London Retains Status as Global Arbitration Hub

This article is part of the "International Arbitration Perspectives" series. 

In 2025, the UK has remained committed to reinforcing its status as a global arbitration hub through legislative and regulatory updates and a significant body of jurisprudence on key issues – notably confirming the courts’ limited interference with arbitral awards, save in exceptional circumstances (see our alert here).

London remains one of the world’s leading arbitration centres, and the most preferred seat of arbitration globally. 2025 data confirms English law as the preferred applicable law for international commerce worldwide. It is the most common applicable law in LCIA (78% of all arbitrations) and ICC arbitrations (15% of all arbitrations) and the second most common law in HKIAC, SCC and SIAC arbitrations¹–a preference that will continue to attract arbitrations to London in the coming years.

English Arbitration Act 2025

Almost 30 years after the English Arbitration Act 1996, the UK enacted the English Arbitration Act 2025, which enhances rather than overhauls the existing framework and seeks to “re-enforce Britain’s position as the best place to resolve disputes without having to go to court”.² The 2025 Act applies to arbitrations and arbitration-related court proceedings commenced on or after 1 August 2025 and introduces changes across several areas, including:

• Summary disposal: empowering tribunals to summarily dispose of claims or defences with no real prospect of success, mirroring court-style summary judgment. This is a departure from traditional arbitral caution and may trigger disputes over the proper threshold and due‑process limits.
  
  
• Governing law of the arbitration agreement: establishing a default rule that the law of the seat governs the arbitration agreement unless otherwise stated by the parties.
  
  
• Interim relief: expressly clarifying that peremptory orders by emergency arbitrators are enforceable in the same way as peremptory orders by tribunals and that the court’s power to order interim relief in support of arbitration includes making orders in relation to third parties.
  
  
• Arbitrators’ duty of disclosure: imposing an ongoing obligation on arbitrators to disclose circumstances that may give rise to justifiable doubts over their impartiality.
  
  
• Expanded arbitrator immunity: enhancing protections for arbitrators against liability arising from resignation or removal, supporting impartial decision-making.
  
  
• Reform of s. 67 jurisdiction challenges: limiting full rehearings where jurisdictional arguments have already been aired before the tribunal, allowing courts to rely on the tribunal’s findings.

Cases requiring the English courts to interpret the new provisions of the 2025 Act have yet to appear but are expected for 2026.

Enforcement of Intra-EU Investment Awards

Over the last decade, there has been significant debate on whether states implicitly waive sovereign immunity from enforcement by entering into multilateral treaties such as the ICSID Convention or the Energy Charter Treaty. This question has been particularly relevant with respect to intra-EU investment arbitrations.

In Infrastructure Services Luxembourg SARL & Anor v Kingdom of Spain, the English High Court,³ Court of Appeal,⁴ and most recently the Supreme Court⁵ held that Article 54 of the ICSID Convention constitutes a clear submission to jurisdiction for the purposes of recognising and enforcing ICSID awards (see our alert on the Supreme Court’s judgment here). Importantly, in line with the Supreme Court’s decision in Micula⁶, the High Court had affirmed that EU law cannot alter the obligation on ICSID Convention signatories to recognise and enforce awards made pursuant to that convention. While the Court of Appeal and the Supreme Court did not re-examine this question, their decisions effectively permitted the enforcement of an intra-EU ICSID award – further strengthening the UK’s position as a key jurisdiction for enforcement of intra-EU investment awards.

A similar approach has been taken by the courts in Australia⁷ and the US.⁸ By contrast, the EU remains committed to opposing intra-EU investment claims. Notably, in 2025, the EU Commission indicated that payment of an ICSID award by a member state to EU investors would constitute incompatible state aid.⁹

Driving Change Through AI Initiatives

Artificial intelligence is now embedded across the entire lifecycle of an arbitration, from early case assessment and document review to legal research, drafting, and even tribunal deliberation support (see our alert here), making technological capability a defining feature of modern arbitral practice.

London has positioned itself at the forefront of innovation with the Centre for International Arbitration recently issuing its Guideline on the Use of AI in Arbitration, which provides the first comprehensive soft‑law framework for the benefits, risks, and procedural management of AI tools in arbitral proceedings, including model AI agreements and procedural orders.¹⁰ The LCIA has announced a strategic partnership with Jus Mundi to develop arbitration‑specific AI solutions designed to enhance case analysis and decision‑making without compromising procedural integrity.¹¹

^{1 International Data Insights Report 3rd Edition 2025, The Law Society of England and Wales}

^{2 Boost for UK economy as Arbitration Act receives Royal Assent}

^{3 [2023] EWHC 1226 (Comm)}

^{4 [2024] EWCA Civ 1257}

^{5 [2026] UKSC 9}

^{6 [2020] UKSC 5}

^{7 Blasket Renewable Investments LLC v Kingdom of Spain [2025] FCA 1028 (29 August 2025) (Austl.). This case is currently pending an appeal.}

^{8 Blasket Renewable Invs., LLC v. Kingdom of Spain, No. 20-817 (JDB), 2025 WL 2336428 (D.C. Cir. Aug. 13, 2025)}

^{9 Antin (Case SA.54155 (2021/NN)) Commission Decision C(2025) 1781 final [2025] OJ L 1235/1.}

^{10 CIArb Guideline on Use of AI in Arbitration.}

^{11 LCIA-Jus Mundi Partnership.}