2025: Year in Review

The last year has seen some notable developments in the global international arbitration space. In this article, we take you through important legislative and judicial developments across our key office locations.  

United Kingdom

The United Kingdom saw efforts to modernize the legislative arbitration framework in England, Wales, and Northern Ireland. The Arbitration Act 2025, which came into force on 1 August 2025, introduced targeted reforms to the Arbitration Act 1996. The new law codified common law, making the 1996 Act more user-friendly and tidied up some irregularities within the 1996 Act. The key features of the new law, which applies to all arbitral proceedings commenced after 1 August 2025, including both court proceedings and arbitral awards, are discussed here. 

The latter half of 2025 also saw the announcement of the 14th Programme of Law Reform which aims to review the legal framework surrounding trust law arbitration, signalling a growing judicial and legislative interest in expanding arbitration's role in trust disputes. 

There were also some notable arbitration-related developments in the UK courts. In A Corporation v (1) Firm B (2) Mr W [2025] EWHC 1092 (Comm), the High Court clarified the boundaries of arbitral confidentiality, particularly for law firms that act for connected clients in multiple arbitrations. In CC/Devas (Mauritius) Ltd and Others v India [2025] EWHC 964 (Comm), the English High Court found that ratification of the New York Convention would not, by itself, waive a State’s sovereign immunity against the enforcement of an arbitral award against it. 

France

In France, efforts to reform the French arbitration law, which kicked off in 2024, continued through 2025. In March 2025, a 17-member working group submitted a report with reform proposals and a draft Code of Arbitration, which is expected to be codified in the second half of 2026. The Paris Court of Appeal also confirmed that an arbitral award would exclude procedural orders and interim measures. 

Switzerland

In Switzerland, the Court of Arbitration for Sport (CAS) issued a new Code of Sports-related Arbitration, which applies to all CAS procedures initiated from 1 July 2025. 

In Case of Semenya v Switzerland (Application no. 10934/21), the Grand Chamber of the European Court of Human Rights held that the Federal Supreme Court of Switzerland (and other national courts) was required to adopt a “particularly rigorous” standard while considering appeals to awards from CAS arbitrations in which fundamental individual rights were at stake. This judgment is important because, as warned in the dissenting opinion, it created a risk that this higher standard for review of arbitral awards would be applied by national courts to arbitral awards in general. 

Italy 

In Italy, the Tribunal of Milan clarified the scope of the 2023 reforms to the Italian arbitration law pursuant to which arbitral tribunals in Italian-seated arbitrations were authorized to grant interim measures in proceedings initiated after February 2023; the Tribunal held that arbitral tribunals would not have the power to issue interim measures in cases of proceedings arising from arbitration agreements which had been signed before February 2023. 

United Arab Emirates

UAE users were among the top users of arbitration at the ICC (ranking tenth overall), the LCIA (ranked fifth overall), and the SIAC (ranking eighth largest foreign user) (based on 2024 caseload statistics announced in 2025). Notably, the year also saw a conclusion to the uncertainty surrounding the signature requirements for an arbitral award. The UAE Federal and Local Judicial Principles Unification Authority confirmed that arbitral awards need only be signed on the final page of the award. All courts in the UAE must now comply with this interpretation of the signature requirement. Other notable pro-arbitration judicial decisions included a Dubai Court of Cassation judgment confirming an arbitral tribunal’s authority to issue anti-suit injunctions under the Federal Arbitration Law. 

Bahrain

In Bahrain, the Bahrain International Commercial Court (BICC) was launched. The BICC will have jurisdiction over disputes relating to arbitrations, including matters related to interim measures and tribunal composition, with the possibility of appeals to the Singapore International Commercial Court. Bahrain also became the first country in the Middle East to conclude a Host Country Agreement with the Permanent Court of Arbitration (PCA) to facilitate the conduct of PCA proceedings in Bahrain.

Qatar

In Qatar, the revised Arbitration Rules of the Qatar International Center for Conciliation and Arbitration came into force on 1 January 2025. The updated rules provide for expedited procedures, electronic submissions and digital signatures, and consolidation and joinder. The Qatar Financial Center (QFC) Court also exhibited a pro-arbitration stance by ruling, in two separate cases involving ambiguously worded arbitration clauses, that parties can designate the QFC as a supervisory court in their arbitration agreements, even if the arbitration is seated in onshore Qatar. 

Singapore

In Singapore, the seventh edition of the Arbitration Rules of the Singapore International Arbitration Centre (SIAC) came into effect on 1 January 2025 (the 2025 Rules). These rules, applicable to all arbitrations commenced from that date unless parties stipulate otherwise, are set to redefine the efficiency, flexibility, and transparency of the arbitration process. The key innovations of the 2025 Rules are discussed here. In August, SIAC also launched a Restructuring and Insolvency Arbitration Protocol which provides a procedure for arbitrating disputes related to restructuring, adjustment of debts, and insolvency. Over the year, the Singapore High Court also demonstrated its pro-arbitration stance by confirming that administrative and procedural decisions of arbitral institutions will only be revisited in exceptional circumstances and clarified the distinction between interim measures (which do not definitively resolve an issue and are inherently capable of variation) and final awards (which conclusively dispose of a claim).

Hong Kong

In Hong Kong, a project to review the existing national arbitration framework was announced in September 2025. A Working Group is currently undertaking the review process, and has identified as topics for consideration the governing law of the arbitration agreement, scope of disputes for arbitration, arbitral tribunal’s powers and jurisdiction, court’s powers, and the use of artificial intelligence in arbitration. 

In Hyalroute Communication Group Limited v. Industrial And Commercial Bank Of China (Asia) Limited [2025] HKCFI 2417, the Hong Kong Court of First Instance ruled for the first time that foreign winding-up proceedings would not automatically need to be stayed in favour of arbitration; the language of the arbitration clause, as well as the legal effect of foreign insolvency proceedings on the dispute to be presented to arbitration were the relevant factors to be considered.