (following the 2024 reform, exemption or partial translation may be granted at the court’s discretion) and legal representation. Specific rates are subject to verification at the time of filing.[5]

The grounds are the same as those set out in Article 36(1) of the Model Law and Article V of the New York Convention.[9]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or failure to state one’s position;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article V(2))

Non-arbitrability of a dispute under Japanese law;

Contrary to public order in Japan.

The 2024 reform introduced a mechanism for the judicial enforcement of interim measures ordered by the tribunal (via a court order of approval). Once an enforcement order has been issued, recovery is carried out in accordance with the Civil Enforcement Act: seizure and sale of property, and attachment of the debtor’s bank accounts and other assets.[10]

6.1. Tracing the debtor’s assets

Useful resources:

Register of Legal Entities (National Tax Agency / hojin-bangou): www.houjin-bangou.nta.go.jp;

Legal Affairs Bureau — the land and companies register;

The Japan Commercial Arbitration Association (JCAA): www.jcaa.or.jp.

6.2. Practical advantages and obstacles

Automatic recognition: no separate proceedings for recognition are required;[4]

Translation into Japanese: required (following the reform, exemption or partial translation may be granted at the court’s discretion);[8]

Courts’ areas of specialisation: international cases — Tokyo and Osaka.

7.1. Legislation and official sources

Japanese Law Translation — Arbitration Act: www.japaneselawtranslation.go.jp

New York Convention (Japan): newyorkconvention.org

7.2. Registers

Register of legal entities: www.houjin-bangou.nta.go.jp

Legal Affairs Office: www.moj.go.jp

7.3. Arbitration institutions

Japan Commercial Arbitration Association (JCAA): www.jcaa.or.jp

7.4. Specialists in the enforcement of arbitral awards in Japan

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Japanese Arbitration Act (Act No. 138 of 2003, as amended; amendments in force from April 2024); Civil Enforcement Act; Supreme Court Rule No. 27 of 2003. japaneselawtranslation.go.jp

[2] The Arbitration Act — a single regime for awards where the place of arbitration is in Japan or abroad; applicable regardless of whether a country is a party to the Convention.

[3] The 1958 New York Convention (Japan — in force since 18 September 1961; reservation regarding reciprocity).

[7] Arbitration Act, section 46(2) (certified copy of the award; Japanese translation).

Analytical and reference materials

[4] Lexology — Global arbitrations around the world: Japan; Arbitration Act, section 45 (automatic recognition), 46 (enforcement).

[5] Global Law Experts — Enforcement of Arbitration Awards in Japan (District Court; Tokyo/Osaka).

[6] Lexology — Japan (burden of proof; two grounds for ex officio action; section 46(8) of the Act).

[8] Lexology — In brief: enforcing and challenging arbitral awards in Japan (translation; relaxations following the reform).

[9] Macfarlanes / AMT — Arbitration: Japan (grounds: Article 36(1) of the Model Law / Article V of the Convention).

[10] Global Legal Insights — International Arbitration 2026, Japan (2024 reform; interim measures; Civil Enforcement Act).

1.1. Key legislation

The recognition and enforcement of foreign arbitral awards in Kazakhstan are governed by the Civil Procedure Code of the Republic of Kazakhstan (CPC; in particular, Articles 501–504, as well as Articles 253 and 255), the Law ‘On Arbitration’ No. 488-V of 8 April 2016, the Law ‘On Enforcement Proceedings and the Status of Bailiffs’, and international treaties.[1]

Foreign arbitral awards shall be recognised and enforced where provided for by the legislation of the Republic of Kazakhstan, by a ratified international treaty, or on the basis of the principle of reciprocity.[2]

1.2. The New York and European Conventions

The key treaties are the 1958 New York Convention and the 1961 European Convention on Foreign Trade Arbitration. In proceedings for the recognition of foreign awards, these conventions take precedence over the procedural rules of the Republic of Kazakhstan. Kazakhstan’s accession to the 1961 European Convention limits the application of the ground set out in Article V(1)(e) of the New York Convention (set-aside at the place where the award was made): refusal on this ground is possible only within narrower limits.[3]

Kazakhstan is also a party to the Washington Convention (ICSID) and a number of bilateral treaties on legal assistance (including with Turkey, the UAE, Kyrgyzstan and Turkmenistan).[4]

2.1. The Court

An application for recognition and enforcement shall be lodged with the competent court (a specialised interdistrict economic court or a regional court, depending on the parties involved) at the debtor’s place of residence or business, and if this is unknown, at the location of their property.[5]

2.2. An exhaustive list of grounds and the burden of proof

The list of grounds for refusal is exhaustive — the courts are not entitled to extend it. The burden of proving that notice was not properly given during the arbitration proceedings lies with the party against whom recognition and enforcement are sought. The applicant is not obliged to prove that notice was properly given at the time of filing, but is entitled to gather the relevant evidence in advance.[6]

It should be borne in mind that the practice regarding the application of Article 503(1) of the Code of Civil Procedure is inconsistent: in one particular case, the court effectively added a ground for refusal not provided for in Article V of the New York Convention, which has been criticised as being inconsistent with Kazakhstan’s international obligations.[7]

3.1. Required documents

In accordance with Article IV of the New York Convention and the Code of Civil Procedure, the following are attached:[8]

A duly certified original of the arbitral award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A certified translation into Kazakh or Russian, if the documents are in another language.

3.2. Submission deadline

A judgment may be enforced within three years of the date on which it becomes final. This three-year period is of a procedural nature and does not constitute a limitation period under substantive law. Article 502 of the Code of Civil Procedure does not, however, set a time limit for the court to consider the application itself.[9]

3.3. Legal costs

A state fee is payable when filing an application with the competent court under the Tax Code of the Republic of Kazakhstan (as a rule, a multiple of the minimum wage; subject to verification). A foreign award is recognised and enforced in accordance with Articles 501–504 of the Code of Civil Procedure; a domestic (rendered in Kazakhstan) arbitral award is enforced through the issuance of a writ of execution by the court (Articles 253–254 of the Code of Civil Procedure, the Law ‘On Arbitration’) — the difference lies in the procedure, not in the fundamental amount of the fee. In addition, there are costs for a certified translation into Kazakh or Russian and legal support. Specific rates are subject to verification at the time of filing.[5]

The grounds are set out in Article 255 of the Code of Civil Procedure and are almost entirely consistent with Article V of the New York Convention (subject to the restriction under Article V(1)(e) due to participation in the 1961 European Convention).[10]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or failure to state one’s position;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision has not become binding, or has been set aside or suspended in the country in which it was made (subject to the restrictions under the 1961 European Convention).

4.2. Grounds subject to judicial review (Article V(2))

The dispute is not subject to arbitration under the law of the Republic of Kazakhstan;

Contrary to public order in the Republic of Kazakhstan.

Once the claim has been recognised and a writ of execution has been issued, enforcement is carried out in accordance with the Law ‘On Enforcement Proceedings’ through bailiffs: the seizure and sale of property, and the attachment of the debtor’s bank accounts and assets. In practice, there are sometimes delays in the processing of applications; it is advisable to establish the location of the debtor’s assets in advance.[11]

6.1. Tracing the debtor’s assets

Useful resources:

E-government portal (eGov): egov.kz;

Register of Legal Entities (Ministry of Justice / stat.gov.kz);

Unified Register of Debtors and Enforcement Proceedings: aisoip.adilet.gov.kz.

6.2. Practical advantages and obstacles

Priority of conventions: correctly identify the applicable treaty and link the application to it;[3]

An exhaustive list of grounds: the courts are not entitled to extend it (though case law is inconsistent);[7]

3-year time limit: ensure that the procedural time limit for serving the enforcement notice is observed.

7.1. Legislation and official sources

Adilet — The Law ‘On Arbitration’ and the Civil Procedure Code of the Republic of Kazakhstan: adilet.zan.kz

The New York Convention (Kazakhstan): newyorkconvention.org

7.2. Registers

E-government: egov.kz

Enforcement Proceedings Register: aisoip.adilet.gov.kz

7.3. Arbitration institutions

Kazakhstan International Arbitration (KIA);

AIFC Arbitration Centre (AIFC / IAC): iac.aifc.kz

7.4. Specialists in the enforcement of arbitral awards in Kazakhstan

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] Civil Procedure Code of the Republic of Kazakhstan (Articles 253, 255, 501–504); Law of the Republic of Kazakhstan ‘On Arbitration’ No. 488-V of 8 April 2016; Law of the Republic of Kazakhstan ‘On Enforcement Proceedings and the Status of Bailiffs’. adilet.zan.kz

[2] Recognition and enforcement — in accordance with the legislation of the Republic of Kazakhstan, a ratified treaty, or on the basis of reciprocity.

[3] The 1958 New York Convention; the 1961 European Convention on Foreign Trade Arbitration (takes precedence over the Code of Civil Procedure; restriction on the grounds set out in Article V(1)(e)).

[4] The Washington Convention on ICSID; bilateral treaties on legal assistance (Turkey, the UAE, Kyrgyzstan, Turkmenistan).

[10] Civil Procedure Code of the Republic of Kazakhstan, Article 255 (grounds for refusal corresponding to Article V of the Convention).

Case law

[7] Grata — Kazakhstan’s Recent Arbitration Enforcement Precedent (application of Article 503(1) of the Code of Civil Procedure; addition of a ground not provided for in Article V — criticism); Supreme Court Regulatory Resolution No. 3.

Analytical and reference materials

[5] Mondaq / Conventus Law — Recognition and Enforcement of a Foreign Arbitral Award in Kazakhstan (competent court; location of the debtor/assets; documents).

[6] Unicase / Mondaq — Recognition and Enforcement of Arbitral Awards in Kazakhstan: A Practical Overview (exhaustive list; burden of proof regarding notification).

[8] Article IV of the New York Convention; Conventus Law — Kazakhstan (documents; translation).

[9] Unicase — Kazakhstan (three-year procedural time limit; Article 502 of the Code of Civil Procedure — no time limit for consideration).

[11] Chambers — Recognition and Enforcement of Foreign Judgments and Commercial Arbitration Awards in Kazakhstan (enforcement proceedings; delays).

1.1. Key legislation

The recognition and enforcement of arbitral awards in Latvia are governed by the Civil Procedure Law (Civilprocesa likums, GPZ) and the Arbitration Law (Šķīrējtiesu likums). Foreign arbitral awards are recognised and enforced under Chapter 77.1 of the CPL (Articles 645–651) in conjunction with the New York Convention; domestic (awards made in Latvia) are enforced under Chapter 66 of the CPL (Articles 534–537) through the issue of a writ of execution.[1]

An arbitral award that is enforceable outside Latvia shall be enforced in accordance with the 1958 New York Convention.[2]

1.2. The New York Convention and other treaties

Latvia is a party to the 1958 New York Convention, the ICSID Washington Convention and the 1961 European Convention on Foreign Trade Arbitration, and applies international mechanisms for the recognition and enforcement of awards.[3]

1.3. Supervisory reform and the withdrawal mechanism (2023–2024)

In February 2023, the Constitutional Court of Latvia ruled that the absence of a mechanism for setting aside arbitral awards was unconstitutional; the contested provisions ceased to have effect on 1 March 2024. As a result of the reform, a mechanism for setting aside domestic arbitral awards has been introduced (Article 533.1 of the Civil Procedure Code): the court serves the application on the other party, allowing at least 20 days for a response; it considers the case in writing (unless it deems it necessary to hold a hearing) within 20 days; if the application for setting aside is refused, the applicant has 10 days to appeal, whilst if the award is set aside, no appeal is permitted. The reform has also granted courts the right to issue enforcement orders in respect of ad hoc awards and has strengthened the requirements regarding the impartiality and independence of arbitrators.[4]

Note: this set-off mechanism applies to domestic (Latvian) judgments; foreign judgments are recognised under the New York Convention.

1.4. EU sanctions (2025)

The 18th EU sanctions package (Council Regulation (EU) 2025/1494 of 18 July 2025) prohibits the recognition and enforcement in EU Member States of investment arbitration awards (ISDS) in favour of sanctioned Russian or Belarusian entities. This restriction should be borne in mind when dealing with such awards.[5]

2.1. Foreign judgements

An application for the recognition and enforcement of a foreign arbitral award is lodged with the district (city) court and is heard at a court hearing, with prior notice given to the parties; the failure of interested parties to appear does not prevent the application from being considered (Article 649 of the Civil Procedure Code). Recognition is governed by Articles 645–651 of the Civil Procedure Code.[6]

2.2. Internal solutions (for comparison)

If an award of a permanent arbitral tribunal is enforceable in Latvia and has not been voluntarily complied with, the interested party is entitled to apply for an enforcement order from the district (municipal) court at the debtor’s declared place of residence or registered office; in the absence of either, at the debtor’s place of residence or at the place where the arbitral award is to be enforced (Article 534 of the Civil Procedure Code). The procedure for considering the application is set out in Article 535 of the Civil Procedure Code; the grounds for refusing to issue a writ of execution are listed in Article 536 of the Civil Procedure Code.[7]

3.1. Required documents

In accordance with Article IV of the New York Convention and Article 13(2) of the General Provisions, the following are annexed:[8]

The original arbitration award or a duly certified (notarised) copy thereof;

The original arbitration agreement or a certified copy thereof;

Translation into Latvian, if the documents are in another language.

3.2. Legal costs

The state fee depends on the type of award. For a foreign arbitral award (recognition and enforcement, Chapter 77.1 of the Civil Procedure Code), the fee for filing an application for recognition and enforcement is a fixed amount of 30 EUR (Article 34 of the Civil Procedure Code; the rate set for the recognition of foreign court awards; its applicability to foreign arbitral awards is subject to clarification). For a domestic (Latvian) award, the fee for issuing a writ of execution is 1% of the amount to be recovered, but not exceeding 285 EUR (Article 34 of the Civil Procedure Law); the fee for submitting the writ of execution to a bailiff is 3 EUR. In addition, costs for a certified translation into Latvian (Article 13(2) of the Civil Procedure Code) and legal assistance are taken into account. The amounts are current as at mid-2026 and are subject to verification at the time of submission.[6]

For foreign judgments, the grounds set out in Article V of the New York Convention apply.[9]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article V(2))

Non-arbitrability of a dispute under Latvian law;

Contrary to public order in Latvia.

Latvian doctrine notes that the requirement for arbitrators to possess professional qualifications (Article 497 of the Civil Procedure Code) should not be regarded as a mandatory rule in international arbitration and should not be applied to international proceedings unless the parties have agreed otherwise.[10]

Upon application by an interested party, the court is entitled to enforce a foreign arbitral award (Article 650 of the Civil Procedure Code). Once recognised, the award is enforced in accordance with the rules of the Civil Procedure Code through a sworn bailiff (zvērināts tiesu izpildītājs): seizure of property and bank accounts, and enforcement against assets (Article 651 of the Civil Procedure Code).[11]

6.1. Tracing the debtor’s assets

Useful resources:

Register of Enterprises (Uzņēmumu reģistrs): www.ur.gov.lv;

Land Register (Zemesgrāmata): www.zemesgramata.lv;

Council of Sworn Bailiffs: www.lzti.lv.

6.2. Practical advantages and obstacles

Adversarial proceedings: the application is considered at a hearing at which the parties are notified (Article 649 of the Civil Procedure Code);

A translation into Latvian and a notarised copy are mandatory (Article 13(2) of the Civil Procedure Code);

EU sanctions: check whether Regulation 2025/1494 applies to ISDS awards.

7.1. Legislation and official sources

→ likumi.lv — Civil Procedure Act (GPZ): likumi.lv

→ likumi.lv — Arbitration Act: likumi.lv

→ The New York Convention (Latvia): newyorkconvention.org

7.2. Registers

Business Register: www.ur.gov.lv

Land Register: www.zemesgramata.lv

7.3. Arbitration institutions

Riga Arbitration Court (Rīgas šķīrējtiesa): court.lv

7.4. Specialists in the enforcement of arbitral awards in Latvia

A list of recommended experts is available on the official website of the Riga Arbitration Court:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Latvian Civil Procedure Law (Civilprocesa likums), Chapter 77.1 (Articles 645–651) and Chapter 66 (Articles 534–537); Arbitration Act (Šķīrējtiesu likums). likumi.lv

[2] GPZ — enforcement of an arbitral award outside Latvia under the 1958 New York Convention.

[3] The 1958 New York Convention; the ICSID Washington Convention; the 1961 European Convention (Latvia is a party to it).

[4] Constitutional Court of Latvia, February 2023 (invalidity due to the absence of a mechanism for repealing the Constitution; the provisions ceased to have effect on 1 March 2024); GPZ, Article 533.1 (mechanism for repeal).

[5] Council Regulation (EU) 2025/1494 of 18 July 2025 (the 18th EU sanctions package) — a ban on the recognition and enforcement of ISDS awards in favour of sanctioned entities in the Russian Federation and the Republic of Belarus.

Case law and official sources

[6] Civil Procedure Code, Articles 646–651 (in particular Article 649 — hearing with notice to the parties); Article 13(2) of the Civil Procedure Code.

[7] Riga Arbitration Court (court.lv), FAQ section; Civil Procedure Code, Articles 534–537 (domestic awards, writ of execution).

[10] DOAJ / academic publication — the application of Article V(1)(d) of the New York Convention in Latvia; Article 497 of the Civil Procedure Code (qualifications of arbitrators).

Analytical and reference materials

[8] CMS Expert Guides — International arbitration in Latvia; Jus Mundi — Latvia: Arbitration Reform (Article 13(2) of the Civil Procedure Code — translation, notarised copy).

[9] Chambers — Investor-State Arbitration 2025, Latvia (application of the New York Convention and the Model Law).

[11] CMS Expert Guides — Latvia; Civil Procedure Code, Articles 650 and 651 (security and enforcement).

1.1. Key legislation

Arbitration in Lithuania is governed by the Law on Commercial Arbitration (Komercinio arbitražo įstatymas), which came into force on 2 May 1996 and was substantially amended in June 2012 (as amended in 2017). The Act is based on the UNCITRAL Model Law (1985 version, including the 2006 amendments), which is applied in interpreting the Act (Article 4(5)). Procedural matters relating to enforcement are governed by the Code of Civil Procedure (CCP).[1]

The Act does not contain a separate list of grounds for refusing to recognise foreign judgments: pursuant to Article 51, recognition and enforcement are carried out in accordance with the New York Convention, the provisions of which (Article V) are directly applicable.[2]

1.2. The New York Convention

The 1958 New York Convention entered into force for Lithuania on 12 June 1995; a reservation regarding reciprocity has been made (Article I(3)): Lithuanian courts shall enforce judgments delivered in States party to the Convention.[3]

1.3. Other international treaties

The 1965 Washington Convention on ICSID (in force for Lithuania since 5 August 1992); bilateral treaties.[4]

2.1. The Court

An application for the recognition (or for the recognition and enforcement) of a foreign arbitral award is lodged with the Court of Appeal of Lithuania (Lietuvos apeliacinis teismas) — this is the court of first instance for such matters and it hears the case by written procedure.[5]

2.2. Entry into force and appeals

The ruling of the Court of Appeal takes effect from the moment it is handed down; from that moment, the foreign judgment is enforceable in accordance with the rules of the Code of Civil Procedure. The ruling may be appealed to the Supreme Court of Lithuania (Lietuvos Aukščiausiasis Teismas) within 30 days.[6]

2.3. No review on the merits

Arbitral awards are not reviewed on the merits: both the Court of Appeal and the Supreme Court review the award solely on the grounds for refusal to recognise and enforce it, as provided for in Article V of the Convention.[7]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are annexed:[8]

The original arbitration award or a duly certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A duly certified translation into Lithuanian, if the documents are not in the official language.

3.2. Legal costs

Applications for the recognition and enforcement of foreign arbitral awards are not subject to state fees (stamp duty). For a domestic (rendered in Lithuania) arbitral award, no separate recognition procedure is required — a writ of execution is issued by the court upon application (under the Code of Civil Procedure); the difference from a foreign award lies in the existence of a recognition stage before the Court of Appeal, rather than in the amount of the fee. In addition, the costs of a certified translation into Lithuanian and legal assistance are taken into account.[9]

The grounds are not enshrined in Lithuanian domestic law — Article V of the New York Convention applies directly.[2]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to review by the court (Article V(2))

Non-arbitrability of the dispute under Lithuanian law;

Contrary to public policy in Lithuania.

4.3. A decision set aside abroad

The Act does not contain an explicit prohibition on the enforcement of set-aside awards; Article V(1)(e) of the Convention applies. In practice, the Court of Appeal has suspended enforcement pending the conclusion of annulment proceedings at the seat of arbitration and has refused to enforce the part of the award that has been set aside at the seat of arbitration, whilst noting that annulment in itself is not always automatically sufficient grounds for refusal if the debtor does not object. Given the scarcity of case law, Lithuanian courts rely on general international practice in the application of the Convention.[10]

State courts are entitled to apply interim measures in support of arbitration. Once the order recognising the foreign award has come into force, the award acquires a status equivalent to that of a domestic court order and is enforced in accordance with the rules of the Code of Civil Procedure through a bailiff (antstolis): seizure of property and bank accounts, and attachment of assets. An enforcement order is issued by the court upon application.[11]

6.1. Tracing the debtor’s assets

Useful resources:

Register of Legal Entities (Registrų centras): www.registrucentras.lt;

The Land Registry — via the same registry centre;

Chamber of Bailiffs: www.antstoliurumai.lt.

6.2. Practical advantages and obstacles

No duty: the application for recognition is not subject to stamp duty — this reduces costs;

Written proceedings before the Court of Appeal — as a rule, without an oral hearing;

Public order: in a number of recent judgments, the Supreme Court has applied the exception more broadly than usual — the wording of the judgment and the procedure are important.

7.1. Legislation and official sources

e-seimas.lrs.lt — Commercial Arbitration Act: e-seimas.lrs.lt

New York Convention (Lithuania): newyorkconvention.org

7.2. Registers

Register of Legal Entities: www.registrucentras.lt

Chamber of Executors: www.antstoliurumai.lt

7.3. Arbitration institutions

Vilnius Commercial Arbitration Court (VCCA): www.arbitrazas.lt

7.4. Specialists in the enforcement of arbitral awards in Lithuania

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Law of Lithuania on Commercial Arbitration (Komercinio arbitražo įstatymas; in force since 2 May 1996; as amended in June 2012 and 2017), Article 4(5). e-seimas.lrs.lt

[2] Commercial Arbitration Act, Articles 50 and 51; the grounds set out in Article V of the New York Convention apply directly.

[3] The 1958 New York Convention (Lithuania – in force since 12 June 1995; reservation regarding reciprocity, Article I(3)).

[4] The 1965 Washington Convention on ICSID (in force for Lithuania since 5 August 1992); bilateral treaties.

Case law

[10] Kluwer Arbitration Blog — Recognition and Enforcement of Annulled Arbitral Awards: Lithuania; the case law of the Court of Appeal (Article V(1)(e) of the Convention).

Analytical and reference materials

[5] CMS Expert Guides — International arbitration in Lithuania (Court of Appeal of Lithuania; written proceedings).

[6] Jus Mundi — Lithuania country publication (entry into force of the decision; appeal to the Supreme Court, 30 days).

[7] IBA Arbitration Guide: Lithuania (2024) — no review on the merits.

[8] IBA Arbitration Guide: Lithuania — documents (Article IV of the Convention; Lithuanian translation).

[9] IBA Arbitration Guide: Lithuania — no stamp duty is payable on an application for recognition.

[11] Global Arbitration Review — Commercial Arbitration: Lithuania (Motieka & Audzevičius); enforcement under the Code of Civil Procedure.

1.1. Key legislation

Arbitration in Luxembourg is governed by the Arbitration Act of 19 April 2023, which came into force on 25 April 2023 and is set out in Articles 1224–1249 of the New Code of Civil Procedure (Nouveau Code de procédure civile, NCPC). The reform replaced provisions that essentially dated back to the Napoleonic Code of 1806 and is based on the UNCITRAL Model Law and French arbitration law.[1]

The new law applies to arbitration agreements concluded, tribunals constituted, and awards made after its entry into force.[2]

1.2. The New York Convention

Luxembourg ratified the 1958 New York Convention by the Act of 20 May 1983, entering a reservation regarding reciprocity (the Convention applies to judgments rendered in another Contracting State); no reservation regarding the commercial nature of the matter was made. In most cases, it is the Convention that applies.[3]

1.3. Other international treaties

The 1961 European Convention on Foreign Trade Arbitration; the ICSID Washington Convention.[4]

2.1. Authority and procedure

Arbitral awards made in Luxembourg or abroad are recognised and enforceable only after an exequatur has been obtained — an order from the President of the competent District Court (Tribunal d’arrondissement), sought by way of an ex parte (unilateral application). Article 1245 of the Code of Civil Procedure applies to foreign awards. Exequatur can usually be obtained within a few days.[5]

2.2. Appeals

With regard to foreign judgments, the only remedy available to the opposing party is to appeal against the order for enforcement. The appeal is lodged with the Court of Appeal; where enforcement is refused, the order must state the grounds for the refusal and may be appealed within one month of notification (with the other party being summoned).[6]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are annexed:[7]

A certified original of the arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

Translation if required (into French or German).

3.2. Limitation period

Luxembourg law does not specify a specific time limit for lodging an application for the recognition and enforcement of an arbitral award.[8]

3.3. Legal costs

Court fees for the enforcement procedure in Luxembourg are low (civil proceedings are virtually exempt from court fees); the main costs are the lawyer’s fees and the services of a bailiff (huissier de justice), as well as translation where necessary. Both foreign and domestic (issued in Luxembourg) judgments are enforced via exequatur before the President of the District Court (Articles 1245 and 1233 of the Code of Civil Procedure) — there is no difference in the amount of the fee between them. The specific rates are subject to verification at the time of application.[5]

Where an international treaty (the New York Convention or the ICSID Convention) applies, a refusal is possible only on the grounds set out therein — in the case of the Convention, these are the seven grounds set out in Article V. In the majority of cases, it is the Convention that applies.[9]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article V(2))

Non-arbitrability of the dispute;

Contrary to public policy in Luxembourg.

If, however, the international treaty does not apply, the Court of Appeal shall refuse to grant enforcement on the grounds set out in Article 1238 of the Code of Civil Procedure (lack of jurisdiction of the tribunal, breach of the procedure for its constitution, exceeding its mandate, breach of public policy, lack of reasoning in the decision (unless the parties have agreed otherwise), breach of the adversarial principle, obtaining the decision by fraudulent means, etc.).[10]

Provisional enforcement (exécution provisoire) may be granted in respect of assets if the judgment contains an order for provisional enforcement or if such an order is issued by a Luxembourg judge. Following exequatur, the judgment is enforced through a bailiff (huissier de justice): seizure of property and bank accounts, and the realisation of assets.[11]

6.1. Tracing the debtor’s assets

Useful resources:

Commercial Register (RCS Luxembourg): www.lbr.lu;

Register of Beneficial Owners (RBE) — via the LBR;

Chamber of Bailiffs: www.huissier.lu.

6.2. Practical advantages and obstacles

Fast-track ex parte procedure: an exequatur is often granted within a few days;

Financial hub: Luxembourg is a place where many international organisations hold their assets, which is important for compliance;

The 2023 reform: a predictable, arbitration-friendly regime.

7.1. Legislation and official sources

Legilux — Civil Code (arbitration, Articles 1224–1249): legilux.public.lu

The New York Convention (Luxembourg): newyorkconvention.org

7.2. Registers

RCS Commercial Register: www.lbr.lu

Chamber of Executors: www.huissier.lu

7.3. Arbitration institutions

The Arbitration Centre of the Luxembourg Chamber of Commerce (CAL): www.cc.lu

7.4. Specialists in the enforcement of arbitral awards in Luxembourg

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Luxembourg Arbitration Act of 19 April 2023 (in force since 25 April 2023), New Code of Civil Procedure (NCCP), Articles 1224–1249. legilux.public.lu

[2] Civil Procedure Code, Articles 1233 (domestic judgments), 1234, 1238, 1245 (foreign judgments), 1246; application to acts after the law comes into force.

[3] The 1958 New York Convention (Luxembourg — Act of 20 May 1983, reservation regarding reciprocity; no reservation regarding commercial matters), Articles IV and V.

[4] The 1961 European Convention; the ICSID Washington Convention.

Analytical and reference materials

[5] CMS — The new Arbitration Act 2023 marks Luxembourg’s return as a centre for international arbitration; Global Arbitration Review — Luxembourg (Articles 1233 and 1245 of the Code of Civil Procedure; ex parte; a few days).

[6] A&O Shearman — New rules for arbitration under Luxembourg law (appeal against a refusal to grant exequatur, 1 month; Court of Appeal).

[7] ICC Country Answers: Luxembourg (Article IV of the Convention; documents and translation).

[8] Global Arbitration Review — Luxembourg (no specific limitation period).

[9] Chambers — Enforcement of Judgments 2024, Luxembourg (the seven grounds set out in Article V of the Convention).

[10] Lexology / Loyens & Loeff — New Arbitration Law of 19 April 2023 (Articles 1234 and 1238 of the Code of Civil Procedure — grounds for refusal not covered by the contract).

[11] Jus Mundi — Luxembourg (provisional enforcement; exécution provisoire); Arendt — Parliament votes to reform Luxembourg’s arbitration law.

1.1. Key legislation

Arbitration in Malta is governed by the Arbitration Act (Chapter 387 of the Laws of Malta, Act II of 1996, as amended, most recently by Act VIII of 2020). The Act establishes the Malta Arbitration Centre (MAC) and incorporates the 1985 UNCITRAL Model Law (annexed as the First Annex and forming an integral part thereof; the 2006 amendments have not been implemented).[1]

The Act also incorporates the New York Convention, the 1923 Geneva Protocol, the 1927 Geneva Convention and the 1965 ICSID Washington Convention.[2]

1.2. The New York Convention

Malta signed and ratified the 1958 New York Convention on 22 June 2000, entering two reservations: one on reciprocity and one on non-retroactivity. The Convention applies only: (i) to the recognition and enforcement of awards made in another Contracting State; and (ii) to arbitration agreements concluded after the date of Malta’s accession to the Convention.[3]

2.1. A two-stage procedure

The recognition and enforcement of a foreign award take place in two stages: the foreign award is first registered with the Malta Arbitration Centre (MAC), after which it is enforced by a Maltese court in the same way as a domestic award. An award registered with the MAC becomes an enforceable title and is then enforced by the claimant through executive warrants.[4]

Awards under the 1965 ICSID Washington Convention are an exception: they are treated as final court judgements and are enforced directly by the court, without registration with the MAC.[5]

2.2. Timelines and efficiency

The Registrar shall not register the decision until thirty days have elapsed from the date on which the parties were notified of the decision, or if the Centre has been notified of any appeal against the decision. Enforcement may be effected by means of an enforcement order within 24 hours (section 69A(1) of the Act).[6]

2.3. Appeals

In international commercial arbitration, the parties are entitled to appeal to the Court of Appeal on a point of law if they have expressly agreed to such a right (in addition to the remedies provided for in Article 34 of the Model Law). An application deemed by the court to be unfounded or vexatious shall result in a fine of between €232.94 and €11,646.87 being imposed on the party that lodged it.[7]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are annexed:[8]

A certified original of the arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A certified translation, if required;

An affidavit (Rule 54 of the Rules of Procedure, SL 387.01) stating that no appeal has been lodged against the decision and that no appeal is pending, and that the decision is final.

3.2. Legal costs

The fees charged by the Malta Arbitration Centre (MAC) for the registration of the award, court fees for enforcement, and costs relating to translation and legal support are taken into account (specific rates are subject to verification). Both foreign and domestic (rendered in Malta) awards are registered with the MAC and are then enforced by the court as an enforceable title (with the exception of ICSID awards, which are enforced directly by the court) — there is no difference in the amount of the fee between them. The successful party is, as a rule, entitled to reimbursement of the costs incurred.[9]

The recognition of a foreign judgment may be refused only on the grounds set out in Article V of the New York Convention; the Maltese courts interpret these grounds restrictively.[10]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to review by the court (Article V(2))

Non-arbitrability of the dispute under Maltese law;

Contravention of public policy (an infringement is recognised only where there is a clear and manifest contravention of the fundamental principles of the Maltese legal system).

If the award has not been set aside but proceedings to set it aside are pending at the seat of arbitration, the Maltese courts will, as a rule, suspend recognition and enforcement. This is in accordance with Rule 54 of the Rules (affidavit as to the finality of the award and the absence of any appeal). An award that has been set aside at the seat of arbitration will, as a rule, not be enforced (on grounds of public policy).[11]

Once the case has been registered with the MAC and the judgment has been made enforceable, enforcement is carried out by means of enforcement orders: the seizure of property and bank accounts, and the attachment of the debtor’s assets.[4]

6.1. Tracing the debtor’s assets

Useful resources:

Company Register (Malta Business Registry): registry.mbr.mt;

Public Registry — information on property and encumbrances;

Malta Arbitration Centre (MAC): www.mac.com.mt.

6.2. Practical advantages and obstacles

Registration with the MAC: a mandatory first step for foreign awards (except ICSID);[5]

Affidavit (Rule 54): provide confirmation that the decision is final;

Strict scrutiny of formalities: whilst generally adopting a pro-arbitration approach, the courts rigorously assess compliance with formal requirements.

7.1. Legislation and official sources

Legislation Malta — Arbitration Act (Cap. 387): legislation.mt

The New York Convention (Malta): newyorkconvention.org

7.2. Registers

MBR Companies Register: registry.mbr.mt

Malta Arbitration Centre: www.mac.com.mt

7.3. Arbitration institutions

Malta Arbitration Centre (MAC): www.mac.com.mt

7.4. Specialists in the enforcement of arbitral awards in Malta

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Maltese Arbitration Act (Arbitration Act, Cap. 387, Act II of 1996, as amended, most recently by Act VIII of 2020); The 1985 UNCITRAL Model Law (Annex I). legislation.mt

[2] The 1923 Geneva Protocol; the 1927 Geneva Convention; the 1965 ICSID Washington Convention.

[3] The 1958 New York Convention (Malta — ratified on 22 June 2000; reservations regarding reciprocity and non-retroactivity), Articles IV and V.

[6] Arbitration Act, section 69A(1) (enforcement order within 24 hours); the 30-day rule prior to registration.

[8] Arbitration Rules (Subsidiary Legislation 387.01), Rule 54 (oath of finality).

Analytical and reference materials

[4] Lexology — In brief: arbitration formalities in Malta (registration with the MAC; enforcement orders).

[5] Lexology — Malta (ICSID awards — bypassing the MAC, as final court judgements).

[7] GĦSL Law Journal — The Republic of Malta and the 1958 New York Convention; Mondaq — International Arbitration in Malta (Court of Appeal; fine of between €232.94 and €11,646.87).

[9] Lexology — Malta (costs; reimbursement to the successful party).

[10] Chambers — International Arbitration 2025, Malta (Ganado Advocates) — a restrictive interpretation of Article V; public policy.

[11] Chambers / Global Arbitration Review — Malta (stay of proceedings upon setting aside at the seat of arbitration; Rule 54; set-aside awards).

1.1. Key legislation

Commercial arbitration in Mexico is governed by the Commercial Code (Código de Comercio), Book Five, Section IV (Articles 1415–1480), into which the UNCITRAL Model Law (as amended in 2011) was incorporated in 1993. The recognition, enforcement and setting aside of arbitral awards — regardless of the country in which they were made — are governed by Chapters VIII and IX (articles on nulidad, reconocimiento and ejecución).[1]

1.2. The New York Convention and other treaties

Mexico is a party to the 1958 New York Convention and the 1975 Inter-American (Panama) Convention. Under Article 133 of the Mexican Constitution, these treaties form part of the country’s ‘supreme law’. The provisions of the Commercial Code concerning grounds for refusal reflect Article V of the New York Convention and Article V of the Panama Convention.[2]

The Convention does not apply to matters relating to the setting aside of an award or the suspension of arbitration proceedings — these are governed by domestic law. Furthermore, the Convention does not apply if the award was made in Spanish within the territory of Mexico and is enforceable in Mexico.[3]

2.1. The Court

An application for recognition and enforcement is filed with a commercial judge (either a federal judge or a state court judge, at the applicant’s discretion, subject to concurrent jurisdiction). There are as yet no specialised arbitration courts in Mexico (with the exception of those recently established in the state of Yucatán, which have not yet commenced operations). The double exequatur has been abolished.[4]

2.2. Procedure for consideration

The court notifies the defendant of the application and allows 15 working days for a response (Article 1473 of the Commercial Code). The court does not review the merits of the dispute.[5]

3.1. Required documents

In accordance with Article IV of the New York Convention and the Commercial Code, the following are attached:[6]

A certified original of the arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

Translation into Spanish, if the documents are in another language.

3.2. Limitation period

The time limit for enforcing the decision is ten years (Article 1047 of the Commercial Code).[7]

3.3. Legal costs

In Mexico, access to justice is, as a general rule, free of charge (Article 17 of the Constitution); therefore, no state fee is usually charged for filing an application with a commercial court judge; the main costs are lawyers’ fees and certified translation into Spanish. Recognition and enforcement follow a single procedure (the double exequatur has been abolished) regardless of the country in which the judgment was rendered — domestic (rendered in Mexico) and foreign judgments are enforced in the same way by the same court. Specific costs are subject to verification at the time of filing.[4]

The grounds are limited and reflect Article V of the New York Convention.[8]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article V(2))

Non-arbitrability of the dispute under Mexican law;

Contrary to public order.

Arbitrators are vested with broad powers to order interim measures (following the 2011 amendments). Once the award has been recognised, it is enforced by the court: seizure and sale of property, and attachment of the debtor’s bank accounts and assets.[9]

6.1. Tracing the debtor’s assets

Useful resources:

Public Commercial Register (SIGER / RPC): rpc.economia.gob.mx;

Unified Register of Movable Collateral (RUG): www.rug.gob.mx;

State public property registers (Registro Público de la Propiedad).

6.2. Practical advantages and obstacles

Competing jurisdiction: you may choose between a federal court and a state court;[4]

A term of 10 years: one of the longest (section 1047 of the Commercial Code);[7]

Translation into Spanish: required for documents in other languages.

7.1. Legislation and official sources

Chamber of Deputies — Commercial Code: www.diputados.gob.mx

New York Convention (Mexico): newyorkconvention.org

7.2. Registers

Public Commercial Register: rpc.economia.gob.mx

RUG Pledge Register: www.rug.gob.mx

7.3. Arbitration institutions

Mexican Arbitration Centre (CAM): www.camex.com.mx

Mexican Arbitration Centre (CAMCA / ICC México).

7.4. Specialists in the enforcement of arbitral awards in Mexico

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Mexican Commercial Code (Código de Comercio), Book Five, Section IV, Articles 1415–1480 (UNCITRAL Model Law, 1993, as amended in 2011); Chapters VIII–IX. diputados.gob.mx

[2] The 1958 New York Convention; the 1975 Inter-American (Panama) Convention; Article 133 of the Mexican Constitution (the supreme law).

[3] Global Legal Insights — International Arbitration 2025, Mexico (the Convention does not apply to the setting aside or suspension of awards; awards in Spanish in Mexico).

[7] Commercial Code, Article 1047 (10-year limitation period); Article 1473 (15 working days to respond).

Analytical and reference materials

[4] Global Arbitration Review — Commercial Arbitration: Mexico; Guide to Arbitration in Latin America: Mexico (competent court; absence of specialised courts; abolition of double exequatur).

[5] Von Wobeser — Enforcing Arbitration Awards in Mexico (Article 1473 of the Commercial Code; without review on the merits).

[6] Article IV of the New York Convention; Von Wobeser v Mexico (documents; Spanish translation).

[8] Von Wobeser — Mexico; Global Arbitration Review — Mexico (grounds reflecting Article V of the Convention and the Panama Convention).

[9] Global Arbitration Review — Guide to Arbitration in Latin America: Mexico (arbitrators’ powers in relation to interim measures; 2011 amendments).

1.1. Key legislation

The recognition and enforcement of foreign arbitral awards in the Netherlands are governed by Articles 1075 and 1076 of the Dutch Code of Civil Procedure (Wetboek van Burgerlijke Rechtsvordering, referred to as the DCCP in English-language sources).[1]

Article 1075 of the DCCP — applies where a judgment is covered by an international treaty on recognition and enforcement (for example, the New York Convention);[1]

Article 1076 of the DCCP — applies in the absence of an applicable contract (or by virtue of any stipulations).[2]

Judgments rendered in the Netherlands (domestic) are enforced in accordance with different rules — Articles 1062–1063 of the DCCP (through a judge responsible for interim measures). Judgments are considered foreign if the place of arbitration is outside the Netherlands.[3]

1.2. Dual basis for submission

The applicant is entitled to rely on Articles 1075 and/or 1076 of the DCCP simultaneously — in practice, this is recommended. The advantage of Article 1075 (Convention) is that the grant of exequatur is not subject to appeal. The advantage of Article 1076 is that the judgment does not need to be enforceable in the country where it was given (which is useful, for example, if the time limit for enforcement has expired in that country). The choice between the two is based on the rule of the more favourable law (Article VII of the Convention).[4]

1.3. The New York Convention

The Netherlands signed and ratified the 1958 New York Convention in 1964.[5] Upon accession, a reservation regarding reciprocity was made: the Convention applies to judgments rendered in the territory of other Contracting States.

1.4. Stability of legislation

The current version of the arbitration legislation was introduced by the 2015 reform (in force since 1 January 2015) and remains stable; there are currently no proposals for a comprehensive reform.[6] The Netherlands is a leading centre for investment arbitration (The Hague).

2.1. The court of first instance

Since 1 January 2015, the Court of Appeal (Gerechtshof) has had jurisdiction over foreign arbitral awards — Articles 1075(2) and 1076(6) of the DCCP.[7] Previously (before the reform), such applications were heard by the judge responsible for interim measures at the district court. Jurisdiction is determined by the place where enforcement is sought.

2.2. Nature of the procedure

Unlike proceedings concerning domestic judgments (which are generally conducted ex parte), the examination of an application for the enforcement of a foreign judgment is adversarial in nature: the Court of Appeal hears both parties.[8] However, the court may grant exequatur without hearing the respondent if there are no grounds for refusal, whilst retaining the discretion to invite the respondent to present their case.[9]

2.3. The position of the Dutch courts

Dutch courts have traditionally taken a favourable view of the enforcement of arbitral awards; the grounds for refusal are interpreted restrictively.[10]

3.1. Procedure

An application (verzoekschrift) for enforcement must be lodged with the Court of Appeal through a Dutch lawyer authorised to practise before the courts. The general rules on the content of applications (Articles 261 et seq. of the DCCP) and on the procedure for the enforcement of foreign judgments (Articles 985 et seq. of the DCCP) also apply.[2]

3.2. Required documents

In accordance with Article IV of the New York Convention and Articles 1075 and 1076 of the DCCP, the following are attached:[2]

A duly authenticated original of the arbitral award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

Translation where necessary: the court may require a translation. In practice, Dutch judges take a pragmatic approach to decisions in English and do not always insist on a full translation.[11]

3.3. Legal costs

A court fee (griffierecht) is payable, the amount of which depends on the category of the case and the status of the applicant (for foreign judgments — in accordance with the Court of Appeal’s schedule of fees, Articles 1075/1076 of the DCCP). A domestic (Dutch) judgment is enforced differently — through the judge for interim measures at the District Court (Articles 1062–1063 DCCP), usually ex parte and at a lower griffierecht rate set by the District Court; thus, the fee is usually lower for a domestic judgment. The main other costs are the Dutch solicitor’s fees. As a general rule, the losing party reimburses the winning party’s legal costs; however, these are calculated according to a fixed scale approved by the court and, in practice, cover only part of the actual costs.[12]

Note: Current griffierecht fees are subject to verification at the time of submission.

3.4. Deadlines

Applications for exequatur where no objections are raised are processed efficiently — usually within approximately 6–12 weeks. Adversarial proceedings where objections are raised take longer, depending on the complexity of the case.[13]

3.5. Limitation period

A limitation period of 20 years applies to the enforcement of court and arbitration awards, commencing on the day following the date on which the award was made (or, if conditions have been set for enforcement, on the date on which those conditions are fulfilled).[14]

Under Article 1075 (Convention), the grounds set out in Article V of the New York Convention apply. Article 1076 of the DCCP establishes a similar list. The court does not review the merits of the case.[4]

4.1. Grounds (Article V of the Convention / Article 1076 of the DCCP)

Invalidity of the arbitration agreement / legal incapacity of the parties;

Breach of the procedure for the constitution of the arbitral tribunal;

The tribunal exceeding its mandate;

Inadequate notification / failure to present a case;

The decision may still be appealed (to the arbitrators or to the courts of the country where the award was made);

The decision has been set aside by the competent authority of the issuing country;

Contrary to public policy (ordre public).

4.2. Public order and the ECHR

Dutch courts interpret public policy restrictively — intervention is permitted only in exceptional cases. The right of access to a court of law (Article 6 of the ECHR), as well as the fundamental right to be heard, fall within the scope of public policy and are subject to review. The exequatur procedure must not be used as a disguised appeal.[15]

4.3. Special case: a decision set aside abroad

Dutch courts retain a certain degree of discretion under Article V(1)(e) of the Convention and, in exceptional cases, may enforce a judgment set aside in another jurisdiction, provided that this does not contravene public policy in the Netherlands.[16] In the Yukos Capital v Rosneft case, the Amsterdam Court of Appeal concluded that if a foreign setting-aside decision cannot be recognised under Dutch private international law, Article V(1)(e) need not be taken into account. In the NLMK case, the Supreme Court confirmed that the enforcing judge has discretion; the burden of proving exceptional circumstances lies with the party seeking recognition.[16]

A key feature of the Netherlands is the ‘asymmetric appeal’ rule under the Convention regime (Article 1075 of the DCCP):[17]

The granting of enforcement to a foreign judgment is, as a rule, NOT subject to appeal (except in cases of a breach of Article 6 of the ECHR) — Supreme Court, 25 June 2010 (Rosneft v Yukos Capital);[18]

A refusal to grant exequatur may be appealed all the way to the Supreme Court.

Under Article 1076 of the DCCP (in the absence of a contract), both the granting and the refusal of exequatur are subject to appeal. This is a practical argument in favour of bringing proceedings under Article 1075.[19]

Once an exequatur has been granted, the judgment is enforced in the same way as a Dutch court judgment. Enforcement is carried out by a bailiff (gerechtsdeurwaarder). Available at: [10]

Seizure (beslag) of movable and immovable property, and bank accounts;

A protective (provisional) attachment — conservatoir beslag — may be imposed either before or during the proceedings, subject to the authorisation of the judge responsible for protective measures;

Attachment of receivables (derdenbeslag) from third parties.

7.1. Mandatory representation

The application must be submitted through a Dutch lawyer (advocaat) who is authorised to appear in court. This is a mandatory requirement for foreign claimants.

7.2. Tracing the debtor’s assets

Useful resources:

Chamber of Commerce Trade Register (KvK Handelsregister): www.kvk.nl;

Land Registry (Kadaster): www.kadaster.nl;

Register of Ultimate Beneficial Owners (UBO) — via the KvK.

7.3. English in the workplace

If the parties so agree, proceedings may be conducted in English before the Netherlands Commercial Court (NCC) — which is convenient for international parties.[6]

7.4. Practical obstacles

Choice of legal basis (1075 vs 1076): this affects the possibility of appealing — it is worth planning your strategy in advance;

Authenticity of documents: the courts have dismissed cases where it was not possible to verify the authenticity of the arbitration agreement (for example, email correspondence);[2]

Adversarial nature: unlike in a number of jurisdictions, the procedure for enforcing a foreign judgment requires the debtor’s participation.

8.1. Legislation and official sources

Wetten.overheid.nl — Rv (Code of Civil Procedure), Articles 1020–1076

The New York Convention (Netherlands): newyorkconvention.org

The judicial system: rechtspraak.nl

8.2. Registers

Chamber of Commerce (KvK): www.kvk.nl

Kadaster: www.kadaster.nl

8.3. Arbitration institutions

The Netherlands Arbitration Institute (NAI): www.nai-nl.org

Permanent Court of Arbitration (PCA), The Hague: www.pca-cpa.org

8.4. Specialists in the enforcement of arbitral awards in the Netherlands

A list of recommended experts is available on the official website of the Riga Arbitration Court:

court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Dutch Code of Civil Procedure (Wetboek van Burgerlijke Rechtsvordering, Rv / DCCP), Articles 1075 and 1076; Articles 1062–1063 (domestic decisions). wetten.overheid.nl

[2] DCCP, Articles 1076, 985 et seq., 261 et seq. (procedure for filing and required documents); Article IV of the Convention.

[3] DCCP, sections 1020(3), 1057, 1064a, 1065 (form, termination, grounds); the 2015 reform of arbitration law.

[5] The 1958 New York Convention (Netherlands — since 1964, with a reservation regarding reciprocity), Articles IV, V and VII.

[14] DCCP — 20-year limitation period for the enforcement of judgements (Jus Mundi, country publication: Netherlands).

Case law

[16] Hoge Raad (Supreme Court), Yukos Capital v Rosneft; the NLMK case; Amsterdam Court of Appeal (2022) — discretion under Article V(1)(e).

[18] Supreme Court, 25 June 2010, ECLI:NL:HR:2010:BM1679 (Rosneft v Yukos Capital); 1 May 2015, ECLI:NL:HR:2015:1194; 31 March 2017, ECLI:NL:HR:2017:555.

[15] Amsterdam Court of Appeal, 10 November 2020; 29 January 2019 — public order and Article 6 of the ECHR.

Analytical and reference materials

[4] Wolfs Advocaten — Enforcement of international judgements (Part II): the choice between Articles 1075 and 1076, Article VII of the Convention.

[6] Global Legal Insights — International Arbitration Laws & Regulations 2026, Netherlands; Legal500 Country Guide.

[7] Jus Mundi — Netherlands country publication (jurisdiction of the Court of Appeal from 1 January 2015).

[8] Lexology — In brief: enforcing and challenging arbitral awards in the Netherlands (2023).

[9] Legal500 — The Netherlands: International Arbitration (ex parte, where there are no grounds for refusal).

[11] Jus Mundi / Court of Appeal, The Hague, 17 April 2018 — a pragmatic approach to the translation of English-language judgments.

[12] Lexology — fixed scale of legal costs; griffierecht.

[13] Global Legal Insights — processing times (6–12 weeks).

[17] LexisNexis UK — Dutch Court of Appeal confirms that no appeal may be lodged against exequatur (asymmetric appeal).

[19] Caland Lawyers — The Enforcement of Foreign Arbitral Awards in the Netherlands.

[10] Kluwer Arbitration Blog — Let's Go Dutch! (2023); a pro-arbitration approach.

1.1. Key legislation

Arbitration in Norway is governed by the Arbitration Act of 14 May 2004 No. 25 (Voldgiftsloven, NAA), which came into force on 1 January 2005 and is based on the 1985 UNCITRAL Model Law. The Act applies to domestic and international arbitration and governs the recognition and enforcement of awards (Sections 45–46). Enforcement itself is carried out under the Enforcement Act (Tvangsfullbyrdelsesloven) in conjunction with the Civil Procedure Act (Tvisteloven, § 19–16).[1]

The chapter on arbitration in the previous Civil Procedure Act was repealed when the Arbitration Act 2004 came into force.[2]

1.2. The New York Convention

Norway ratified the 1958 New York Convention on 14 March 1961 (which entered into force on 11 June 1961). A reservation on reciprocity was formally entered, but the implementing legislation (section 45 of the Arbitration Act) effectively waived its application: in practice, awards are recognised and enforced regardless of where they were made.[3]

1.3. Other international treaties

The 1965 Washington Convention on ICSID;

The 2007 Lugano Convention (for court judgments; it does not apply directly to arbitral awards).[4]

2.1. Direct enforcement without separate acknowledgement

Arbitral awards (both Norwegian and foreign) falling within the scope of the Convention are binding and enforceable in Norway. A separate procedure for recognition (exequatur) is not normally required: the award is enforced in the same way as a domestic court judgment, and any grounds for refusal are considered as part of the enforcement proceedings.[5]

2.2. Authority

An application for enforcement is submitted to the enforcement authority (Namsmyndighet / Namsfogden) in the jurisdiction where the debtor or their assets are located. In the event of a dispute regarding the grounds for refusal, the matter may be referred to the district court (tingrett).[6]

2.3. Condition of solvency

A decision must be enforceable in the country where it was made in order to be enforceable in Norway; whether it must be final depends on the law of the country where it was made. Settlements confirmed by an arbitral award have the same effect.[7]

3.1. Required documents

In accordance with Article IV of the New York Convention and the Arbitration Act, the following are attached:[8]

The original arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A translation is required if the documents are in a language other than English; however, decisions in English, Danish or Swedish do not require translation.

3.2. Legal costs

Fees charged by the enforcement authority and legal costs are taken into account; specific rates are subject to verification at the time of submission.[6]

The grounds are in accordance with Article V of the New York Convention (§§ 45–46 of the Arbitration Act).[9]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article V(2))

Non-arbitrability of a dispute under Norwegian law;

Contrary to public policy (ordre public).

The ‘ordre public’ exception applies if the result of recognition and enforcement would be contrary to the fundamental principles of the Norwegian legal system; it is the result that is assessed, not the law applied. Norwegian courts interpret this ground narrowly.[10]

Interim measures ordered by an arbitral tribunal in the form of a procedural order are not regarded as an ‘award’ for the purposes of recognition and enforcement, according to the explanatory notes to the Act. Once the award has been admitted, enforcement is carried out through the enforcement authority: seizure of property and bank accounts, and the realisation of the debtor’s assets.[11]

6.1. Tracing the debtor’s assets

Useful resources:

Business Register (Brønnøysundregistrene): www.brreg.no;

Land Registry (Kartverket / Grunnboken): www.kartverket.no;

The Enforcement Authority (Namsfogden) — via the police or the tax authorities.

6.2. Practical advantages and obstacles

Direct enforcement: a separate writ of execution is not usually required;[5]

Language flexibility: solutions in English, Danish or Swedish do not require translation;[8]

Ad hoc arbitration: Ad hoc arbitration is the norm in Norway — please bear this in mind when preparing documents.

7.1. Legislation and official sources

→ Lovdata — Voldgiftsloven (Arbitration Act 2004): lovdata.no

→ The New York Convention (Norway): newyorkconvention.org

7.2. Registers

Register of businesses: www.brreg.no

Cadastral register: www.kartverket.no

7.3. Arbitration institutions

The Oslo Chamber of Commerce’s Institute of Arbitration and Dispute Resolution (Nordic Arbitration): www.chamber.no

7.4. Specialists in the enforcement of arbitral awards in Norway

A list of recommended experts is available on the official website of the Riga Arbitration Court:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Norwegian Arbitration Act (Voldgiftsloven, No. 25 of 14 May 2004, in force since 1 January 2005), Sections 45–46; The Civil Procedure Act (Tvisteloven), Section 19-16; The Enforcement Act (Tvangsfullbyrdelsesloven). lovdata.no

[2] The repeal of the chapter on arbitration in the previous Civil Procedure Act upon the entry into force of the 2004 Act.

[3] The 1958 New York Convention (Norway — ratified on 14 March 1961, in force since 11 June 1961; the reciprocity clause is not applied in practice — section 45 of the Act).

[4] The 1965 Washington Convention on ICSID; the 2007 Lugano Convention (for court judgments).

Analytical and reference materials

[5] Global Arbitration Review — Norway (enforcement as if they were court judgments, regardless of where they were made); CMS Expert Guides — Norway.

[6] Mondaq — Enforcement of Foreign Judgments: Norway (Namsmyndighet; tingrett; costs).

[7] Mondaq — Norway (enforceability in the country of origin; settlement agreements).

[8] Global Arbitration Review — Norway (languages: English/Danish/Swedish, without translation; Article IV of the Convention).

[9] Lexology — Arbitration in Norway (sections 45–46 of the Act; Article V of the Convention).

[10] IBA — Public policy as a bar to recognition and enforcement in Norway (narrow interpretation).

[11] Springer — Interpretation and Application of the New York Convention by National Courts: Norway (interim measures are not regarded as a judgment; Ot.prp. no. 27 (2003–2004)).

1.1. Key legislation

Polish arbitration law is set out in Part V of the Code of Civil Procedure (Kodeks postępowania cywilnego, KPC; referred to as the CCP in English-language sources). These provisions were introduced by the Act of 28 July 2005 (in force since 17 October 2005) and are based on the 1985 UNCITRAL Model Law.[1]

Recognition and enforcement are governed by Section VIII of Part V of the KPC (Articles 1212–1217). Recognition or enforcement does not take place automatically: an arbitral award must undergo a judicial procedure for recognition or a declaration of enforceability (Article 1212 of the KPC). Two procedures are provided for: Article 1214 of the KPC for domestic awards, and Article 1215 of the KPC for foreign awards. An award is considered foreign if it was made outside Poland (territorial principle).[2]

1.2. The New York Convention

Poland is a party to the 1958 New York Convention (subject to a reservation regarding reciprocity). In most cases, the recognition and enforcement of foreign judgments are based precisely on this Convention.[3]

1.3. Legislative developments

The reform, which came into force on 1 January 2016, transferred the so-called post-arbitration procedures (annulment, as well as recognition and enforcement) to the courts of appeal as courts of sole instance — with the aim of speeding up proceedings and improving the quality of case law.[4] The 2023 reforms introduced a mechanism for referring a legal dispute to arbitration (Article 1161(1)(1) of the Code of Civil Procedure). It should be noted that the previously discussed draft provision on the complete exclusion of appeals against orders on recognition and enforcement was not adopted.

1.4. A pro-arbitration approach

The Supreme Court of Poland has emphasised the need to interpret arbitration agreements in favour of the arbitral tribunal’s jurisdiction, particularly in international trade (judgment of 1 December 2017, I CSK 170/17).[5] However, Polish courts are not bound by the decisions of other jurisdictions concerning the same arbitral award.[6]

2.1. The Court

Since 1 January 2016, applications for the recognition and enforcement of foreign arbitral awards have been heard by the Court of Appeal (Sąd Apelacyjny) as the court of sole instance.[4]

2.2. Appeals

As the Court of Appeal acts as the court of sole instance, there is no provision for an ordinary appeal; in specified cases, a cassation appeal (skarga kasacyjna) may be lodged with the Supreme Court of Poland.[7]

2.3. Nature of the procedure

The proceedings are conducted in accordance with the KPC rules; the parties are involved in the process. The court does not review the merits of the dispute.[8]

3.1. Content of the application

The application must contain details of the arbitral award, the tribunal and the parties, the claim (in whole or in part), including the allocation of costs, and a list of annexes. Documents must be submitted in Polish; there is no limit on the length.[9]

3.2. Required documents

In accordance with Article 1213 of the KPC and Article IV of the New York Convention, the following are attached:[10]

The original arbitration award or a copy thereof certified by the arbitral tribunal;

The original arbitration agreement or a copy thereof certified by a notary;

A translation into Polish certified by a sworn translator (or a consul), if the documents are in another language. In practice, it is recommended that a full translation be provided.[9]

A power of attorney (if the application is submitted by a representative) and copies of the application form and its annexes, one for each participant.

3.3. Legal costs

A fixed application fee of 300 zlotys (approximately 70 euros) has been set. A similar fee is payable in the event of a cassation appeal. In addition, the costs of a sworn translation and the fees of a Polish lawyer (advocate or legal adviser) should be taken into account.[11]

3.4. Deadlines

No specific official timeframes have been set. The transfer of cases to the courts of appeal (as part of the 2016 reform) was intended to speed up proceedings; the actual duration depends on the court’s caseload and whether any objections are raised.[4]

In the case of foreign judgments (Article 1215 of the Code of Civil Procedure), the grounds set out in Article V of the New York Convention apply. Some of these grounds are examined by the court of its own motion.[2]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to review by the court (Article V(2))

Non-arbitrability of a dispute under Polish law;

Inconsistency with the fundamental principles of the legal order of the Republic of Poland (public policy clause).

Public policy is interpreted narrowly and applied with particular caution; Polish courts do not distinguish between international and domestic public policy. The Supreme Court (judgment of April 2024, II CSKP 48/22) emphasised that the public policy exception applies only in exceptional cases of particularly gross violation; an error on the part of the tribunal (for example, regarding interest rates) does not, in itself, constitute grounds for refusal.[12]

4.3. Formal requirements: case law from 2024

Polish case law takes a strict approach to formal requirements. The Supreme Court (12 April 2024, II CSKP 1099/22) considered a refusal to recognise an ICC (ICC) on the grounds that there was no original or duly certified copy of the arbitration agreement accompanied by a sworn translation (only a scanned copy in German had been submitted).[13]

At the same time, a more lenient approach is emerging: recognition may be granted even in the absence of an arbitration agreement, provided that the existence of a foreign arbitration clause is not disputed; and a party which has defended itself on the merits in arbitration without challenging the jurisdiction may not subsequently rely on the absence or invalidity of the clause.[14]

Polish courts are entitled to order interim measures, including before the commencement of arbitration (in certain cases ex parte).[15] Once a decision has been declared enforceable (clausula executoria), it is enforced in accordance with the general rules of the Code of Civil Procedure (KPC) through a bailiff (komornik). Available at:

Seizure of movable property and bank accounts;

Foreclosure on property;

Seizure of receivables and shareholdings.

6.1. Representative Office

The proceedings are conducted through a Polish legal representative (adwokat or radca prawny). This is a requirement for foreign claimants.

6.2. Tracing the debtor’s assets

Useful resources:

National Court Register (KRS): ekrs.ms.gov.pl;

Central Register and Information on Economic Activity (CEIDG) — for sole traders: www.ceidg.gov.pl;

Land Registers (Księgi wieczyste): ekw.ms.gov.pl.

6.3. Practical obstacles

Strict formal requirements regarding documents: the original or a notarised copy of the arbitration agreement and a certified translation are required — any shortcomings will result in the application being rejected;[13]

Translation: a certified translation (tłumacz przysięgły) is required — allow for the time and costs involved;

Public policy: historically, Polish courts have sometimes shown a tendency to apply an extended test — the wording of the judgment is important.

7.1. Legislation and official sources

→ ISAP — KPC (Civil Procedure Code), Part V: isap.sejm.gov.pl

→ New York Convention (Poland): newyorkconvention.org

7.2. Registers

KRS Court Register: ekrs.ms.gov.pl

CEIDG: www.ceidg.gov.pl

7.3. Arbitration institutions

Arbitration Court at the Polish Chamber of Commerce (SAKIG, Warsaw): www.sakig.pl

Lewiatan Arbitration Court: www.sadarbitrazowy.org.pl

7.4. Specialists in the enforcement of arbitral awards in Poland

A list of recommended experts is available on the official website of the Riga Arbitration Court:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Polish Code of Civil Procedure (Kodeks postępowania cywilnego), Part V (Act of 28 July 2005, in force since 17 October 2005). ISAP: isap.sejm.gov.pl

[2] KPC, Section VIII of Part V, Articles 1212–1217 (in particular 1213, 1214 and 1215); grounds under Article V of the New York Convention.

[3] The 1958 New York Convention (Poland — subject to a reservation of reciprocity), Articles IV and V.

[4] The KPC reform, in force since 1 January 2016 — the transfer of post-arbitration proceedings to the courts of appeal; the 2023 reforms (Article 1161(1)(1)).

Case law

[5] Supreme Court, judgment of 1 December 2017, I CSK 170/17 — interpretation in favour of the arbitral tribunal’s jurisdiction.

[12] Supreme Court, April 2024, II CSKP 48/22 — a public policy reservation (Article 1206(2)(2) of the Code of Civil Procedure) applies only in exceptional cases.

[13] Supreme Court, 12 April 2024, II CSKP 1099/22 — formal requirements under Article IV of the Convention (original or certified copy of the agreement, sworn translation).

[14] Supreme Court, 19 January 2024, II CSKP 897/22; Baker McKenzie Yearbook 2024–2025 — relaxation of requirements where the existence of a reservation is undisputed.

Analytical and reference materials

[6] Global Arbitration Review — Challenging and Enforcing Arbitration Awards: Poland (Gide Loyrette Nouel) — Polish courts are not bound by decisions of other jurisdictions.

[7] Global Arbitration Review — Poland (appeal to the Supreme Court).

[8] CMS Expert Guides — International arbitration law and rules in Poland (2025).

[9] Global Arbitration Review — The Guide to Challenging and Enforcing Arbitration Awards, 4th ed., Poland (fixed fee of 300 zlotys; translation requirements).

[10] Baker McKenzie International Arbitration Yearbook 2024–2025, Poland (Article 1213 of the Code of Civil Procedure).

[11] Baker McKenzie — Cross-Border Enforcement Centre, Poland (court fees; certified translation).

[15] Delos — Guide to Arbitration Places (GAP), Poland (interim measures; Article 1215 of the Code of Civil Procedure).

1.1. Key legislation

Arbitration in Portugal is governed by the Voluntary Arbitration Act (Lei da Arbitragem Voluntária, LAV — Law No. 63/2011 of 14 December 2011, in force since 15 March 2012), which replaced the 1986 Act and follows the UNCITRAL Model Law (1985 and 2006 versions). The reform was carried out as part of structural reforms involving the IMF and EU institutions.[1]

The recognition and enforcement of foreign judgments are governed by Articles 55–58 of the LAV, which incorporate Articles IV, V and VI of the New York Convention; Article 706(1) of the Code of Civil Procedure also applies.[2]

1.2. The New York Convention

Portugal ratified the 1958 New York Convention (Decree of the President of the Republic No. 52/94 of 8 July 1994), entering a reservation regarding reciprocity. The practical effect of the reservation is limited by the rule of the more favourable law, the existence of other treaties and the similarity between the requirements of the LAV and those of the Convention.[3]

1.3. Other international treaties

The 1965 Washington Convention on ICSID;

Bilateral agreements on legal cooperation with Portuguese-speaking countries (Angola, Cape Verde, Guinea-Bissau, Mozambique, São Tomé and Príncipe).[4]

2.1. Two distinct stages

Without prejudice to the mandatory provisions of the Convention and other treaties, a foreign judgment may be enforced in Portugal only after a recognition procedure has been completed. Recognition and enforcement are divided into two stages.[5]

2.2. The court’s decision to recognise

An application for recognition must be lodged with the Court of Appeal (Tribunal da Relação) of the judicial district in which the person against whom the decision is invoked is domiciled. For disputes falling within the jurisdiction of the administrative courts, the Central Administrative Court has jurisdiction.[6]

2.3. Enforcement Court

Once recognised, enforcement is carried out by the court of first instance at the debtor’s place of residence. Only a final judgment (having the force of res judicata) is recognised and enforced. It is not necessary to identify assets at the recognition stage — this may be required at the enforcement stage.[7]

2.4. Appeals

A decision by the Court of Appeal to grant (or refuse) an application may be appealed to the Supreme Court (Supremo Tribunal de Justiça) in accordance with the general rules, provided the relevant conditions are met.[8]

3.1. Required documents

In accordance with Article IV of the New York Convention (incorporated into the LAV), the following are annexed:[2]

A certified original of the arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A certified translation into Portuguese, if the documents are in another language.

3.2. Time limits for objections

The LAV does not explicitly set a time limit for lodging objections. In legal theory and practice, there are two positions: a subsidiary time limit of 10 days (for example, the decision of the Lisbon Court of Appeal of 26 September 2019, Case No. 406/19.1YRLSB) or 30 days (the time limit for submitting a defence under the Code of Civil Procedure).[9]

3.3. Legal costs

Court fees (custas) are payable in accordance with the general rules, as well as costs for a certified translation and legal assistance. The specific amounts are subject to verification at the time of submission.[6]

The grounds are in accordance with Article V of the New York Convention (where applicable) or equivalent grounds under the LAV. A review of the case on its merits is not permitted.[10]

4.1. Grounds based on the debtor’s application

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds to be examined by the court

Non-arbitrability of the dispute under Portuguese law;

A clear contradiction of international public order.

A decision may be recognised or enforced even where set-aside proceedings are pending at the seat of arbitration; a stay is not mandatory. When deciding on a stay, the Portuguese courts have broad discretion and assess the prospects of success of the annulment proceedings, the anticipated duration of the stay, the harm to the claimant and the adequacy of the security.[11]

The arbitral tribunal is entitled to order interim measures (without an ex parte ruling), which are enforceable through the state courts; their recognition and enforcement are governed by the LAV, not by the Convention. Once recognised, the award is enforced as an enforceable instrument (through a bailiff — agente de execução).[12]

6.1. Tracing the debtor’s assets

Useful resources:

Company Register (Portal Justiça / Registo Comercial): publicacoes.mj.pt;

The portal for companies’ public data — via the Instituto dos Registos e do Notariado (IRN);

Land Register (Predial Online): www.predialonline.pt.

6.2. Practical advantages and obstacles

Two stages: recognition (Relação) and enforcement (first instance) — these are separate proceedings, which extends the timeframe;

Uncertainty regarding the time limit for objections (10 vs 30 days) — bear this in mind when planning;[9]

Lusophone agreements: a contractual arrangement may be possible for solutions from Portuguese-speaking countries.

7.1. Legislation and official sources

→ DRE — Law 63/2011 (LAV): dre.pt

→ The New York Convention (Portugal): newyorkconvention.org

7.2. Registers

Register of Companies: publicacoes.mj.pt

Predial Online Land Register: www.predialonline.pt

7.3. Arbitration institutions

Arbitration Centre of the Portuguese Chamber of Commerce (CAC): www.centrodearbitragem.pt

7.4. Specialists in the enforcement of arbitral awards in Portugal

A list of recommended experts is available on the official website of the Riga Arbitration Court:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] Law on Voluntary Arbitration (Lei da Arbitragem Voluntária, Law No. 63/2011 of 14 December 2011, in force since 15 March 2012). DRE: dre.pt

[2] LAV, Articles 55–58, 59; Code of Civil Procedure, Article 706(1); Articles IV–VI of the New York Convention.

[3] The 1958 New York Convention (Portugal — Presidential Decree No. 52/94 of 8 July 1994, reservation regarding reciprocity).

[4] The 1965 Washington Convention on ICSID; bilateral treaties with Angola, Cape Verde, Guinea-Bissau, Mozambique, and São Tomé and Príncipe.

Case law

[9] Lisbon Court of Appeal, 26 September 2019, Case No. 406/19.1YRLSB (time limit for lodging objections).

Analytical and reference materials

[5] CMS Expert Guides — International arbitration in Portugal; Global Arbitration Review — Portugal (recognition prior to enforcement).

[6] Global Arbitration Review — Portugal (Tribunal da Relação; Central Administrative Court).

[7] Global Arbitration Review — Portugal (court of first instance for enforcement; res judicata).

[8] Lexology — Global arbitrations around the world: Portugal (appeal to the STJ).

[10] Jus Mundi — Portugal country publication; prohibition of révision au fond.

[11] Lexology — Portugal (suspension upon revocation; judicial discretion).

[12] CMS Expert Guides — Portugal (interim measures ordered by arbitrators; Articles 56–57 of the LAV).

1.1. Key legislation

Arbitration in Qatar is governed by the Civil and Commercial Arbitration Act No. 2 of 2017, which is based on the UNCITRAL Model Law and replaced the previous provisions of the Civil and Commercial Procedure Code (Law No. 13 of 1990, Articles 190–210). The 2017 Law has significantly modernised the regime for the recognition and enforcement of awards.[1]

A separate system applies to arbitration proceedings conducted under the auspices of the Qatar Financial Centre (QFC): the QFC Civil and Commercial Court has exclusive jurisdiction over the enforcement of QFC awards and also applies the Arbitration Law.[2]

1.2. The New York Convention and other treaties

Qatar acceded to the 1958 New York Convention on 30 December 2002 (ratified by Emirate Decree No. 29 of 15 March 2003) without reservations. Qatar is also a party to the Riyadh Convention (Arab States) and the Convention on Cooperation among the States of the Gulf Cooperation Council (GCC Convention). Under the Riyadh Convention, recognition and enforcement are possible without reviewing the substance of the dispute, provided that the judgment does not contravene public policy, public morality or the principles of Sharia.[3]

2.1. Authority

An application for enforcement is filed with the competent judge — the enforcement judge of the local courts or the QFC Court (as appropriate) — in accordance with section 34(3) of the Arbitration Act. The relevant judge has the power to recognise and enforce the award or to refuse to do so.[4]

2.2. Nature of the procedure

An application for recognition and enforcement is not, as a rule, considered on an ex parte basis: the other party is given notice and the opportunity to present its case. At this stage, the party against whom enforcement is sought is entitled to lodge an objection and request that recognition and enforcement be refused. The standard of review is in line with the New York Convention and makes no distinction between foreign and domestic judgments.[5]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are annexed:[6]

A certified original of the arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A certified translation into Arabic (for local courts; proceedings at the QFC are conducted in English).

3.2. Timelines and costs

The timeframe depends on the complexity of the case and the courts’ caseload, and usually takes several months. Court fees, translation costs and legal fees are taken into account.[5]

The grounds are set out in Article 35 of the Arbitration Act and are consistent with Article V of the New York Convention. Qatari courts generally adopt a pro-enforcement approach.[7]

4.1. Grounds based on the debtor’s application (Article 35(1) / Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision has not become binding or has been set aside or suspended in the country in which it was made (Article 35(1)(e)).

4.2. Grounds subject to judicial review (Article 35(2) / Article V(2))

The dispute is not arbitrable under Qatari law;

Contrary to public policy in the State of Qatar.

The Act expressly permits a refusal to enforce a foreign award that has been set aside or stayed at the seat of arbitration (Article 35(1)(e)). An application to set aside an award will, as a rule, stay its enforcement unless the court orders otherwise. Once enforcement has been authorised, the enforcement is carried out by the enforcement judge: seizure and realisation of property, and attachment of the debtor’s accounts and assets.[8]

6.1. Tracing the debtor’s assets

Useful resources:

Company Register (Ministry of Trade and Industry): www.moci.gov.qa;

QFC Register (for QFC structures): www.qfc.qa;

Ministry of Justice (property, enforcement): www.moj.gov.qa.

6.2. Practical advantages and obstacles

No reservations to the Convention: a broad scope of recognised judgments;[3]

Two options: the local courts or the QFC (for QFC rulings);[2]

Objection to a refusal: this may be more convenient for the debtor than a revocation (as it is not subject to strict time limits).

7.1. Legislation and official sources

→ Al Meezan — Qatar’s legislation portal: www.almeezan.qa

→ The New York Convention (Qatar): newyorkconvention.org

7.2. Registers

Ministry of Trade and Industry: www.moci.gov.qa

QFC Register: www.qfc.qa

7.3. Arbitration institutions

Qatar International Centre for Conciliation and Arbitration (QICCA): www.qicca.org

QFC Arbitration Centre (QICDRC).

7.4. Specialists in the enforcement of arbitral awards in Qatar

A list of recommended experts is available on the official website of the Riga Arbitration Court:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] Qatar’s Law No. 2 of 2017 on Arbitration in Civil and Commercial Matters (UNCITRAL Model Law); previously — the Civil and Commercial Procedure Code No. 13 of 1990, Articles 190–210. almeezan.qa

[2] QFC regime — exclusive jurisdiction of the QFC court over QFC awards; application of the Arbitration Act.

[3] The 1958 New York Convention (Qatar — as of 30 December 2002, Emir’s Decree No. 29 of 15 March 2003, without reservations); The Riyadh Convention; the GCC Convention (Gulf Convention).

[6] Article IV of the New York Convention (documents; Arabic translation).

[7] Qatar Arbitration Act, Article 35 (grounds for refusal = Article V of the Convention); Article 34(3) (competent judge).

[8] Qatar Arbitration Act, Article 35(1)(e) (refusal in the event of annulment or suspension at the place of arbitration).

Analytical and reference materials

[4] Crowell — A Look at Enforcing and Contesting Arbitral Awards in Qatar (Article 34(3); enforcement judge / QFC court).

[5] Legal500 — Qatar: International Arbitration (Convention standard; notice, not ex parte; time limits).

1.1. Key legislation

The recognition and enforcement of foreign arbitral awards are governed by Articles 1124–1133 of the Romanian Code of Civil Procedure (Codul de procedură civilă, CPC). Enforcement itself is carried out in accordance with Book V of the CPC (Despre executarea silită — ‘On Enforcement’).[1]

Under Article 1124 of the CPC, a foreign award is defined as any domestic or international arbitral award rendered in a foreign state and not regarded as a domestic award in Romania. Under Article 1125 of the CPC, such an award shall be recognised and enforced provided that the subject matter of the dispute is capable of being referred to arbitration in Romania and the award does not contravene the public policy of Romanian private international law.[2]

1.2. The New York Convention

Romania is a party to the 1958 New York Convention; the conditions for recognition under the Code of Civil Procedure are in line with the Convention’s standards. The regime (the Convention or Articles 1124–1133 of the Code of Civil Procedure) that is more favourable to recognition and enforcement applies.[3]

1.3. Two procedures

A distinction must be made between two procedures: (i) the recognition and enforcement of a foreign judgment (exequatur) under the New York Convention and Articles 1124–1133 of the CPC; (ii) enforcement itself, carried out by a bailiff in accordance with Book V of the Code of Civil Procedure. First, an application for recognition and enforcement is filed; once this has been granted, enforcement proceedings are initiated through a bailiff (executor judecătoresc).[4]

2.1. The Court

An application for recognition and enforcement shall be lodged with the tribunal (tribunal — district court) at the place of domicile or, where necessary, at the place of business (seat) of the person against whom enforcement is sought. If it is not possible to determine such a court, the Bucharest Tribunal has jurisdiction.[5]

2.2. Nature of the inspection

In the context of exequatur proceedings, the court merely verifies compliance with formal requirements and the absence of grounds for refusal; a review of the decision on the merits is not permitted (prohibition of révision au fond), nor is the court authorised to amend the decision. Once exequatur has been granted, the judgment acquires the force of res judicata within Romania, and enforcement proceedings may commence.[6]

2.3. Final decisions only

Only final awards are enforceable. Interim awards (concerning interim or provisional measures, and those with provisional enforceability) are not subject to compulsory enforcement; partial awards that finally resolve the dispute may be recognised and enforced. Emergency measures ordered by the arbitrator and procedural orders are enforced only on a voluntary basis.[7]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are annexed:[8]

The original arbitration award or a copy thereof (either the original or a copy is sufficient);

The original arbitration agreement or a copy thereof;

A translation into Romanian, if the documents are drawn up in another language (the translation must be certified by the submitting party as a true copy of the original);

Additional copies, one for each party to be summoned, if their attendance is required.

3.2. Legal costs

This includes lawyers’ fees, bailiff’s fees and the court stamp duty for enforcement (under Emergency Ordinance No. 80/2013), as well as any other possible costs incurred in challenging the enforcement.[9]

3.3. Limitation period

There is no specific time limit for lodging an application for recognition and enforcement; the lodging of an application for recognition interrupts (suspends) the running of the time limit for enforcement. However, enforcement will be refused if the right to claim enforcement has been forfeited under the law of the State in which the place of arbitration is situated (Articles 1104(1), 1100 and 1129(f) of the CPC).[10]

The grounds are in accordance with Article V of the New York Convention and Articles 1124–1133 of the CPC; they are common to the Civil Procedure Code, EU Regulation No 1215/2012 and the Convention.[11]

4.1. Main grounds

Disturbance of public order (Romanian Ministry of Emergency Situations);

Breach of the right to a fair trial (inadequate notification);

Issues relating to jurisdiction or the composition of the tribunal;

The fact that the decision is not final or binding;

The invalidity or absence of an arbitration agreement;

Non-arbitrability of the subject matter of the dispute under Romanian law.

The grounds for setting aside domestic decisions are set out in Article 608 of the CPC, whilst the formal requirements for decisions are set out in Article 603 of the CPC.[12]

Once the writ of execution has been issued, and in the absence of voluntary compliance, the claimant initiates enforcement proceedings under Book V of the Code of Civil Procedure through a court enforcement officer (executor judecătoresc): the attachment of the debtor’s property, bank accounts and other assets.[4]

Interim measures issued in the form of a procedural order or by an emergency arbitrator prior to the constitution of the tribunal are not enforceable in Romania — they are enforced only on a voluntary basis.[7]

6.1. Tracing the debtor’s assets

Useful resources:

Commercial Register (ONRC): www.onrc.ro;

Electronic Register of Provisional Measures (RNPM): www.rnpm.ro;

Union of Judicial Enforcement Officers (UNEJ): www.executori.ro.

6.2. Practical advantages and obstacles

Two stages: exequatur, followed by enforcement under Book V — separate proceedings;[4]

Link to the law of the place of arbitration: enforcement will be refused if the right to enforcement has been lost there;[10]

Only final decisions: interim and protective measures are not enforceable.

7.1. Legislation and official sources

→ Legislativ Portal — Code of Civil Procedure (Codul de procedură civilă): legislatie.just.ro

→ The New York Convention (Romania): newyorkconvention.org

7.2. Registers

ONRC Commercial Register: www.onrc.ro

UNEJ Performers’ Union: www.executori.ro

7.3. Arbitration institutions

The Court of International Commercial Arbitration at the Romanian Chamber of Commerce and Industry (CICA): arbitration.ccir.ro

7.4. Specialists in the enforcement of arbitral awards in Romania

A list of recommended experts is available on the official website of the Riga Arbitration Court:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Romanian Code of Civil Procedure (Codul de procedură civilă), Articles 1124–1133; Book V (On Enforcement). legislatie.just.ro

[2] CPC, Article 1124 (recognition of a foreign judgment), 1125 (conditions for recognition); Articles 603 and 608 of the CPC.

[3] The 1958 New York Convention (to which Romania is a party), Articles IV and V; the principle of more favourable treatment.

[10] CPC, Articles 1100, 1104(1) and 1129(f) — limitation periods and reference to the law of the place of arbitration.

Analytical and reference materials

[4] Aarna Law — Romania: The Enforcement of Arbitral Awards (two procedures; Book V of the Code of Civil Procedure).

[5] CMS Expert Guides — Recognition and enforcement of foreign judgements in Romania (competent court; Bucharest Court).

[6] Legal500 — Recognition and Enforcement of Foreign Judgments and Arbitral Awards in Romania (exequatur; prohibition on review on the merits).

[7] Legal500 / Aarna Law — Romania (final awards only; interim measures ordered by the arbitrator).

[8] Jus Mundi — Romania country publication (documents; translated into Romanian).

[9] Lexology — In brief: enforcing and challenging arbitral awards in Romania (Stoica & Asociații); Emergency Ordinance No. 80/2013.

[11] Legal500 — Romania (grounds for refusal: public policy, right to a fair trial, jurisdiction, res judicata).

[12] Lexology — Romania (Article 608 of the CPC — setting aside; Article 603 of the CPC — form of the judgment).

1.1. Key legislation

Arbitration in the Kingdom of Saudi Arabia is governed by the Arbitration Act (Royal Decree No. M/34 of 1433 AH / 2012), which is based on the 1985 UNCITRAL Model Law and replaced the previous law of 1983. The recognition and enforcement of awards (including foreign awards) are governed by the Enforcement Act (Royal Decree No. M/53 of 1433 AH / 2012), which came into force on 27 February 2013, and its subordinate legislation (Cabinet Decision No. 261/1433).[1]

The Enforcement Act introduced, for the first time, the office of enforcement judge (qadi al-tanfiz) and specialised enforcement courts, which have exclusive jurisdiction over domestic and foreign court judgements and arbitral awards. Until 14 February 2013, the enforcement of foreign judgements fell within the remit of the Board of Grievances.[2]

1.2. The New York Convention

Saudi Arabia acceded to the 1958 New York Convention in 1994, subject to a reservation regarding reciprocity (and without retroactive effect). Saudi courts have confirmed that the state of the seat of arbitration’s membership of the Convention is sufficient to establish reciprocity; in practice, reciprocity is confirmed by a corresponding declaration from the Ministry of Justice.[3]

2.1. Authority

The application is submitted to the enforcement judge (qadi al-tanfiz) of the specialised enforcement court. The judge carries out a limited review: he does not re-examine the substance of the dispute or re-evaluate the arbitrator’s award, but checks that formal requirements have been met and that there are no grounds for refusal.[4]

2.2. Conditions for issuing an enforcement order

The Enforcement Act requires that an enforcement order be issued promptly, provided that the following conditions are met: (i) the judgment is final and not subject to appeal under the law of the country in which it was rendered; (ii) the judgment does not conflict with a previous judgment of a Saudi court on the same matter; (iii) the judgment does not contravene the principles of Sharia or public policy in the Kingdom; (iv) the party against whom enforcement is sought has been duly notified.[5]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are annexed:[6]

A certified original of the arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A certified translation into Arabic (usually legalised).

The award must comply with the formal requirements of Article 42 of the Arbitration Act: it must be in writing, reasoned and signed by the arbitral tribunal (in the case of a collegial tribunal, by a majority).[7]

3.2. Legal costs

Court fees and costs relating to translation, legalisation and legal support are taken into account; specific rates are subject to verification at the time of submission.[4]

The grounds are in accordance with Article V of the New York Convention; the key criteria are compliance with Sharia law and public policy.[8]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article V(2))

Disputes that cannot be settled by arbitration under Saudi law (e.g. criminal matters and certain family law issues);

Inconsistency with Sharia law and public policy in the Kingdom (section 11 of the Enforcement Act; section 55 of the Arbitration Act).

If a part of a judgement that contravenes Sharia law or public policy is severable, only that part is not enforced, whilst the remainder is enforceable. In particular, any interest (riba) awarded is, as a rule, not enforced, whereas the principal amount of the debt is enforced. In recent years, there has been a trend towards a narrower, international interpretation of public policy.[9]

The scope of interim measures is limited. Once an enforcement order has been issued, enforcement is carried out by the enforcement judge: seizure and sale of property, and attachment of the debtor’s bank accounts and assets. Issues of sovereign immunity must be taken into account when enforcing against state entities.[10]

6.1. Tracing the debtor’s assets

Useful resources:

Company Register (Ministry of Trade): mc.gov.sa;

The ‘Najiz’ platform (Ministry of Justice) — enforcement proceedings: najiz.sa;

Saudi Centre for Commercial Arbitration (SCCA): www.sadr.org.

6.2. Practical advantages and obstacles

Sharia compliance: interest is not usually permitted — structure your requirements accordingly;[9]

Finality: confirm that the award is final under the law of the place of arbitration;[5]

Translation and legalisation: please ensure you have a certified Arabic translation ready in advance.

7.1. Legislation and official sources

→ Bureau of Experts (Saudi legislation): laws.boe.gov.sa

→ The New York Convention (Saudi Arabia): newyorkconvention.org

7.2. Registers

Ministry of Trade: mc.gov.sa

The Najiz platform: najiz.sa

7.3. Arbitration institutions

Saudi Centre for Commercial Arbitration (SCCA): www.sadr.org

7.4. Specialists in the enforcement of arbitral awards in Saudi Arabia

A list of recommended experts is available on the official website of the Riga Arbitration Court:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Saudi Arabian Arbitration Law (Royal Decree No. M/34 of 1433 AH / 2012; the 1985 UNCITRAL Model Law); The Enforcement Act (Royal Decree No. M/53 of 1433 AH / 2012, in force since 27 February 2013; Cabinet Decision No. 261/1433). laws.boe.gov.sa

[2] The Enforcement Act — the office of the enforcement judge (qadi al-tanfiz); specialised enforcement courts; formerly — the Complaints Review Board.

[3] The 1958 New York Convention (Saudi Arabia — acceded in 1994; reservation regarding reciprocity); confirmation of reciprocity by a statement from the Ministry of Justice.

[6] Article IV of the New York Convention (documents; Arabic translation).

[7] The Arbitration Act, section 42 (formal requirements for an award); section 55 (public policy/Sharia); the Enforcement Act, section 11.

Analytical and reference materials

[4] attorney.sa — Enforcing Foreign Arbitration Awards in Saudi Arabia (limited review; no review of the merits).

[5] attorney.sa; Aceris Law — The Legal Framework for the Enforcement of Arbitral Awards in Saudi Arabia (conditions for the issuance of an order).

[8] Dentons — Enforcement of Arbitral Awards (KSA); IBA Arbitration Guide: Saudi Arabia (grounds; Article V of the Convention).

[9] Pinsent Masons — Enforcing foreign arbitral awards in Saudi Arabia (interest/riba; severability; narrow interpretation of public policy).

[10] Mondaq — Enforcement of Arbitral Awards in Saudi Arabia (interim measures; sovereign immunity; rise in the number of applications).

1.1. Key legislation

Arbitration in Serbia is governed by the Arbitration Act 2006 (Zakon o arbitraži), which is based on the 1985 UNCITRAL Model Law. The recognition and enforcement of foreign awards are governed by Chapter IX (Articles 64–68) of this Act, which contains the same rules as the New York Convention. Enforcement itself is carried out in accordance with the Enforcement and Security Act (Official Gazette of the Republic of Serbia, No. 106/2015).[1]

1.2. The New York Convention

Serbia is a party to the 1958 New York Convention by virtue of succession (formerly the SFRY; the notification of succession confirmed the 1982 declaration). Although the SFRY had entered a reservation regarding reciprocity, this has become irrelevant: the 2006 Arbitration Act does not require reciprocity for the recognition of foreign awards. The requirement that the matter be of a commercial nature is also no longer applied.[2]

1.3. Other international treaties

The 1961 European Convention and the ICSID Washington Convention;

Bilateral treaties on recognition and enforcement.[3]

2.1. Recognition and enforcement

Domestic final awards have the force of a final and binding court judgement; foreign arbitral awards acquire such force upon their recognition. A foreign award must be recognised before it can be enforced; once recognised, it has the force of a final and binding domestic judgement.[4]

2.2. Appeals

The right to appeal against a decision of the court of first instance is provided for within 30 days of receiving it.[5]

2.3. Monitoring of internal decisions

Internal decisions may be reviewed through the annulment of an arbitral award; in particular, an award may be set aside if it is based on false testimony by a witness or expert, forged documents, or criminal acts by the arbitrators or the parties (as established by a final judgement).[6]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are annexed:[7]

A certified original of the arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A certified translation into Serbian, if the documents are in another language.

3.2. Limitation period

Serbian law does not specify a particular time limit for lodging an application for the recognition and enforcement of a foreign judgment; there is no case law that expressly addresses this issue.[8]

3.3. Legal costs

Court fees, translation costs and legal fees are taken into account; specific rates are subject to verification at the time of filing.[4]

The grounds are in accordance with Article V of the New York Convention (the Arbitration Act contains identical provisions).[9]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or failure to state one’s position;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article V(2))

Non-arbitrability of the dispute under Serbian law;

Contrary to public order in Serbia.

Once the judgment has been recognised, enforcement is carried out in accordance with the Law on Enforcement and Security through bailiffs (javni izvršitelj): seizure of property and bank accounts, and the realisation of the debtor’s assets.[10]

Special rule: enforcement proceedings against a foreign state or an international organisation are permitted only with the written authorisation of the Ministry of Foreign Affairs or with the express consent of that state or organisation.[11]

6.1. Tracing the debtor’s assets

Useful resources:

Agency for Business Registers (APR): www.apr.gov.rs;

Land Registry (RGZ): www.rgz.gov.rs;

Chamber of Bailiffs (Komora javnih izvršitelja): www.komoraizvrsitelja.rs.

6.2. Practical advantages and obstacles

No reciprocity or commercial requirements: the 2006 Act does not impose any such requirements;[2]

Translation into Serbian — allow for time and costs;

State assets: enforcement against a state or an international organisation is permitted only with the authorisation or consent of the Ministry of Foreign Affairs.

7.1. Legislation and official sources

→ pravno-informacioni-sistem.rs — Arbitration Act 2006: pravno-informacioni-sistem.rs

→ New York Convention (Serbia): newyorkconvention.org

7.2. Registers

Agency for Business Registers: www.apr.gov.rs

RGZ Land Registry: www.rgz.gov.rs

7.3. Arbitration institutions

Arbitration Court at the Serbian Chamber of Commerce and Industry (Belgrade Arbitration Centre): www.bac.org.rs

7.4. Specialists in the enforcement of arbitral awards in Serbia

A list of recommended experts is available on the official website of the Riga Arbitration Court:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Serbian Arbitration Act 2006 (Zakon o arbitraži), Chapter IX, Articles 64–68; The Enforcement and Security Act (Official Gazette of the Republic of Serbia No. 106/2015). pravno-informacioni-sistem.rs

[2] The 1958 New York Convention (Serbia — successor state since 27 April 1992; the reciprocity reservation has ceased to apply; the commercial requirement was repealed by the 2006 Act).

[3] The 1961 European Convention; the ICSID Washington Convention; bilateral treaties.

Analytical and reference materials

[4] Lexology — In brief: arbitration formalities in Serbia (recognition of a foreign award prior to enforcement; internal validity).

[5] Lexology — Serbia (appeal against a first-instance judgment — 30 days).

[6] Global Arbitration Review — Commercial Arbitration: Serbia (Schoenherr) — setting aside domestic awards; key features of the 2006 Act.

[7] Article IV of the New York Convention (documents; translation).

[8] Jus Mundi — Serbia (no specific limitation period).

[9] Jus Mundi — Serbia; Lexology — Serbia (grounds set out in Article V of the Convention; identity of the rules).

[10] Jus Mundi — Serbia (Enforcement and Security Act No. 106/2015).

[11] Global Arbitration Review — Serbia (enforcement against a foreign state — authorisation by the Ministry of Foreign Affairs / consent).

1.1. Key legislation

Arbitration in Singapore is governed by two pieces of legislation: the International Arbitration Act 1994 (IAA) — for international arbitration seated in Singapore and for foreign awards — and the Arbitration Act 2001 ( AA) — for domestic arbitration. The IAA incorporates the UNCITRAL Model Law (section 3(1)). Procedural matters are governed by the Rules of Court 2021.[1]

A foreign award (Convention award) is defined in Article 27(1) of the IAA as an award made pursuant to an arbitration agreement within the territory of a Contracting State to the New York Convention other than Singapore. Under Article 29 of the IAA, such an award is enforced either by way of an action or in the same manner as a Singaporean award under Article 19 of the IAA. Awards from states that are not parties to the Convention are enforced under Article 46(3) of the AA (as domestic awards).[2]

1.2. The New York Convention

Singapore is a party to the New York Convention; a foreign judgment under the IAA is presumed to be enforceable unless one of the grounds for refusal under Article 31 of the IAA applies. The court does not review the merits of the case.[3]

2.1. The Court

The application is filed with the High Court of Singapore (General Division). Generally speaking, there are no requirements regarding jurisdiction (such as the debtor’s domicile or assets), other than the fact that the decision must be a Convention award.[4]

2.2. Nature of the procedure

An application for leave to enforce is made to the High Court on an ex parte basis (an introductory application with an affidavit — Rules of Court 2021, Order 48). Where leave is granted, the award is enforced in the same way as a court order, and a court order may be made in the terms of the arbitral award. The proceedings for recognition are adversarial in nature; the court may order the parties to appear.[5]

3.1. Required documents

In accordance with the IAA (and Article IV of the New York Convention), the following are attached:[6]

The original arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A certified translation, if the decision or agreement is drawn up in a foreign language.

3.2. Limitation period

An application for a writ of execution must be made within six years of the date on which the judgment was given (Limitation Act 1959, section 6(1)(c)).[7]

3.3. Legal costs

Fees are charged in accordance with the Fourth Schedule to the Rules of the Court; translation and legal assistance costs are also taken into account.[5]

The grounds are set out in Article 31 of the IAA and are consistent with Article V of the New York Convention; the Singapore courts interpret them narrowly.[8]

4.1. Grounds based on the debtor’s application (Article 31(2) of the IAA / Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or failure to state one’s position;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to judicial review (Article 31(4) of the IAA / Article V(2))

The dispute is not subject to arbitration under Singapore law;

Contrary to public order in Singapore.

Singapore adopts a pro-arbitration approach: awards made by an ad hoc arbitrator (including those from foreign arbitration) are enforceable under section 29 of the IAA (CVG v CVH [2022] SGHC 249). Once authorisation has been granted, enforcement proceeds in the same way as for a court order: attachment of property and bank accounts (garnishee), and seizure of the debtor’s assets.[9]

6.1. Tracing the debtor’s assets

Useful resources:

ACRA Company Register (BizFile): www.bizfile.gov.sg;

Singapore Land Authority (INLIS) — property information: www.sla.gov.sg;

Court portal (eLitigation): www.elitigation.sg.

6.2. Practical advantages and obstacles

Presumption of enforceability: a foreign judgment is enforceable unless grounds for refusal are established;[3]

Emergency arbitrator: decisions made by an emergency arbitrator are enforceable (CVG v CVH);[9]

Leading hub: SIAC / Maxwell Chambers’ well-established infrastructure — a predictable practice.

7.1. Legislation and official sources

→ Singapore Statutes Online — IAA: sso.agc.gov.sg

→ New York Convention (Singapore): newyorkconvention.org

7.2. Registers

ACRA Companies Register: www.bizfile.gov.sg

SLA Land Authority: www.sla.gov.sg

7.3. Arbitration institutions

Singapore International Arbitration Centre (SIAC): www.siac.org.sg

7.4. Specialists in the enforcement of arbitral awards in Singapore

A list of recommended experts is available on the official website of the Riga Arbitration Court:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] International Arbitration Act 1994 (IAA), Part III; Arbitration Act 2001 (AA); UNCITRAL Model Law (Article 3(1) of the IAA); Rules of Court 2021. sso.agc.gov.sg

[2] IAA, Article 27(1) (definition of ‘Convention award’), 29 (enforcement of a foreign award), 19; AA, Article 46(3) (non-contracting states).

[3] The 1958 New York Convention (Singapore is a party); presumption of enforceability (Articles 29 and 31 of the IAA).

[7] Limitation Act 1959, section 6(1)(c) — a six-year limitation period.

Case law

[9] CVG v CVH [2022] SGHC 249 — the enforceability of an emergency arbitrator’s award under Article 29 of the IAA.

Analytical and reference materials

[4] Jus Mundi — Singapore (no jurisdiction requirements, except for Convention awards; Article 27(1) of the IAA).

[5] Global Arbitration Review — Challenging and Enforcing Arbitration Awards: Singapore (High Court; ex parte; Order 48 RoC 2021); Global Legal Post — Singapore.

[6] Article IV of the New York Convention; Lexology — Issues With Enforcement of Arbitral Awards in Singapore (documents).

[8] CMS Expert Guides — Singapore; Lexology — Singapore (Article 31 of the IAA = Article V of the Convention; narrow interpretation).

1.1. Key legislation

Arbitration is governed by the Arbitration Act No. 244/2002 Coll. (in force since 1 July 2002; a major reform on 1 January 2015 brought it into line with the 2006 version of the UNCITRAL Model Law; minor amendments were made in 2017 and 2020). The Act applies to arbitration seated in Slovakia, as well as to the recognition and enforcement of domestic and foreign awards. Consumer arbitration is governed by a separate Act No. 335/2014 Coll.[1]

Enforcement proceedings themselves are governed by the Enforcement Code No. 233/1995 Coll. (Exekučný poriadok); procedural matters are governed by the Civil Procedure Code No. 160/2015 Coll.[2]

1.2. The New York Convention and the primacy of treaties

Slovakia is a party to the New York Convention by virtue of succession (since 1 January 1993; for Czechoslovakia, since 10 October 1959), subject to a reservation of reciprocity. In practice, a foreign award is recognised and enforced primarily under a bilateral treaty and, in the absence of such a treaty, under the Convention. According to Section 53 of the Arbitration Act, international treaties take precedence over its provisions, which are applied on a subsidiary basis.[3]

1.3. Other international treaties

The 1961 European Convention and the 1927 Geneva Convention;

The Washington Convention, the ICSID Convention and bilateral treaties. EU Regulation No 1215/2012 does not apply to arbitral awards.[4]

2.1. Recognition mechanism

A foreign judgment must be recognised prior to enforcement; however, Slovak courts do not, as a rule, issue a separate order of recognition (exequatur) — with the exception of declaratory judgments. Recognition is granted within the framework of enforcement proceedings: pursuant to Section 54 of the Enforcement Code, before issuing an authorisation for enforcement, the court serves the foreign judgment on the debtor and affords them the opportunity to demonstrate that there are grounds for refusal (under the Convention, a contract or the Arbitration Act).[5]

Under section 49(3) of the Arbitration Act, it is also possible to recognise an award without enforcing it (in the case of declaratory awards that do not require enforcement): a separate application is filed, and the court issues a ruling confirming the recognition.[6]

2.2. Scope of the review and appeals

If the debtor does not put forward any grounds, the court shall, on its own initiative, examine only whether the dispute is arbitrable and whether it is consistent with public policy. Any decision refusing recognition and enforcement must be reasoned and may be appealed against.[7]

3.1. Required documents

In accordance with Article IV of the New York Convention and the Arbitration Act, the following are attached:[8]

The original arbitration award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A certified translation into Slovak, if the documents are in another language.

3.2. Legal costs and time limits

Court fees in cases concerning annulment amount to €331.50 (the same amount applies to an ordinary appeal; for an extraordinary appeal, the fee is €663); lawyers’ fees are reimbursed in accordance with Decree No. 655/2004. According to statistics from the Ministry of Justice, district and regional courts take an average of 21 months to hear cases. As a general rule, the losing party bears the costs.[9]

The requirements for the recognition of a foreign award under the Arbitration Act are virtually identical to those set out in Article V of the New York Convention.[10]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or failure to state one’s position;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings (if this could have affected the outcome);

The decision has not become binding, or has been set aside or suspended by a court in the country where it was made.

4.2. Grounds subject to review by the court (Article V(2))

Non-arbitrability of the dispute under Slovak law;

Contrary to public policy in the Slovak Republic.

Where a decision is severable, the court may recognise and enforce only that part of the decision which relates to the dispute within the scope of the arbitration agreement.[10]

The filing of an application for annulment (in respect of awards where the place of arbitration is Slovakia; time limit: 60 days from the date of service) does not automatically suspend enforcement; the court may suspend enforcement upon application by a party. Once the application has been granted, enforcement is carried out in accordance with the Enforcement Code through a bailiff (súdny exekútor): seizure of property and bank accounts, and the realisation of the debtor’s assets.[11]

6.1. Tracing the debtor’s assets

Useful resources:

Commercial Register (Obchodný register): www.orsr.sk;

Land Registry (Kataster): www.katasterportal.sk;

Register of enforcement proceedings — via the Slovak Chamber of Bailiffs: www.ske.sk.

6.2. Practical advantages and obstacles

Recognition in the context of enforcement: a separate exequatur is not usually issued — this simplifies the process;[5]

Debtor’s action: the scope of the review of the grounds depends on whether the debtor raises them;

Translation into Slovak — allow for time and costs.

7.1. Legislation and official sources

→ Slov-Lex — Act No. 244/2002 Coll.: slov-lex.sk

→ The New York Convention (Slovakia): newyorkconvention.org

7.2. Registers

Commercial Register: www.orsr.sk

Cadastral register: www.katasterportal.sk

7.3. Arbitration institutions

Arbitration Court at the Slovak Chamber of Commerce and Industry: www.sopk.sk

7.4. Specialists in the enforcement of arbitral awards in Slovakia

A list of recommended experts is available on the official website of the Riga Arbitration Court:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Slovak Arbitration Act No. 244/2002 Coll. (in force since 1 July 2002; amended with effect from 1 January 2015 — the 2006 UNCITRAL Model Law); Act No. 335/2014 (consumer arbitration). slov-lex.sk

[2] Executive Code No. 233/1995 Coll. (Section 54); Civil Procedure Code No. 160/2015 Coll.

[3] The 1958 New York Convention (Slovakia — succession as of 1 January 1993; Czechoslovakia – from 10 October 1959; reservation on reciprocity); Section 53 of the Arbitration Act.

[4] The 1961 European Convention; the 1927 Geneva Convention; the ICSID Washington Convention; EU Regulation No 1215/2012 (which does not apply to arbitral awards).

Analytical and reference materials

[5] Arbitration-Slovakia.com — Enforcement of Arbitral Awards (Section 54 of the Enforcement Code; recognition in the context of enforcement).

[6] Arbitration-Slovakia.com — Section 49(3) of the Arbitration Act (recognition without enforcement).

[7] CMS Expert Guides — Slovakia (reasoned refusal; appeal; ex officio review).

[8] Lexology — First-step analysis: arbitration in Slovakia (documents; Article IV of the Convention).

[9] Lexology — Slovakia (court fees: 331.50/663 euros; average duration: 21 months; Decree No. 655/2004).

[10] CMS Expert Guides — Slovakia (grounds under Article V of the Convention; partial implementation).

[11] Global Arbitration Review — Commercial Arbitration: Slovakia (A&O Shearman); 60-day cancellation period; Code of Civil Procedure.

1.1. Key legislation

Arbitration in Slovenia is governed by the Arbitration Act (Zakon o arbitraži, ZArbit), which was adopted on 25 April 2008 and came into force on 10 August 2008. The Act incorporates the main provisions of the UNCITRAL Model Law (1985 version and certain aspects of the 2006 version). Procedural matters are governed by the Civil Procedure Act, whilst the recognition of awards is governed by the rules on non-contentious (non-litigious) proceedings.[1]

Under Article 42 of the ZArbit, the recognition and enforcement of foreign judgments are governed directly by the New York Convention. Foreign judgments become binding once they have been recognised by the Ljubljana District Court.[2]

1.2. The New York Convention

Slovenia became a party to the New York Convention by way of succession on 6 July 1992. The sole reservation is that the Convention shall not apply retroactively to judgments rendered prior to 6 July 1992; no reservation regarding reciprocity has been made. The application of the rule of the more favourable law (Article VII(1)) is excluded by an express reference in the ZArbit to the Convention.[3]

1.3. Other international treaties

The 1961 European Convention and the ICSID Washington Convention;

The 1960 Agreement between the former Yugoslavia and Austria on the Mutual Recognition and Enforcement of Arbitral Awards (by way of succession).[4]

2.1. The Court

The Ljubljana District Court (Okrožno sodišče v Ljubljani) has exclusive jurisdiction over the recognition of foreign arbitral awards. In order for an award to be enforced, the claimant must establish that the debtor has assets in the relevant district.[5]

2.2. Nature of the procedure

The recognition of a foreign judgment is carried out in accordance with the procedure for uncontested civil proceedings, which are adversarial in nature: before delivering its judgment, the court gives the opposing party the opportunity to present its case (inter partes).[6]

2.3. Appeals

There is a single level of appeal: appeals against decisions of the Ljubljana District Court are heard by the Supreme Court of the Republic of Slovenia. Extraordinary appeals are not permitted.[7]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are annexed:[8]

The original arbitration award or a copy thereof;

The original or a certified copy of the arbitration agreement — as required by the court;

A certified translation, if the decision or agreement is not drawn up in the court’s official language.

3.2. Legal costs

Court fees, translation costs and legal fees are taken into account; specific rates are subject to verification at the time of submission.[5]

For foreign judgments, the grounds set out in Article V of the New York Convention apply.[9]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to review by the court (Article V(2))

Non-arbitrability of a dispute under Slovenian law;

Contrary to public policy in the Republic of Slovenia.

In the case of domestic awards, the court may refuse to declare an award enforceable on only two grounds — that the subject-matter of the dispute is not arbitrable or that the award is contrary to public policy; no review on the merits is carried out.[10]

Enforcement against assets is possible: (i) once the decision on recognition has become final (res iudicata — no appeal has been lodged and the time limit for lodging an appeal has expired) or (ii) if the court has declared its decision immediately enforceable, notwithstanding any appeal. Only the decision on recognition and enforceability, together with the arbitral award, constitutes an enforceable title.[11]

Enforcement is carried out by the usual means of judicial enforcement under the Law on Enforcement and Security (Zakon o izvršbi in zavarovanju): seizure of property and bank accounts, and the realisation of assets.[12]

6.1. Tracing the debtor’s assets

Useful resources:

Slovenian Business Register (AJPES): www.ajpes.si;

Land Register (Zemljiška knjiga): evlozisce.sodisce.si;

Court register (sodni register) — via AJPES.

6.2. Practical advantages and obstacles

Single court: all cases concerning the recognition of foreign judgments — Ljubljana District Court;

Adversarial nature: the debtor takes part in the recognition proceedings;

Assets in the district: in order to proceed with enforcement, it is necessary to confirm that the debtor has assets in the relevant district.

7.1. Legislation and official sources

→ PIS — Arbitration Act (ZArbit): pisrs.si

→ The New York Convention (Slovenia): newyorkconvention.org

7.2. Registers

AJPES Business Register: www.ajpes.si

Land Register: evlozisce.sodisce.si

7.3. Arbitration institutions

The Ljubljana Arbitration Centre (LAC) at the Slovenian Chamber of Commerce and Industry: www.sloarbitration.eu

7.4. Specialists in the enforcement of arbitral awards in Slovenia

A list of recommended experts is available on the official website of the Riga Arbitration Court:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] The Slovenian Arbitration Act (Zakon o arbitraži, ZArbit; adopted on 25 April 2008, in force since 10 August 2008; based on the UNCITRAL Model Law). pisrs.si

[2] ZArbit, Article 42 — recognition of foreign judgments directly under the New York Convention; Ljubljana District Court.

[3] The 1958 New York Convention (Slovenia — successor state since 6 July 1992; reservation regarding non-retroactivity; no reservation regarding reciprocity; exclusion of Article VII(1)).

[4] The 1961 European Convention; the ICSID Washington Convention; the 1960 Agreement (former Yugoslavia–Austria).

Analytical and reference materials

[5] Jus Mundi — Slovenia country publication (Ljubljana District Court; presence of assets in the district); CMS Expert Guides — Slovenia.

[6] Jus Mundi — Slovenia (inter partes; non-contentious proceedings).

[7] Jus Mundi — Slovenia (appeal to the Supreme Court; single instance).

[8] Global Arbitration Review — Slovenia; Article IV of the Convention (documents; translation).

[9] Lexology — In brief: arbitration formalities in Slovenia (Jadek & Pensa); grounds under Article V of the Convention.

[10] Global Legal Insights — International Arbitration 2024, Slovenia (grounds for setting aside domestic awards).

[11] Jus Mundi — Slovenia (enforcement against assets; res judicata; immediate enforceability).

[12] Global Legal Insights — Slovenia (Enforcement and Security Act).

1.1. Key legislation

Arbitration in the Republic of Korea is governed by the Korean Arbitration Act (KAA), which adopted the UNCITRAL Model Law in 1999 and was amended in 2016 and 2020 (taking into account the 2006 amendments to the Model Law). The procedure for recognition and enforcement is set out in Article 37 of the KAA; Articles 38–39 are key for foreign awards.[1]

South Korea adopts a bifurcated (dual) approach: domestic awards (made in South Korea) and foreign awards (made abroad) are governed by different rules. This is complemented by the 2016 Act on the Development of the Arbitration Industry, which supports the arbitration infrastructure.[2]

1.2. The New York Convention

South Korea acceded to the 1958 New York Convention in 1973, entering reservations regarding reciprocity and the commercial nature of the judgments. Under Article 39(1) of the KAA, the recognition and enforcement of foreign judgments falling within the scope of the Convention are carried out in accordance with the Convention.[3]

1.3. Decisions outside the scope of the Convention

The recognition and enforcement of foreign judgments handed down in states that are not parties to the Convention are governed by Article 39(2) of the KAA, which refers to Article 217 of the Civil Procedure Act and Articles 26(1), 27 of the Civil Enforcement Act (general requirements for the recognition of foreign judgments, including international jurisdiction and reciprocity).[4]

2.1. The court and the form of the judgment

The application is lodged with the district court. Since the 2016 reform, the court’s decision on enforcement has been issued in the form of a court order rather than a formal judgment — this speeds up the procedure. There is no specialised court for arbitration cases in Korea.[5]

2.2. Appeals

Either party is entitled to appeal against an enforcement order to the High Court and subsequently to the Supreme Court. However, an appeal does not suspend enforcement: a district court order is, as a rule, subject to provisional enforcement whilst the appeal is being considered.[6]

3.1. Required documents

Pursuant to Article 37 of the KAA (and Article IV of the New York Convention), the following are annexed:[7]

A certified or uncertified copy of the arbitration award;

Arbitration agreement (for decisions under the Convention — pursuant to Article IV);

A translation into Korean, if the decision is drafted in a foreign language.

3.2. Limitation period

The KAA does not specify a specific time limit for the enforcement of an arbitral award; pursuant to Article 35 of the KAA, an award (provided that recognition or enforcement has not been refused) has the same force as a final court judgement.[8]

3.3. Legal costs

Court fees, translation costs and legal fees are taken into account; specific rates are subject to verification at the time of submission.[5]

For foreign judgments under the Convention, the grounds set out in Article V of the New York Convention apply (for domestic judgments, the almost identical grounds set out in Article 38 of the KAA apply). Korean courts very rarely refuse to enforce such judgments.[9]

4.1. Grounds based on the debtor’s application (Article V(1))

Legal incapacity of the parties / invalidity of the arbitration agreement;

Failure to give proper notice or the inability to present a case;

The decision going beyond the scope of the arbitration agreement;

A breach of the rules governing the composition of the tribunal or of the proceedings;

The decision is no longer binding, or has been set aside or suspended in the country where it was made.

4.2. Grounds subject to review by the court (Article V(2))

Non-arbitrability of a dispute under Korean law;

Contrary to public order in Korea.

The Supreme Court stated that, when assessing public policy under the Convention, account must be taken not only of the domestic situation in Korea but also of the need for predictability and stability in international trade; this standard is interpreted narrowly. In its judgment of 11 March 2022, the Supreme Court recognised the possibility of enforcing judgments awarding punitive damages under certain conditions, provided that such damages are permitted under Korean law.[10]

Article 18-7 of the KAA permits the judicial enforcement of interim measures ordered by an arbitral tribunal, but only if the seat of such arbitration is in Korea; interim measures ordered by a foreign tribunal are not enforced by Korean courts (Cheongju District Court, judgment 2022KaHap50245 of 8 June 2023). Once an enforcement order has been issued, recovery is carried out in accordance with the Civil Enforcement Act: seizure and realisation of property, and attachment of the debtor’s accounts and assets.[11]

6.1. Tracing the debtor’s assets

Useful resources:

Commercial Register (Supreme Court Internet Registry): www.iros.go.kr;

The Land Registry — via the same court portal;

Korean Commercial Arbitration Board (KCAB): www.kcab.or.kr.

6.2. Practical advantages and obstacles

Low rate of set-asides: consistent pro-arbitration practice — high predictability;[9]

An order instead of a decision: an expedited enforcement procedure since 2016;[5]

Interim measures: only measures ordered by a tribunal with the seat of arbitration in Korea are enforceable.

7.1. Legislation and official sources

→ Korea Law Translation Centre — Arbitration Act: www.law.go.kr

→ New York Convention (Korea): newyorkconvention.org

7.2. Registers

Supreme Court Online Register: www.iros.go.kr

KCAB: www.kcab.or.kr

7.3. Arbitration institutions

Korean Commercial Arbitration Board (KCAB / KCAB International): www.kcab.or.kr

7.4. Specialists in the enforcement of arbitral awards in Korea

A list of recommended experts is available on the official website of the Riga Arbitration Court:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as at mid-2026. A list of the sources on which these guidelines are based is provided below.

Legislation and international treaties

[1] Arbitration Act of the Republic of Korea (KAA; UNCITRAL Model Law – 1999, as amended in 2016 and 2020), Articles 35, 37, 38 and 39. law.go.kr

[2] The KAA bifurcation approach (domestic/foreign awards); the Arbitration Industry Development Act 2016.

[3] The 1958 New York Convention (Korea — accession in 1973; reservations regarding reciprocity and commercial matters); KAA, Article 39(1).

[4] KAA, Article 39(2) → Civil Procedure Act, Article 217; Civil Enforcement Act, Articles 26(1) and 27.

[7] KAA, Article 37; Article IV of the New York Convention (documents; Korean translation).

[8] KAA, Article 35 (binding effect of a final court decision; no specific time limit).

Case law

[10] Supreme Court of Korea, judgment of 11 March 2022 (punitive damages); Global Arbitration Review — Rejecting public policy defences: South Korean courts (narrow public policy test).

[11] Cheongju District Court, judgment 2022KaHap50245 of 8 June 2023 (interim measures — only where the place of arbitration is in Korea; Article 18-7 of the KAA).

Analytical and reference materials

[5] CMS Expert Guides — South Korea; Global Legal Post — South Korea (district court; orders have been used in place of judgements since 2016).

[6] Lexology — Arbitration formalities in South Korea (appeals: High Court → Supreme Court; provisional enforcement).

[9] Global Arbitration Review — Challenging and Enforcing Arbitration Awards: South Korea (Baker McKenzie & KL Partners) — rare instances of refusal; Article 38 of the KAA / Article V of the Convention.

1.1. Primary legislation

The recognition and enforcement of foreign arbitral awards in Spain is governed by a body of rules:[1]

Arbitration Act No. 60/2003 of 23 December 2003 (Ley de Arbitraje, SAA) — Article 46 refers directly to the New York Convention for the exequatur of foreign awards;[2]

Act No. 29/2015 of 30 July 2015 on international legal cooperation in civil matters (LCJI), Title V — the exequatur procedure (applicable from 20 August 2015);[3]

Code of Civil Procedure No. 1/2000 (Ley de Enjuiciamiento Civil, LEC) — on a subsidiary basis.

Act 60/2003 is based on the 1985 UNCITRAL Model Law and applies both to domestic and international arbitration.[2]

1.2. The New York Convention

Spain signed the 1958 New York Convention on 29 April 1977, without any reservations.[4] Under Article 46.2 of the SAA, the exequatur of foreign awards is governed directly by the Convention (without prejudice to more favourable international treaties). In essence, the Convention is incorporated into Spanish law and renders a separate domestic exequatur regime unnecessary.[5]

1.3. Other international treaties

The 1961 European Convention on International Commercial Arbitration (signed 05.03.1975);

The 1961 Geneva Convention on International Commercial Arbitration;

Bilateral treaties with a number of countries (Switzerland, France, Italy, China, Bulgaria, Morocco, Mexico, Brazil, Uruguay, etc.) containing provisions on recognition.[6]

2.1. Two separate procedures

Spanish law clearly distinguishes between two procedures: (1) recognition (exequatur) of a foreign arbitral award and (2) the subsequent enforcement of the recognised award.[7]

2.2. The court for recognition (exequatur)

Since 2011 (as amended by Act 11/2011), jurisdiction over the exequatur of foreign awards lies with the Civil and Criminal Chamber of the High Court of Justice (Tribunal Superior de Justicia, TSJ) of the autonomous community where the debtor party is located — Article 8.6 of the SAA.[8] There are 17 such courts in Spain (corresponding to the number of autonomous communities). Jurisdiction is determined: first, by the respondent's domicile; second, by the place of enforcement of the award; third, by the place where the award is to produce legal effects.[9]

2.3. The court for enforcement

Once exequatur has been obtained, enforcement is carried out by the Court of First Instance (Juzgado de Primera Instancia) at the place where the award is to produce its effects, in accordance with the rules of the Code of Civil Procedure (LEC).[1]

2.4. The position of the Spanish courts

The Spanish courts demonstrate a consistently pro-arbitration approach. Applications for annulment are rarely granted, and foreign awards are, as a rule, recognised and enforced. Courts rarely refuse exequatur on the grounds of Article V of the Convention.[10]

2.5. Appeal

The TSJ decision on the question of exequatur is final and not subject to further appeal.[7]

3.1. Procedure

The procedure may be initiated by any person having a legitimate interest (Art. 54 LCJI). The application must meet the requirements of Article 399 LEC (identification of the parties, statement of facts and legal grounds, formulation of the claims). Representation by a procedural attorney (procurador) and a lawyer (abogado) is mandatory.[11]

The court examines the application and documents; if they are accepted, they are served on the respondent for the submission of objections within 30 days. Once objections have been formalised or the deadline has expired, the court issues its decision.[12]

3.2. Required documents

In accordance with Article IV of the New York Convention, the following are attached:[13]

the original of the arbitral award, duly authenticated, or a certified copy thereof;

the original of the arbitration agreement or a certified copy thereof;

a translation into Spanish (or the official language of the relevant autonomous community) if the documents are drawn up in another language; the translation is certified by an official or sworn translator or by a diplomatic/consular institution.[13]

3.3. Court costs

The applicant's main costs: the mandatory fees of the procedural attorney (procurador) and the lawyer (abogado), as well as the costs of a sworn translation. A court fee (tasa judicial) is levied on legal entities under Act 10/2012; natural persons are exempt from the fee.[11]

Note: the specific amounts depend on the circumstances of the case and are subject to verification at the time of submission.

3.4. Timeframes

The average duration of the exequatur procedure is between 6 months and 1 year (according to some estimates — 6–9 months). Subsequent enforcement is, as a rule, carried out more quickly.[1]

3.5. Limitation period

An application for exequatur must be submitted within five years from the moment the arbitral award became final.[14]

Since exequatur is governed directly by the New York Convention, only the grounds of Article V of the Convention apply. The TSJ limits its review to the presence or absence of these grounds.[7]

4.1. Grounds invoked by the debtor (Art. V(1))

Incapacity of the parties or invalidity of the arbitration agreement;

Improper notice of the appointment of an arbitrator / the proceedings, or the inability to present one's case;

The award going beyond the scope of the arbitration agreement;

A breach of the procedure for constituting the tribunal or of the procedure itself;

The award has not yet become binding or has been set aside / suspended in the country where it was made.

4.2. Grounds examined by the court (Art. V(2))

Non-arbitrability of the subject matter of the dispute under Spanish law;

Conflict with the public policy of Spain.

4.3. A special case: an award set aside abroad

The question of enforcing awards set aside in the country where they were made has not been definitively settled in Spain. No Spanish court has yet enforced an award set aside abroad. At the same time, courts have recognised awards where there was merely an unfinished set-aside procedure at the seat of arbitration.[15] The High Court of Murcia (12 April 2019) indicated that a court has the right, but not the obligation, to refuse exequatur on the ground of Art. V(1)(e) of the Convention. Thus, the enforcement of a set-aside award is theoretically possible but, in practice, difficult.[15]

Under Article 54(2) of Act 29/2015 (LCJI), interim measures may be requested during the exequatur procedure for a foreign award.[16] Once recognised, the award is enforced as a final judicial decision (Art. 43 SAA). The available measures (by analogy with Art. 727 LEC) include:

Preventive attachment (embargo preventivo) of property and funds;

Judicial administration of productive property;

Attachment of bank accounts and accounts receivable.

6.1. Mandatory representation

Both a procedural attorney (procurador) and a lawyer (abogado) are required. For a foreign creditor, engaging Spanish specialists is mandatory.

6.2. Tracing the debtor's assets

Useful resources for establishing the property and status of the debtor:

The Commercial Register (Registro Mercantil): www.registradores.org;

The Land Register (Registro de la Propiedad) — via the same portal;

The official bulletin BORME (Boletín Oficial del Registro Mercantil): www.boe.es/diario_borme.

6.3. Practical obstacles

The five-year limitation period: the application should be submitted in good time;[14]

The separation of procedures: recognition and enforcement are two distinct proceedings, which increases the overall time;

Translation: a sworn translation of the award and the arbitration agreement is required.

7.1. Legislation and official sources

→ BOE — Arbitration Act 60/2003: boe.es

→ BOE — Act 29/2015 (LCJI)

→ The New York Convention (Spain): newyorkconvention.org

7.2. Registers

The Commercial Register and the Land Register: www.registradores.org

BORME: www.boe.es/diario_borme

7.3. Arbitration institutions

The Madrid Court of Arbitration (Corte de Arbitraje de Madrid): www.arbitramadrid.com

The Spanish Court of Arbitration (CEA): www.cienternacional.com

7.4. Specialists in the enforcement of arbitral awards in Spain

A list of recommended specialists is available on the official website of the Riga Court of Arbitration:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from open sources as of mid-2026. Below is a list of the materials on which this guide relies.

Legislation and international treaties

[2] Arbitration Act No. 60/2003 of 23 December 2003 (Ley de Arbitraje), Arts. 8.6, 43, 46 (as amended by Act 11/2011). BOE: boe.es

[3] Act No. 29/2015 of 30 July 2015 on international legal cooperation in civil matters (LCJI), Title V, Art. 54.

[1] Code of Civil Procedure No. 1/2000 (Ley de Enjuiciamiento Civil), Arts. 399, 727; Act 10/2012 (court fees).

[4] The 1958 New York Convention (signed by Spain on 29.04.1977, without reservations), Arts. IV, V, VII.

[6] Spain's bilateral treaties on recognition (Switzerland, France, Italy, China, etc.); the 1961 European Convention.

Case law

[15] Tribunal Superior de Justicia de Murcia, 12 April 2019 (the right, but not the obligation, to refuse under Art. V(1)(e)); Tribunal Supremo, No. 9443/2004.

Analytical and reference materials

[5] Global Arbitration Review — Commercial Arbitration, Spain (Cuatrecasas) — Art. 46.2 SAA, preamble.

[7] Lawants — Enforcement of Arbitral Awards in Spain (separation of procedures, TSJ jurisdiction, finality).

[8] Global Legal Insights — International Arbitration Laws and Regulations, Spain (Art. 8.6 SAA).

[10] Vilá Abogados — The New Exequatur of Foreign Arbitral Awards in Spain (procedure under LCJI).

[11] Gamero & Bravo Abogados — How to Enforce an Arbitral Award or a Foreign Judgment in Spain (2025).

[13] Mariscal & Abogados — Implementation of foreign commercial arbitral awards in Spain (Art. IV of the Convention).

[14] Vilá Abogados / LCJI — the five-year period for submitting an application for exequatur.

[16] Clyde & Co — Can you still enforce awards in Spain that have been set aside? (2022).

1.1. Principal legislation

The recognition and enforcement of arbitral awards in Sweden are governed by the Arbitration Act (lagen om skiljeförfarande, SFS 1999:116, in English — Swedish Arbitration Act, SAA). The Act was substantially updated by the 2019 reform (in force since 1 March 2019).[1] The provisions on foreign awards are contained in §§ 52–60 of the SAA. The Act applies to both domestic and international arbitration and, although formally not based on the UNCITRAL Model Law, it has minimal divergences from it.[2]

1.2. The New York Convention

Sweden ratified the 1958 New York Convention on 28 January 1972, without any reservations.[3] The grounds for refusal under Article V(1) of the Convention are incorporated in § 54 of the SAA, and those under Article V(2) in § 55 of the SAA. Foreign awards based on an arbitration agreement are recognised and enforced in Sweden (§ 53 of the SAA).

1.3. Other international treaties

The 1965 ICSID Washington Convention;

The Energy Charter Treaty (ECT);

Bilateral investment treaties with a number of states.[4]

1.4. Pro-arbitration approach

The Swedish courts are independent and have traditionally adhered to an arbitration-friendly approach; the setting aside of awards in practice is extremely rare.[5] A particular nuance concerns intra-EU investment disputes: following the preliminary rulings of the Court of Justice of the EU (Achmea, Komstroy, PL Holdings), the Svea Court of Appeal and the Supreme Court of Sweden declared invalid a number of investment arbitral awards (Novenergia v Spain — non-arbitrability; PL Holdings v Poland — public policy).[6]

2.1. The court

An application for the recognition and enforcement of a foreign arbitral award is filed exclusively with the Svea Court of Appeal (Svea hovrätt) in Stockholm — § 56 of the SAA.[7] The court operates a specialised bench of judges for arbitration matters.

2.2. Nature of the procedure

An application is filed for a declaration of enforceability of the award (declaration of enforceability), which is then served on the opposing party. The court verifies only compliance with the formal requirements (essentially corresponding to the New York Convention) and does not review the case on the merits.[8]

2.3. Appeal

A decision of the Svea Court of Appeal may be appealed to the Supreme Court of Sweden only upon a double leave: if the Court of Appeal itself grants leave to appeal (owing to the case's precedential significance) and if the Supreme Court grants leave for review.[9]

3.1. Required documents

In accordance with §§ 56–57 of the SAA and Article IV of the New York Convention, the following are attached:[10]

The original of the arbitral award or a certified copy thereof;

A certified translation into Swedish: as a rule, a full translation of the entire award is required, although the court may at its discretion assess whether the content of an award drawn up in a foreign language is sufficiently clear to it;[11]

The application is subject to service on the opposing party.

Note: at the enforcement stage of an arbitral award, the existence of a written arbitration agreement, in Swedish practice, does not always have to be attached as strictly as in a number of other jurisdictions; the grounds relating to the agreement pertain to the debtor's burden of proof (§ 54 of the SAA).[2]

3.2. Court costs

The filing of an application for the recognition and enforcement of a foreign award is not subject to a state fee. The principal costs are translation and attorney's fees. Once the court has issued a decision permitting enforcement, the enforcement officer charges a fee of 600 Swedish kronor for enforcement actions (for example, the imposition of an attachment); where property is sold at a public auction, a percentage is charged depending on the type of property.[12]

3.3. Timeframes

Proceedings before the Svea Court of Appeal are, as a rule, not lengthy, provided that no difficulties arise with serving the application on the other party.[13]

3.4. Limitation period

No special time limit for filing an application for the recognition and enforcement of an arbitral award is established under Swedish law.[14]

The grounds correspond to Article V of the New York Convention and are incorporated in §§ 54–55 of the SAA.[15]

4.1. Grounds upon the debtor's application (§ 54 of the SAA / Art. V(1))

Incapacity of the parties / invalidity of the arbitration agreement;

Improper notification or the inability to present one's case;

The award going beyond the scope of the arbitration agreement;

A breach of the procedure for constituting the tribunal or of the procedure;

The award has not become binding or has been set aside / suspended in the country of origin.

4.2. Grounds examined by the court ex officio (§ 55 of the SAA / Art. V(2))

The non-arbitrability of the dispute under Swedish law;

Manifest incompatibility with the fundamental principles of Swedish legal order (public policy).

4.3. Special case: an award set aside abroad

Unlike in France or the Netherlands, a foreign arbitral award set aside by a court of the country in which it was rendered cannot be enforced in Sweden.[16] According to the doctrinal position, the Swedish enforcement rule is non-discretionary in nature and does not permit the enforcement of a set-aside award. There are known decisions of lower instances refusing on this ground; no instances of permitting the enforcement of a set-aside award have been recorded.

If the Svea Court of Appeal grants the application, the award becomes immediately enforceable on a par with a final Swedish court judgment (unless, on appeal, the Supreme Court orders a stay). Enforcement is carried out through the Enforcement Authority (Kronofogdemyndigheten) where the debtor has property in Sweden — § 59 of the SAA.[17]

A stay of enforcement while the award is being challenged in parallel at the seat of arbitration is, as a rule, not granted automatically: the court may require the debtor to provide security and defers enforcement only where there is clear evidence of a probable success of the challenge.[18]

Since interim measures of the arbitrators in Sweden are, as a rule, not considered to be enforceable, one may apply to a state court to obtain them, notwithstanding the existence of an arbitration agreement.[19]

6.1. Tracing the debtor's assets

Useful resources for ascertaining property and the debtor's status:

The Companies Register (Bolagsverket): www.bolagsverket.se;

The Tax Agency (Skatteverket) — registration information;

The Enforcement Authority (Kronofogden): www.kronofogden.se.

6.2. Language of the proceedings

In challenge proceedings, the Swedish appellate courts permit the hearing of witnesses in English without translation into Swedish — a convenience for international parties. At the same time, the application for enforcement itself, as a rule, requires a certified translation of the award.[11]

6.3. Practical obstacles

Service of documents abroad: the principal cause of delays is difficulties with serving the application on the debtor;[13]

Set-aside awards: where an award has been set aside in the country of origin, enforcement in Sweden is not possible;

Intra-EU investment disputes: in the light of the Achmea/Komstroy case-law — an elevated risk of a declaration of invalidity.

7.1. Legislation and official sources

→ Riksdagen — Arbitration Act (SFS 1999:116): riksdagen.se

→ The New York Convention (Sweden): newyorkconvention.org

→ Svea Court of Appeal: domstol.se/svea-hovratt

7.2. Registers

The Companies Register Bolagsverket: www.bolagsverket.se

The Enforcement Authority Kronofogden: www.kronofogden.se

7.3. Arbitration institutions

The Arbitration Institute of the Stockholm Chamber of Commerce (SCC): www.sccarbitrationinstitute.se

7.4. Specialists in the enforcement of arbitral awards in Sweden

A list of recommended specialists is published on the official website of the Riga Court of Arbitration:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from open sources as at mid-2026. Below is a list of the materials on which this guide is based.

Legislation and international treaties

[1] The Swedish Arbitration Act (lagen om skiljeförfarande, SFS 1999:116), the 2019 reform (in force since 01.03.2019), §§ 52–60. riksdagen.se

[2] SAA, § 53 (recognition of foreign awards), § 54 (Art. V(1)), § 55 (Art. V(2)), §§ 56–60 (exequatur procedure).

[3] The 1958 New York Convention (Sweden — ratification on 28.01.1972, without reservations), Arts. IV, V.

[4] The 1965 ICSID Washington Convention; the Energy Charter Treaty; Sweden's bilateral investment treaties.

[17] SAA, § 59; the Enforcement Code (Enforcement Code, SFS 1981:774), Chapter 3 § 3.

Case-law

[6] Svea hovrätt (December 2022) — Novenergia v Spain (non-arbitrability); Högsta domstolen — PL Holdings v Poland (public policy); CJEU Achmea (C-284/16), Komstroy (C-741/19), PL Holdings (C-109/20).

[16] ICC Digital Library, Country Answers: Sweden; IBA Arbitration Guide: Sweden — the non-enforceability of set-aside awards.

Analytical and reference materials

[5] Global Arbitration Review — Commercial Arbitration: Sweden (Norburg & Scherp); Global Legal Insights — Sweden 2024.

[7] ICC Digital Library — Country Answers: Sweden (Svea Court of Appeal, Stockholm); CMS Expert Guides — Sweden (2025).

[8] Lexology — In brief: enforcing and challenging arbitral awards in Sweden (2023); declaration of enforceability, verification of formal requirements.

[9] Legal500 — Sweden: International Arbitration (§ 43 of the SAA; double leave to appeal to the Supreme Court).

[10] Aceris Law — International Arbitration in Sweden (§§ 56–60 of the SAA, exequatur procedure).

[11] Aceris Law / Global Legal Insights — translation requirements; the hearing of witnesses in English in challenge proceedings.

[12] Lexology — the cost of enforcement (the absence of a fee; the enforcement officer's fee of 600 kronor).

[13] Legal500 — the timeframes of proceedings before Svea; service of the application.

[14] Lexology / ICC Country Answers — the absence of a limitation period for filing an application.

[15] Global Arbitration Review — Challenging and Enforcing Arbitration Awards: Sweden.

[18] IBA Arbitration Guide: Sweden — a stay of enforcement and security.

[19] Lexology — the non-enforceability of arbitrators' interim measures; recourse to a state court.

1.1. Principal legislation

International arbitration in Switzerland is governed by Chapter 12 of the Federal Act on Private International Law of 18 December 1987 (PILA, Articles 176–194). The recognition and enforcement of foreign awards is governed by Article 194 PILA, which refers directly to the 1958 New York Convention.[1]

Switzerland applies a monist system: international treaties have direct effect, without implementing legislation. Foreign awards are therefore recognised and enforced on the basis of the Convention itself as an international obligation of Switzerland (the reference in Article 194 PILA being declaratory in nature).[2]

1.2. The New York Convention and its broad scope

The Convention was ratified by Switzerland on 1 June 1965 (in force since 30 August 1965). The reciprocity reservation (Article I(3)) was withdrawn in 1993. A significant feature: owing to the direct reference in Article 194 PILA, all foreign awards are recognised and enforced under the Convention irrespective of reciprocity — including those rendered in States that are not parties to it.[3]

1.3. Domestic and foreign awards

An award of a tribunal seated in Switzerland has the same force as a judgment of a Swiss court (Article 190(1) PILA, Article 387 CPC) and is enforceable from the moment of notification, without a separate recognition procedure. An award is foreign where the tribunal is seated outside Switzerland — it is subject to recognition prior to enforcement.[4]

2.1. Absence of a separate exequatur

Swiss law generally provides no self-standing exequatur procedure for foreign awards: the question of recognition is decided incidentally (incidenter) by the competent cantonal court within the enforcement proceedings at the place of enforcement. A separate declaration of enforceability is possible but is usually not required.[5]

2.2. The court

The recognition and enforcement of foreign awards falls within the competence of the cantonal courts at the place of enforcement — as a rule, at the debtor's place of residence (domicile) or the location of the debtor's assets. There is no single centralised court; procedural rules may vary slightly between cantons, but the substantive standard of recognition is uniform and is determined by federal law.[6]

For monetary claims, enforcement is carried out under the Debt Collection and Bankruptcy Act (DCBA, Articles 46–55) through the debt collection office (Betreibungsamt); for non-monetary claims — under Articles 353–399 CPC through the civil courts.[7]

3.1. Required documents

In accordance with Article IV of the New York Convention (by reference in Article 194 PILA), the following are enclosed:[8]

the authenticated original of the arbitral award or a certified copy thereof;

the original of the arbitration agreement or a certified copy thereof;

a certified translation, where the documents are not drawn up in the official language of the canton (translation requirements vary between cantons; Switzerland is a party to the Apostille Convention).

The Swiss courts do not take a formalistic approach to the form of the award: certification (authentication) is not required if the debtor does not challenge the authenticity of the award.[9]

3.2. Certificate of enforceability (for Swiss awards)

To confirm the enforceability of an award seated in Switzerland, a party may apply to the higher civil court of the canton where the seat of arbitration was located (Article 356(1)(b) CPC, Article 193(2) PILA).[10]

3.3. Language of the proceedings

The revised Article 251a CPC (in force since 1 January 2025) allows cantons to provide for the use of English as the language of the proceedings in certain proceedings, where it was used in the arbitration agreement or in the arbitration.[11]

Under Article 194 PILA, the grounds of Article V of the New York Convention are the exclusive grounds for refusal; the Swiss courts interpret them restrictively. Moreover, even where one of the grounds is established, the courts retain discretion to allow recognition and enforcement (SFSC 5A_1046/2019 of 27 May 2020).[12]

4.1. Grounds raised on the debtor's application (Article V(1))

incapacity of the parties / invalidity of the arbitration agreement;

improper notification or inability to present one's case;

the award going beyond the scope of the arbitration agreement;

breach of the rules on the composition of the tribunal or of the procedure;

the award has not become binding or has been set aside / suspended in the country where it was rendered.

4.2. Grounds examined by the court (Article V(2))

non-arbitrability of the dispute;

conflict with Swiss public policy (ordre public).

4.3. Conflict of conventions

Where recognition and enforcement may be governed by two international treaties (for example, the New York Convention and a bilateral treaty), priority is given to the one that facilitates recognition or enforcement (SFSC 4A_95/2021 of 17 June 2021).[13]

The preclusive effect (res judicata) of an award is limited to the operative part; the reasons do not create res judicata but are taken into account to clarify the meaning of the operative part (SFSC 128 III 191). Following recognition, monetary claims are recovered through the Betreibungsamt (attachment, realisation of assets), and non-monetary claims through the civil courts.[14]

Parties without a domicile, habitual residence or place of business in Switzerland may waive the setting-aside procedure (Article 192 PILA); this affects the objections available.[15]

6.1. Tracing the debtor's assets

Useful resources:

The Commercial Register (Zefix): www.zefix.ch;

the debt collection offices (Betreibungsamt) — extracts at the debtor's location;

the Land Register (Grundbuch) — via the cantonal authorities.

6.2. Practical advantages and obstacles

Broad scope and the absence of a separate exequatur: fast and predictable enforcement;[5]

Cantonal differences: verify the procedural rules and translation requirements in the specific canton;

A non-formalistic approach: where there is no dispute as to authenticity, certification of the award is not required.

7.1. Legislation and official sources

→ Fedlex — Private International Law Act (PILA), Chapter 12: fedlex.admin.ch

→ New York Convention (Switzerland): newyorkconvention.org

7.2. Registers

Commercial Register Zefix: www.zefix.ch

Debt collection (Betreibung): www.betreibungsschalter.ch

7.3. Arbitration institutions

Swiss Arbitration Centre: www.swissarbitration.org

7.4. Specialists in the enforcement of arbitral awards in Switzerland

A list of recommended specialists is available on the official website of the Riga Court of Arbitration:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from open sources as of mid-2026. Below is a list of the materials on which this guide relies.

Legislation and international treaties

[1] Federal Act on Private International Law (PILA) of 18.12.1987, Chapter 12, Articles 176–194 (in particular Articles 192, 193(2), 194). fedlex.admin.ch

[2] Switzerland's monist system; direct effect of the New York Convention (Article 194 PILA — a declaratory reference).

[3] The 1958 New York Convention (Switzerland — ratification 01.06.1965, in force since 30.08.1965; reciprocity reservation withdrawn in 1993), Articles IV, V.

[4] PILA, Article 190(1); CPC, Article 387 (domestic awards — force of a court judgment).

[7] Debt Collection and Bankruptcy Act (DCBA), Articles 46–55; CPC, Articles 353–399.

[11] CPC, Article 251a (in force since 01.01.2025) — English as the language of the proceedings by decision of the canton.

Case law

[12] SFSC 5A_1046/2019 of 27 May 2020 (the court's discretion where a ground for refusal exists).

[13] SFSC 4A_95/2021 of 17 June 2021 (priority of the treaty that facilitates enforcement).

[14] SFSC 128 III 191 of 3 April 2002 (res judicata limited to the operative part).

Analytical and reference materials

[5] Loyens & Loeff — Recognition and Enforcement of Arbitral Awards in Switzerland (absence of a self-standing exequatur).

[6] Global Law Experts — Enforcement of Arbitral Awards in Switzerland (cantonal courts at the debtor's/assets' location).

[8] Legal500 — Switzerland: International Arbitration; WAGNER Arbitration — Switzerland (Article IV of the Convention; documents).

[9] WAGNER Arbitration — Switzerland (non-formalistic approach; certification not required absent a dispute as to authenticity).

[10] Global Arbitration Review — Switzerland (Article 356(1)(b) CPC, Article 193(2) PILA — certificate of enforceability).

[15] Jus Mundi — Switzerland (Article 192 PILA — waiver of the setting-aside procedure).

1.1. Principal legislation

The recognition (tanıma) and enforcement (tenfiz) of foreign arbitral awards in Turkey are governed by the Law on Private International Law and Procedure No. 5718 (IPPL / MÖHUK; in force since 2007), Articles 60–63, as well as by the New York Convention. Procedural support is provided by the Code of Civil Procedure (HMK) and the Code of Enforcement and Bankruptcy (İİK). Foreign court judgments are regulated separately — by Articles 50–59 of the IPPL.[1]

1.2. The New York Convention and the priority of treaties

Turkey acceded to the New York Convention on 1 October 1992 (and to the European Convention on International Commercial Arbitration — on 23 September 1991), declaring reservations as to reciprocity and commercial character. Under Article 90 of the Turkish Constitution, duly ratified international treaties have the force of law and, in the event of conflict with domestic law, take priority; the Turkish courts are therefore obliged to apply the New York Convention.[2]

1.3. Delineation of regimes

The New York Convention applies to awards rendered in another contracting state and considered commercial under Turkish law. Awards falling outside this scope (from a non-contracting state or non-commercial) are recognised and enforced under Articles 60–63 of the IPPL.[3]

2.1. The court

The application is filed with the Civil Court of First Instance (Asliye Hukuk Mahkemesi) at the place of the debtor’s domicile in Turkey; in its absence — at the place of habitual residence, and if that too is absent — with a court in Istanbul, Ankara or Izmir.[4]

2.2. Recognition and enforcement

‘Recognition’ (tanıma) confers on the award res judicata effect and evidentiary force; ‘enforcement’ (tenfiz) endows it with enforceability in the same way as a Turkish court judgment. Only final and effective (kesinleşmiş) foreign awards are enforceable. First-instance decisions on enforcement are subject to appeal (istinaf / court of appeal).[5]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are attached:[6]

A certified original of the arbitral award or a certified copy thereof;

The original of the arbitration agreement or a certified copy thereof;

A certified translation into Turkish (as a rule, with an apostille/legalisation).

3.2. Time limits and costs

Uncontested enforcement proceedings are usually completed within 6–12 months; contested proceedings may last 18–24 months at first instance. Court fees and the costs of translation and legal support are to be taken into account.[7]

The grounds correspond to Article V of the New York Convention (and are parallel to the provisions of the IPPL).[8]

4.1. Grounds on the debtor’s application (Art. V(1))

Incapacity of the parties / invalidity of the arbitration agreement;

Improper notification or inability to present one’s case;

The award going beyond the scope of the arbitration agreement;

A breach of the procedure for constituting the tribunal or of the procedure;

The award has not become binding or has been set aside / suspended in the country where it was made.

4.2. Grounds examined by the court (Art. V(2))

Non-arbitrability of the dispute under Turkish law;

Contradiction with the public policy of Turkey.

After the award has been rendered enforceable (tenfiz), recovery is carried out under the Code of Enforcement and Bankruptcy (İİK) through the enforcement authorities (icra dairesi): attachment of property and accounts, and levying of execution against the debtor’s assets.[9]

6.1. Tracing the debtor’s assets

Useful resources:

Trade register (Ticaret Sicili Gazetesi): www.ticaretsicil.gov.tr;

The UYAP / e-Devlet system (enforcement cases): www.turkiye.gov.tr;

Land register (Tapu ve Kadastro) — through the registration authorities.

6.2. Practical advantages and obstacles

Priority of the Convention: under Article 90 of the Constitution, the courts are obliged to apply it directly;[2]

Finality: only kesinleşmiş awards are enforceable — confirm that they have entered into force;[5]

Translation and legalisation: prepare a certified translation into Turkish, as a rule with an apostille.

7.1. Legislation and official sources

→ mevzuat.gov.tr — Law No. 5718 (MÖHUK): mevzuat.gov.tr

→ New York Convention (Turkey): newyorkconvention.org

7.2. Registers

Trade register: www.ticaretsicil.gov.tr

e-Devlet (enforcement): www.turkiye.gov.tr

7.3. Arbitration institutions

Istanbul Arbitration Centre (ISTAC): www.istac.org.tr

7.4. Specialists in the enforcement of arbitral awards in Turkey

A list of recommended specialists is published on the official website of the Riga Court of Arbitration:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as of mid-2026. Below is a list of the materials on which this guide relies.

Legislation and international treaties

[1] Turkey’s Law on Private International Law and Procedure No. 5718 (IPPL / MÖHUK), Arts. 50–59 (court judgments), 60–63 (arbitral); Code of Civil Procedure (HMK); Code of Enforcement and Bankruptcy (İİK). mevzuat.gov.tr

[2] Constitution of Turkey, Art. 90 (priority of treaties); 1958 New York Convention (Turkey — since 01.10.1992, reservations as to reciprocity and commercial character); 1961 European Convention (since 23.09.1991).

[3] New York Convention, Art. I; delineation of the scope of the Convention and the IPPL.

[6] Art. IV of the New York Convention (documents; translation into Turkish).

Analytical and reference materials

[4] IBA — Recognition and enforcement of foreign court judgments and arbitral awards in Turkey (Asliye; jurisdiction; Istanbul/Ankara/Izmir).

[5] IBA — Recognition and enforcement of international arbitral awards in Turkey; Inal Law Office — Turkey (tanıma/tenfiz; finality; appeal).

[7] istanbulattorneys.com — Enforcing Foreign Arbitral Awards in Turkey 2026 (time limits 6–12 / 18–24 months).

[8] Kılınç Law — Recognition and Enforcement of Foreign Arbitral Awards in Turkey; Mondaq — Turkey (grounds under Art. V of the Convention).

[9] Kesikli Law — Enforce an Arbitral Award in Turkey; willeague — Recognition and Enforcement in Turkey (İİK; enforcement authorities).

1.1. Two regimes: onshore and offshore

The UAE operates two parallel regimes. The federal (‘onshore’) regime covers the courts of the emirates (a civil-law system). Separately, offshore financial centres operate under their own common-law systems — DIFC (Dubai International Financial Centre) and ADGM (Abu Dhabi Global Market) — with their own arbitration laws and courts. An award may be enforced through either regime; the choice of regime determines the procedure and strategy.[1]

1.2. Principal legislation (onshore)

Federal Law No. 6 of 2018 on Arbitration (as amended by Federal Decree-Law No. 15 of 2023) primarily governs domestic awards. The recognition and enforcement of foreign awards are governed by Federal Decree-Law No. 42 of 2022 on Civil Procedure (the new CPC), in particular Articles 222–223, as well as Cabinet Decision No. 57/2018 (Articles 85–86). The new procedure came into force on 2 January 2023.[2]

1.3. The New York Convention

The UAE acceded to the 1958 New York Convention by Federal Decree No. 43 of 2006. Article 5 of that decree incorporates Article V of the Convention; the UAE courts apply the provisions of the Convention when enforcing foreign awards and adhere to a pro-enforcement approach (the Dubai Court of Cassation confirmed that the absence of the signatures of all arbitrators on a foreign award does not prevent enforcement).[3]

2.1. The authority

A party seeking to enforce a foreign award onshore files an application with the execution court of the emirate in which enforcement is sought (Articles 85–86 of Cabinet Decision No. 57/2018). The law does not require the debtor’s assets in the UAE to be identified in advance.[4]

2.2. Conditions under Article 223 of the CPC

Article 223 of the CPC sets out two requirements for enforcing a foreign award: (i) the dispute must be arbitrable under UAE law; and (ii) the award must be enforceable in the country of the seat of arbitration. These conditions are consistent with the Convention (Articles V(2)(a) and V(1)(e)).[5]

2.3. Appeal

A party that has lost in the original proceedings is entitled to appeal the decision of the execution court to the competent Court of Appeal within 30 days; thereafter, where permissible, to the Court of Cassation.[6]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are attached:[7]

A certified original of the arbitral award or a certified copy thereof;

The original of the arbitration agreement or a certified copy thereof;

A certified translation into Arabic (for onshore courts; in the DIFC/ADGM, proceedings are conducted in English).

3.2. Route via the DIFC / ADGM

Filing through the DIFC or ADGM courts makes it possible to avoid the mandatory translation into Arabic at the initial stage and to make use of the English-language common-law procedure; a ‘channelling’ (onshore execution) is then possible in order to levy execution against assets in the emirates.[8]

3.3. Limitation period

Federal legislation does not expressly establish a specific time limit for filing an application for recognition and enforcement; in practice it is advisable to send the debtor a demand notice and to allow a reasonable period (for example, two weeks) before filing.[9]

The grounds correspond to Article V of the New York Convention; on the court’s own initiative (ex officio) only arbitrability and public policy are examined, both construed narrowly.[10]

4.1. Grounds raised on the debtor’s application (Article V(1))

Incapacity of the parties / invalidity of the arbitration agreement;

Improper notice or inability to present one’s case;

The award going beyond the scope of the arbitration agreement;

Breach of the rules on the composition of the tribunal or of the procedure;

The award has not become binding, or has been set aside / suspended in the country where it was made.

4.2. Grounds examined by the court (Article V(2))

Non-arbitrability of the dispute under UAE law;

Conflict with the public policy of the UAE (for foreign awards this is generally assessed under the law of the seat of arbitration, unless there is a substantial conflict with UAE public policy).

The arbitral tribunal and the courts are vested with broad powers to grant interim measures (Articles 18–21 of the Arbitration Act): preservation of assets, prohibition on disposing of assets, preservation of evidence, security for costs. Filing an application to set aside the award (Article 54 of the Act; time limit — 30 days) does not automatically suspend enforcement until the court issues a corresponding ruling. Once recognised, the award is treated as equivalent to a court judgment and is enforced under the CPC.[11]

6.1. Tracing the debtor’s assets

Useful resources:

The emirates’ Departments of Economic Development (DED) — company registers (e.g. Dubai DED);

The DIFC and ADGM registers: www.difc.ae, www.adgm.com;

Land departments (e.g. Dubai Land Department): dubailand.gov.ae.

6.2. Practical advantages and obstacles

Choice of regime: onshore or DIFC/ADGM — determines the language, procedure and strategy;[1]

Translation into Arabic: mandatory for onshore courts — allow for time and costs;

The representative’s authority: make sure the arbitration agreement was signed by an authorised person (a common line of objection).

7.1. Legislation and official sources

→ Official UAE legislation portal: uaelegislation.gov.ae

→ New York Convention (UAE): newyorkconvention.org

7.2. Registers

DIFC: www.difc.ae

ADGM: www.adgm.com

7.3. Arbitration institutions

Dubai International Arbitration Centre (DIAC): www.diac.com

ADGM Arbitration Centre (arbitrateAD): www.arbitratead.com

7.4. Specialists in the enforcement of arbitral awards in the UAE

A list of recommended specialists is available on the official website of the Riga Court of Arbitration:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from open sources as of mid-2026. Below is a list of the materials on which this guide relies.

Legislation and international treaties

[1] The two UAE regimes: the federal (onshore) and the offshore (DIFC, ADGM), each with its own arbitration laws and courts.

[2] Federal Law No. 6/2018 on Arbitration (amended by Federal Decree-Law No. 15/2023); Federal Decree-Law No. 42/2022 (CPC), Articles 222–223; Cabinet Decision No. 57/2018, Articles 85–86 (in force since 02.01.2023). uaelegislation.gov.ae

[3] Federal Decree No. 43/2006 (accession to the New York Convention; Article 5 — incorporation of Article V of the Convention).

[5] UAE CPC, Article 223 (arbitrability under UAE law; enforceability in the country of the seat of arbitration).

[7] Article IV of the New York Convention (documents; translation into Arabic for onshore).

Case law

[10] HFW — Dubai Court of Cassation reinforces the New York Convention (narrow interpretation; arbitrators’ signatures; public policy under the law of the seat).

Analytical and reference materials

[4] Global Arbitration Review — Challenging and Enforcing Arbitration Awards: UAE (the execution court; Articles 85–86 of Cabinet Decision No. 57/2018).

[6] Hong Kong Lawyer — A Guide to Recognition and Enforcement of Foreign Arbitral Award in the UAE (appeal — 30 days; in force since 02.01.2023).

[8] uaeahead.com — Enforcement of Foreign Arbitration Awards in the UAE (the DIFC/ADGM route; English-language procedure).

[9] Global Arbitration Review — UAE (Horizons & Co) — absence of a specific time limit; demand notice.

[11] Kluwer Arbitration Blog — Enforcement of Foreign Awards in the UAE; Norton Rose Fulbright — UAE (Articles 18–21, 54 of the Arbitration Act; interim measures).

This guide concerns England and Wales (the law of Scotland and Northern Ireland differs).

1.1. Principal legislation

The recognition and enforcement of arbitral awards in England and Wales is governed by the Arbitration Act 1996 (c. 23). Part III (sections 100–104) is specifically devoted to awards under the New York Convention. In addition, section 66 of the Act provides for the enforcement of arbitral awards under the general procedure (with the leave of the court — as a judgment of the court).[1]

The 1996 Act has been amended by the Arbitration Act 2025, which received Royal Assent on 24 February 2025; its principal provisions came into force during 2025, modernising the 1996 Act (the law applicable to the arbitration agreement is, by default, the law of the seat of arbitration; a disclosure duty for arbitrators; summary disposal; the emergency arbitrator, and others). The regime for the enforcement of awards under sections 100–104 has, however, been retained in substance.[2]

1.2. The New York Convention

The United Kingdom signed and ratified the 1958 New York Convention in 1975, making one reservation — as to reciprocity (the Convention applies to awards made in the territory of another contracting State). The United Kingdom is also a party to the 1927 Geneva Convention.[3]

2.1. The court

The competent court is the High Court, in practice — the Commercial Court. The meaning of the term "court" (the jurisdiction of the High Court and the county court) is defined by section 105 of the Act.[4]

2.2. Nature of the procedure

An application for leave to enforce is made without notice to the other party (ex parte) as an arbitration claim under Part 62 of the Civil Procedure Rules (CPR Part 62); it is accompanied by evidence (a witness statement) with the arbitration agreement and the award attached. The court may order service of the claim, after which the proceedings continue on an adversarial basis.[5]

Since the application is made without notice, the applicant is under a duty of full and frank disclosure of all material facts, including information about any setting-aside proceedings. Failure to comply with this duty may result in the order being set aside or in costs sanctions.[6]

2.3. Methods of enforcement and merger

Under section 101(2), with the leave of the court, the award is enforced in the same manner as a judgment; under section 101(3), the court may enter judgment in terms of the award — in which case the arbitral award "merges" with the judgment (merger), which has important procedural consequences.[7]

3.1. Required documents

Under section 102 of the Act, the following are attached:[8]

The duly authenticated original of the arbitral award or a certified copy thereof;

The original of the arbitration agreement or a certified copy thereof;

A certified translation, if the award or the agreement is drawn up in a foreign language.

3.2. Limitation period

The same limitation rules apply to the enforcement of the award as to an action on the award: as a general rule — six years from the accrual of the cause of action (non-compliance with the award), and if the arbitration agreement is made "under seal" (specialty) — twelve years.[9]

3.3. Court costs

Court fees and the costs of legal representation and translation are taken into account; the specific rates should be verified at the time of filing.[4]

Section 103 contains the same grounds for refusal as Article V of the New York Convention; the list is exhaustive (Rosseel NV v Oriental Commercial & Shipping). Challenges on these grounds are dealt with by way of a rehearing, not a review: the court determines the question afresh.[10]

4.1. Grounds raised on the debtor's application (s. 103(2) / Art. V(1))

Incapacity of the parties / invalidity of the arbitration agreement;

Improper notice or inability to present the case;

The award going beyond the scope of the arbitration agreement;

Breach of the composition of the tribunal or of the procedure;

The award has not become binding or has been set aside / suspended in the country where it was made (s. 103(2)(f)).

4.2. Grounds examined by the court (s. 103(3) / Art. V(2))

Non-arbitrability of the dispute;

Conflict with public policy.

Even where one of the grounds is established, the English court retains a residual discretion to allow enforcement, but construes it narrowly (Dallah Real Estate & Tourism Holding Co v Ministry of Religious Affairs of the Government of Pakistan).[11]

4.3. An award set aside abroad

Under section 103(2)(f), enforcement may be refused if the award has been set aside or suspended by a competent authority of the country in which it was made. In Yukos Capital SARL v OJSC Rosneft Oil Company ([2014] EWHC 2188 (Comm)), the court confirmed that, in deciding this question, principles of honesty, natural justice and public policy are taken into account, including possible bias on the part of the foreign court.[12]

Under section 103(5) of the Act, if an application for the setting aside or suspension of the award has been made in the country where it was made, the English court may, if it considers it proper, adjourn the decision on recognition or enforcement (and may order the provision of security).[13]

Once leave has been obtained (or judgment has been entered in terms of the award), enforcement is carried out by the ordinary means of English enforcement proceedings: levying execution against property, bank accounts (third party debt order), the debtor's shares and assets; the appointment of a receiver, and others.[7]

6.1. Tracing the debtor's assets

Useful resources:

The companies register (Companies House): www.gov.uk/government/organisations/companies-house;

The land registry (HM Land Registry): www.gov.uk/government/organisations/land-registry;

The Register of Judgments: www.trustonline.org.uk.

6.2. Practical advantages and obstacles

London — a leading centre: a developed, predictable, pro-enforcement practice;

Full & frank disclosure: when applying without notice, disclose all material facts, including setting-aside proceedings;[6]

The 2025 reform: take into account the new provisions of the Arbitration Act 2025 when structuring the arbitration.

7.1. Legislation and official sources

→ legislation.gov.uk — Arbitration Act 1996: legislation.gov.uk/ukpga/1996/23

→ The New York Convention (United Kingdom): newyorkconvention.org

7.2. Registers

Companies House: gov.uk/government/organisations/companies-house

HM Land Registry: gov.uk/government/organisations/land-registry

7.3. Arbitration institutions

The London Court of International Arbitration (LCIA): www.lcia.org

7.4. Specialists in the enforcement of arbitral awards in the United Kingdom

A list of recommended specialists is published on the official website of the Riga Court of Arbitration:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from open sources as at mid-2026. Below is a list of the materials on which this guide relies.

Legislation and international treaties

[1] Arbitration Act 1996 (c. 23), Part III, ss. 100–104; ss. 66, 105. legislation.gov.uk

[2] Arbitration Act 2025 (Royal Assent 24.02.2025) — amendments to the 1996 Act.

[3] The 1958 New York Convention (United Kingdom — 1975, reciprocity reservation); the 1927 Geneva Convention.

[8] Arbitration Act 1996, s. 102 (documents: authenticated award/copy, agreement, translation).

[9] Limitation Act 1980 — 6 years (action on the award) / 12 years (specialty).

Case law

[10] Rosseel NV v Oriental Commercial & Shipping Co (UK) Ltd [1991] 2 Lloyd's Rep. 625 (exhaustive list under s. 103).

[11] Dallah Real Estate & Tourism Holding Co v Ministry of Religious Affairs of the Government of Pakistan [2009] EWCA Civ 755 (narrow discretion).

[12] Yukos Capital SARL v OJSC Rosneft Oil Company [2014] EWHC 2188 (Comm) (s. 103(2)(f); honesty, natural justice, public policy).

Analytical and reference materials

[4] ICLG — International Arbitration 2025–2026, England & Wales (High Court; s. 105).

[5] Fortior Law — Enforcement of arbitral awards in England and Wales (CPR Part 62; ex parte; ss. 66/101).

[6] Fortior Law — full and frank disclosure (disclosure when applying without notice).

[7] Jenner — Guide to Enforcement of Foreign Arbitral Awards (ss. 101(2), 101(3) — merger of the award).

[13] Lexology — In brief: enforcing and challenging arbitral awards in United Kingdom (s. 103(5) — adjournment).

1.1. Primary legislation

International commercial arbitration is governed by the Law of Ukraine «On International Commercial Arbitration» of 24 February 1994 (LICA), which is based on the UNCITRAL Model Law. Procedural matters of recognition and enforcement of awards are governed by the Civil Procedure Code of Ukraine (CPC), Section IX; annulment matters — by Section VIII.[1]

The 2017 reform transferred jurisdiction over the recognition and enforcement of foreign awards to the Kyiv Court of Appeal (with the Supreme Court as the higher instance), which raised the quality of judicial review and the consistency of practice.[2]

1.2. The New York Convention

Ukraine is a party to the 1958 New York Convention. Foreign awards are enforced only after recognition by a Ukrainian court under the Convention or another applicable treaty. In the absence of a treaty, recognition is carried out on the basis of the principle of reciprocity, which is presumed until the party opposing enforcement proves otherwise.[3]

1.3. Other international treaties

The 1961 European Convention and the Washington ICSID Convention;

The Energy Charter Treaty and more than 60 bilateral investment treaties.[4]

2.1. The court

The recognition and enforcement of a foreign arbitral award falls within the exclusive jurisdiction of the Kyiv Court of Appeal (the court whose jurisdiction extends over the city of Kyiv — Article 475(3) CPC), acting as a court of first instance. Its ruling may be appealed to the Supreme Court.[5]

2.2. Procedure for consideration

The court notifies the debtor of the application and invites the submission of objections within one month, after which it considers the application either on the basis of the documents submitted or at a court hearing with the participation of the parties. By law, the application must be considered within two months; in practice, owing to the war and the large number of cases, the period may be longer, sometimes up to a year. The ruling may be appealed to the Supreme Court within thirty days from the date it was made.[6]

2.3. Prohibition on review of the merits

A national court is not entitled to review an arbitral award on the merits. Thus, in case No. 824/155/24 the Supreme Court (ruling of 10 April 2025) upheld recognition and enforcement, pointing to the absence of grounds for annulment, since the court does not review the merits of the tribunal's award.[7]

3.1. Required documents

In accordance with Article IV of the New York Convention and the CPC, the following are attached:[8]

The original of the award or a notarised copy of the arbitral award;

The original of the arbitration agreement or a certified copy thereof;

A certified translation into Ukrainian, if the documents are drawn up in another language.

3.2. Limitation period

An application for recognition and enforcement is submitted within three years from the date the award was made (Article 475 CPC). If the deadline is missed, the court returns the application without consideration, unless the applicant petitions for reinstatement of the deadline and the court finds the reasons for the delay to be valid.[9]

3.3. Court costs

The court fee and the costs of translation and legal support are taken into account; the specific rates should be verified at the time of submission.[5]

The grounds correspond to Article V of the New York Convention (as well as the LICA and the CPC). Ukrainian courts, unlike a number of neighbouring jurisdictions, generally do not expand the grounds for refusal and apply the public policy reservation narrowly.[10]

4.1. Grounds raised on the debtor's application (Art. V(1))

Incapacity of the parties / invalidity of the arbitration agreement;

Improper notification or inability to present one's position;

The award going beyond the scope of the arbitration agreement;

Breach of the procedure for constituting the tribunal or of the proceedings;

The award has not become binding, or has been set aside / suspended in the country where it was made.

4.2. Grounds examined by the court (Art. V(2))

Non-arbitrability of the dispute under Ukrainian law;

Contradiction with the public policy of Ukraine (interpreted narrowly).

The procedure for setting aside an award does not in itself automatically suspend its enforcement. However, the court (as a rule, the Kyiv Court of Appeal) has the discretion to suspend recognition and enforcement if an application to set aside the award is being considered before a Ukrainian or a competent foreign court.[11]

Once leave to enforce has been granted, recovery is carried out through the enforcement service / private enforcement officers: seizure of property and accounts, levying execution against the debtor's assets.[6]

6.1. Tracing the debtor's assets

Useful resources:

Unified State Register of Legal Entities (USR): usr.minjust.gov.ua;

State Register of Rights to Immovable Property — via the Ministry of Justice;

Unified Register of Debtors: asvp.minjust.gov.ua.

6.2. Practical advantages and obstacles

Centralisation: all cases go to the Kyiv Court of Appeal, which increases consistency;[5]

Martial law: processing times are in practice extended — allow for time;[6]

Narrow ordre public: Ukrainian courts rarely refuse on public policy grounds.

7.1. Legislation and official sources

→ zakon.rada.gov.ua — 1994 Law on ICA and the CPC: zakon.rada.gov.ua

→ New York Convention (Ukraine): newyorkconvention.org

7.2. Registers

Unified State Register: usr.minjust.gov.ua

Unified Register of Debtors: asvp.minjust.gov.ua

7.3. Arbitration institutions

International Commercial Arbitration Court at the Ukrainian Chamber of Commerce and Industry (ICAC): icac.org.ua

7.4. Specialists in the enforcement of arbitral awards in Ukraine

A list of recommended specialists is published on the official website of the Riga Court of Arbitration:

→ court.lv/en/support/specialists

SOURCES

The information has been gathered from open sources as of mid-2026. Below is a list of the materials on which this guide relies.

Legislation and international treaties

[1] Law of Ukraine «On International Commercial Arbitration» of 24.02.1994 (LICA); Civil Procedure Code of Ukraine, Sections VIII–IX (in particular Art. 475). zakon.rada.gov.ua

[2] The 2017 judicial reform — transfer of jurisdiction to the Kyiv Court of Appeal.

[3] The 1958 New York Convention (Ukraine — a party State); the principle of reciprocity in the absence of a treaty.

[4] The 1961 European Convention; the Washington ICSID Convention; the Energy Charter Treaty; bilateral investment treaties (60+).

Case law

[7] Supreme Court of Ukraine, case No. 824/155/24, ruling of 10 April 2025 (prohibition on review of the merits).

Analytical and reference materials

[5] Global Arbitration Review — Ukraine; Legal500 — How to Enforce Foreign Arbitral Awards in Ukraine (Art. 475(3) CPC; Kyiv Court of Appeal).

[6] Fortior Law — Recognition and Enforcement of Foreign Arbitral Awards in Ukraine (notification of the debtor, 1 month; period of 2 months; impact of the war).

[8] CMS Expert Guides — Ukraine (notarised copy; Art. IV of the Convention).

[9] Global Arbitration Review — Ukraine; Art. 475 CPC (three-year period; reinstatement).

[10] CMS — International Arbitration in Ukraine: The current landscape (narrow interpretation of ordre public; pro-arbitration stance).

[11] Global Arbitration Review — Challenging and Enforcing Arbitration Awards: Ukraine (AVELLUM) — suspension at the discretion of the court (Arts. 367, 383 CPC).

This guide concerns the US federal regime; certain procedural matters may depend on the particular state and district.

1.1. Principal legislation

The recognition and enforcement of foreign arbitral awards in the USA is governed by Chapter 2 of the Federal Arbitration Act (FAA), 9 U.S.C. §§ 201–208, which implements the New York Convention. Chapter 3 (§§ 301–307) implements the 1975 Panama Convention, while Chapter 1 applies subsidiarily (§ 208).[1]

Key provisions: § 201 gives effect to the Convention; § 202 defines which agreements and awards fall under the Convention (commercial; relationships solely between US citizens are excluded unless there is property abroad, enforcement abroad or some other reasonable connection with a foreign state); § 203 confers jurisdiction on the federal district courts regardless of the amount in controversy; § 204 governs venue; § 205 — removal of a case from a state court to a federal court at any time before trial; § 206 — the court's power to compel arbitration; § 207 — confirmation of the award; § 208 — subsidiary application of Chapter 1.[2]

1.2. The New York Convention

The USA acceded to the 1958 New York Convention in 1970 (in force since 29 December 1970), making two reservations — as to reciprocity and as to commercial character. A case falling under the Convention is deemed to arise under the laws and treaties of the USA (federal question).[3]

1.3. Primary and secondary jurisdiction

A distinction is drawn between primary and secondary jurisdiction (CBF Indústria de Gusa v AMCI, 850 F.3d 58 (2d Cir. 2017)). A foreign award (rendered abroad) falls under secondary jurisdiction: the court merely confirms/enforces it and may refuse only on the grounds set out in Articles V/VI of the Convention, but has no power to vacate it. An award rendered in the USA but falling under the Convention ("non-domestic") pertains to primary jurisdiction and may be vacated under FAA §§ 10–11.[4]

2.1. The court

A petition to confirm is filed with the US federal district court (US District Court) having personal jurisdiction over the debtor or its property — as a rule, at the location of the debtor's assets. Jurisdiction is federal and does not depend on the amount in controversy (§ 203).[5]

2.2. Confirmation of the award (§ 207)

Within three years after an award falling under the Convention has been rendered, any party is entitled to apply to the competent court for an order confirming the award. The court must confirm the award unless it finds one of the grounds for refusal or deferral of recognition/enforcement provided for in Article V (or VI) of the Convention.[6]

2.3. Enforcement against third parties

Under secondary jurisdiction, the court is entitled not only to enter judgment on the arbitral award but also to levy execution against a third party not named in the award — under the alter ego theory or other enforcement principles (CBF Indústria de Gusa, 850 F.3d).[7]

3.1. Required documents

In accordance with Article IV of the New York Convention, the following are attached:[8]

The duly authenticated original arbitral award or a certified copy thereof;

The original arbitration agreement or a certified copy thereof;

A certified translation, if the award or the agreement is drawn up in a foreign language.

3.2. Limitation period

The period is three years from the date the award was rendered (§ 207), as opposed to the one-year period for domestic awards under Chapter 1 of the FAA.[9]

3.3. Court costs

Federal court fees and the costs of legal representation and translation are taken into account; the rates depend on the district and are to be verified at the time of filing.[5]

The grounds are exhaustively set out in Article V of the New York Convention; US courts construe them narrowly, maintaining a pro-enforcement orientation (Parsons & Whittemore Overseas Co. v. RAKTA, 508 F.2d 969 (2d Cir. 1974)).[10]

4.1. Grounds raised on the debtor's application (Art. V(1))

Incapacity of the parties / invalidity of the arbitration agreement;

Improper notice or inability to present one's case;

The award going beyond the scope of the arbitration agreement;

Breach of the composition of the tribunal or of the procedure;

The award has not become binding or has been set aside / suspended in the country where it was rendered.

4.2. Grounds examined by the court (Art. V(2))

Non-arbitrability of the dispute under US law;

Conflict with US public policy (construed narrowly).

After confirmation, the arbitral award is converted into a judgment and enforced under the general rules for the enforcement of US judgments: the attachment and sale of property, levying execution against accounts (garnishment), shares and other assets of the debtor, including in different states. Against foreign states, the Foreign Sovereign Immunities Act (FSIA) applies, with an arbitration exception.[11]

6.1. Tracing the debtor's assets

Useful resources:

State company registers (Secretary of State) — e.g., bizfileonline.sos.ca.gov (California), apps.dos.ny.gov (New York);

The federal PACER system (court cases): pacer.uscourts.gov;

UCC registers of security interests — at the state level.

6.2. Practical advantages and obstacles

Secondary jurisdiction: a foreign award cannot be set aside — it can only be refused under Art. V/VI;[4]

Personal jurisdiction: file in the district where the debtor has assets or a connection;

Alter ego: recovery from related persons is possible where it is proven.

7.1. Legislation and official sources

→ Cornell LII — 9 U.S.C. Chapter 2 (§§ 201–208): law.cornell.edu/uscode/text/9

→ The New York Convention (USA): newyorkconvention.org

7.2. Registers

Federal courts (PACER): pacer.uscourts.gov

State company registers: Secretary of State websites

7.3. Arbitration institutions

International Centre for Dispute Resolution (ICDR/AAA): www.icdr.org

JAMS International: www.jamsadr.com

7.4. Specialists in the enforcement of arbitral awards in the USA

A list of recommended specialists is available on the official website of the Riga Court of Arbitration:

→ court.lv/en/support/specialists

SOURCES

The information has been compiled from publicly available sources as of mid-2026. Below is a list of the materials on which this guide relies.

Legislation and international treaties

[1] Federal Arbitration Act (FAA), 9 U.S.C. §§ 201–208 (Chapter 2 — the New York Convention), §§ 301–307 (Chapter 3 — the Panama Convention). law.cornell.edu; uscode.house.gov

[2] 9 U.S.C. §§ 201–208 (in particular § 202 — scope; § 203 — jurisdiction; § 205 — removal; § 207 — confirmation; § 208 — subsidiarity).

[3] The 1958 New York Convention (USA — accession 1970, in force since 29.12.1970; reservations as to reciprocity and commercial character).

[9] 9 U.S.C. § 207 — the three-year period for confirmation.

Case law

[4] CBF Indústria de Gusa S/A v. AMCI Holdings, Inc., 850 F.3d 58 (2d Cir. 2017) — primary/secondary jurisdiction; alter ego.

[7] CBF Indústria de Gusa, 850 F.3d 58 (enforcement against third parties).

[10] Parsons & Whittemore Overseas Co. v. Société Générale de L'Industrie du Papier (RAKTA), 508 F.2d 969 (2d Cir. 1974) — narrow interpretation, pro-enforcement approach.

Analytical and reference materials

[5] Jenner & Block — USA Enforcement guide; Ruhm & Associates — Enforcement under the New York Convention (petition to confirm; personal jurisdiction).

[6] Lexology — Confirming Arbitration Awards Made Abroad (§ 207 FAA).

[8] Article IV of the New York Convention; Jenner — USA Enforcement guide (documents).

[11] Loree Law Firm — Foreign Awards (secondary jurisdiction; the Panama Convention); the Foreign Sovereign Immunities Act (FSIA).