Explore the legislation governing major arbitration seats, with links to official texts and notes on amendments.
The law of the seat and the parties’ chosen rules perform different roles. Official pages may show editorial changes, translations or point-in-time versions: check commencement, transitional provisions and the law applicable to your dispute.
The 1996 Act established the principal framework for arbitration in England and Wales and Northern Ireland. It addresses arbitration agreements, tribunal powers, court support, awards and challenges. The Arbitration Act 2025 amends this Act; it does not replace it. The remaining provisions commenced on 1 August 2025, subject to transitional rules. The reforms include a new default rule on the law governing arbitration agreements. Scotland has a separate framework.
Scotland adopted its own arbitration statute in 2010. The Act and Scottish Arbitration Rules in Schedule 1 address appointments, procedure, tribunal powers, awards and court supervision. The Rules distinguish mandatory provisions from default rules that parties may vary. This separate framework matters when the seat is in Scotland: the Arbitration Act 1996 is not a single UK-wide code. Consult the live legislation for outstanding changes and applicable provisions.
Singapore’s International Arbitration Act gives the UNCITRAL Model Law force of law with statutory modifications. It addresses tribunal jurisdiction, court support, awards and recognition and enforcement. It is the primary starting point for Singapore-seated international cases and should be read alongside its schedules and later amendments. Singapore’s Arbitration Act 2001 provides a separate regime for matters outside the international Act; the nature of the dispute and applicable scope provisions matter.
India’s 1996 Act consolidated the law on arbitration and conciliation. Part I addresses the principal arbitration framework; Part II addresses enforcement of certain foreign awards under the New York and Geneva Conventions. Amendments in 2015, 2019 and 2021 changed aspects of the regime. The distinction between Indian and foreign seats is important when considering court assistance and challenges. Check the commencement and application of individual provisions for the proceedings in question.
Hong Kong’s Arbitration Ordinance created a largely unified framework based on the UNCITRAL Model Law for domestic and international arbitration. It covers tribunal powers, court assistance, confidentiality and enforcement, alongside provisions concerning funding and outcome-related fee structures. It is the starting point for Hong Kong-seated arbitration. Consult the current e-Legislation text and relevant subsidiary legislation; proposals in the 2026 reform consultation should not be confused with enacted amendments.
France’s arbitration framework appears in Book IV of its Code of Civil Procedure, substantially reformed in 2011. Its international arbitration provisions address procedure, court support, recognition, enforcement and challenges, with selected domestic provisions also applying. Decree No. 2026-741 is enacted and generally enters into force on 1 January 2027, subject to its specific transitional rules. This distinction matters for Paris-seated proceedings. The official legislation is in French.
The UAE’s federal arbitration law provides an onshore framework for arbitration agreements, tribunal procedure, awards and court involvement. Its 2023 amendments address matters including arbitrator appointment and procedural arrangements. The law is relevant to UAE onshore seats and enforcement planning, but the DIFC and ADGM have separate legal frameworks. Identifying the legal seat is therefore essential. The linked official portal offers an English version; consult the Arabic text where authoritative wording matters.
Originally enacted in 1925, the Federal Arbitration Act is codified in Title 9 of the United States Code. Chapter 1 addresses arbitration agreements and awards; Chapters 2 and 3 implement the New York and Inter-American Conventions. A separate Chapter 4, added in 2022, addresses specified sexual assault and sexual harassment disputes. State law, federal jurisdiction and court decisions also matter. Check the official Code’s laws-in-effect date for the relevant text.
Chapter 12 of the Swiss Private International Law Act governs international arbitration seated in Switzerland when its statutory conditions are met. It addresses the agreement, tribunal, procedure, awards and recourse. A revision of the international arbitration provisions entered into force on 1 January 2021. The regime matters for Geneva- and Zurich-seated arbitrations; domestic arbitration is addressed separately. Fedlex’s English translation is informational, while the official language texts have legal force.
