AIRPORTS ARE NOT usually considered the most exciting of places for regular travellers, but there is comfort in their sense of certainty. No matter how far from home, or how unfamiliar the local tongues and customs, one can expect an airport to pretty much look and operate like other airports.
For many years, the international arbitration community has striven for a similar sense of global standardisation, creating a consistent and predictable framework for parties worldwide without compromising regional strengths. China is no exception.
For example, the recent revision of the PRC Arbitration Law further aligned China’s framework with international standards by introducing principles such as the seat of arbitration and acknowledging ad hoc arbitration. Beyond playing the “catch up” game, the revision also encourages domestic arbitration institutions to set up entities overseas.
It is therefore encouraging that leading institutions in China’s legal market have, with impressive foresight, been working towards these goals for some time. In this series, we invited top representatives from eight of them to discuss the latest trends and developments in arbitration in China and beyond.
- Two-pronged internationalisation for cross-border arbitration
Jiang Lili – BAC/BIAC - International arbitration in the age of digital intelligence
Wang Chengjie – CIETAC - New Arbitration Law’s impact on maritime arbitration
Li Hu – CMAC - Complex arbitration involving Chinese parties: developments at HKIAC
Joanne Lau & Zhang Xi – HKIAC - Beyond the rulebook: Toolkits of international arbitration
Donna Huang – ICC - Harmonious disaccord: An evolution in commercial mediation
Liu Xiaochun – SCIA - SHIAC’s pursuit of ‘world class’ under new Arbitration Law
Wang Weijun – SHIAC - SIAC rules 7th edition: A pragmatic and professional overhaul
Zhang Cunyuan – SIAC
* The articles are arranged in alphabetical order by the abbreviated name of institutions
Two-pronged internationalisation for cross-border arbitration
Hong Kong is not only a strategic gateway to the Asia-Pacific market, but also a pivotal platform for China’s pursuit of higher-level opening up. Its status as an international centre for finance, shipping and trade remains unassailable.
Supported by a free and open business environment, fair and transparent institutions, market rules closely aligned with international standards, and a unique position at the crossroads of Eastern and Western cultures, Hong Kong continues to attract global commercial actors to conduct trade and investment. This, in turn, provides a strong foundation and sustained momentum for the development of commercial arbitration services.
Meanwhile, Central Asia, as the central hub of the Silk Road Economic Belt, has a strategic location and rapidly expanding potential for co-operation that have made it a key focus of Chinese enterprises’ overseas investment strategies.
China has been Central Asia’s largest trading partner and a major source of investment for many years. Bilateral co-operation has evolved beyond traditional sectors such as energy and mining development, and infrastructure construction, extending across the entire value chain into advanced manufacturing, agritechnology, digital economy integration, and the transition to green energy.
This deepening and diversification of co-operation is opening up significant opportunities for the growth of international commercial arbitration.
As a pillar in the development of Beijing as an international centre for commercial arbitration, the Beijing Arbitration Commission (BAC), encompassing the Beijing International Arbitration Centre and the China (Beijing) Securities and Futures Arbitration Centre, has, since its establishment in 1995, pursued the goal of becoming a world-class arbitration institution.
Following the completion of institutional and governance reforms in 2023, the BAC’s international expansion has been gathering momentum.
To date, the BAC has handled more than 2,500 international cases involving disputes worth about RMB100 billion (USD14.4 billion). Its services extend to 73 countries and regions, with its awards recognised and enforced across all continents.
Building on this foundation, the BAC has identified Central Asia and Hong Kong as two core strategic anchors. By aligning closely with the strong demand for commercial arbitration and the significant market potential in both regions, the commission is developing an international service network that connects southwards to major global centres of trade and commerce, and extends westwards along the Silk Road Economic Belt.
Integrating global resources through Hong Kong presence. In November 2025, the BAC Hong Kong Centre was officially launched. As a highly internationalised city with a dense concentration of financial and commercial activity, Hong Kong has long played a unique role as an institutional connector and resource hub in China’s opening-up framework. It remains a key frontier for Chinese enterprises going global, and for international capital entering the Chinese market.
The BAC positions Hong Kong as a critical anchor for connecting with global resources, drawing on its bridging advantages in the two-way flow of capital and information, as well as its intermediary role between different legal cultures and institutional frameworks.
This enables the provision of end-to-end, comprehensive dispute resolution services. For these reasons, Hong Kong is not only a hub for international dispute resolution resources, but also a key window through which the Chinese mainland’s arbitration system is presented, aligned and understood internationally.
The BAC’s decision to establish its first overseas branch in Hong Kong reflects a strategy of leveraging the complementary strengths of Beijing and Hong Kong.
Its role is defined in three main respects:
- Serving as a legal services outpost for mainland enterprises going global, providing arbitration support for Chinese investment and trade across the Asia–Pacific region;
- Acting as a rules interim for international businesses entering the mainland market, helping foreign parties understand China’s commercial arbitration rules and practice; and
- Drawing on Hong Kong’s position as an international financial centre to integrate global dispute resolution resources, build a multi-jurisdictional service network, and work in co-ordination with institutions such as the International Organisation for Mediation.
From an institutional perspective, locating its first overseas branch in Hong Kong underscores the BAC’s strong emphasis on the communicability of rules and the intelligibility of institutions in its international strategy.
Hong Kong’s intermediary position in terms of legal culture and institutional design enables it to translate rules and bridge systems between mainland arbitration practice and the international dispute resolution framework, thereby offering cross-border parties a wider range of dispute resolution options.
Building a regional service ecosystem through the Central Asia branch. In September 2025, the BAC officially launched its Central Asia branch in Karamay, Xinjiang Uygur Autonomous Region. Karamay was selected for its dual advantages as a hub with strong outward reach to neighbouring markets and close connectivity with the domestic economy.
Externally, Karamay sits at the centre of the northern Xinjiang economic loop and is around a 2.5-hour drive from the China-Kazakhstan border. Its reach extends to neighbouring countries including Russia, Kazakhstan, Mongolia and Pakistan. Supported by active cross-border trade and a well-developed transport network, it has become a key node in the core area of the Silk Road Economic Belt.
Internally, as a major regional transport hub, Karamay is the only intersection point of the belt’s east-west and north-south economic corridors. Establishing the Central Asia branch helps to build an arbitration service network covering Xinjiang and linking it with Central Asia, providing more efficient dispute resolution support for regional economic and trade co-operation.
At the launch ceremony, professionals from institutions including the Astana International Financial Centre Court and its International Arbitration Centre, the International Commercial Arbitration Court at the Chamber of Commerce and Industry of Tajikistan, and the courts of Uzbekistan took part, strengthening the branch’s international connectivity and laying a solid foundation for developing a new hub for international arbitration in the Central Asia region.
Zoning in on the practical needs of arbitration users. The BAC’s two-pronged international strategy, centred on the Hong Kong Centre and the Central Asia branch, represents a significant effort by a Chinese arbitration institution to respond to the core, real-world needs of commercial arbitration users and to explore pathways for institutional opening up.
Advancing in parallel with this geographic expansion is the development of a “1+1+N” arbitration rules framework. Under this model, one set of domestic rules, one set of international rules, and multiple supplementary rules tailored to specialised procedures and sectors operate in co-ordination.
This provides a unified yet flexible institutional foundation for the differentiated roles of the Hong Kong Centre and the Central Asia branch, ensuring effective alignment of rules across regions within the BAC’s international network.
The BAC has released its international arbitration rules in eight languages, directly addressing two major pain points in cross-border dispute resolution: language barriers and differences in the understanding of rules. In doing so, it translates the commission’s extensive experience in managing international cases into tangible, locally accessible services.
These initiatives give concrete expression to the BAC’s core philosophy of “rooted in Beijing while serving the global community”. They not only extend Beijing’s reach as an international arbitration hub and enhance service effectiveness, but also inject sustained momentum into the global profile of Chinese arbitration through practical measures such as rule making and talent exchange.
Looking ahead, as the two strategic anchors work in greater synergy and continue to upgrade their capabilities, the BAC is well positioned to deliver higher-quality and more efficient dispute resolution services to parties worldwide.
International arbitration in the age of digital intelligence
A new wave of technological revolution and industrial reform is upon us, with digital and intelligence technologies forging the path. International arbitration is no exception, with the widespread usage of artificial intelligence (AI), algorithms and cloud computing presenting unprecedented opportunities and challenges.
As the nation’s oldest and most representative permanent international arbitration institution, the China International Economic and Trade Arbitration Commission (CIETAC) has consistently set its sights on the frontier of the development of international arbitration. By exploring the integration of digital intelligence technologies and arbitration practice, CIETAC aims to provide more expedient and high-quality services to domestic and foreign parties, advance the building of an open, collaborative, smart and efficient international arbitration ecosystem, and contribute Chinese wisdom and strength to resolving international disputes in the age of digital intelligence.
Boosting digital and AI applications is essential to tackling the internationalisation and complexity of arbitration. In recent years, many international arbitration institutions have published statistics showcasing a constant climb in the number of international arbitration cases against the backdrop of profound global economic and trade shifts. In the five-year period between 2021 and 2025, CIETAC also witnessed a significant step-up in terms of internationalisation of cases.
First, the number of foreign-related cases and their disputed amounts have risen dramatically. During the five-year period, CIETAC accepted a total of 3,487 foreign-related cases, with an average of 697 cases per year. In 2024, it accepted 758 foreign-related cases, marking an 18% increase over the previous year; the total disputed amount reached RMB81.1 billion (USD11.6 billion), representing 41% of the disputed amount of foreign-related cases across all institutions from the Chinese mainland. In 2025, CIETAC accepted 806 foreign-related cases, marking a 6.3% rise over 2024; the disputed amount reached RMB88.1 billion, an 8.6% increase. During the five-year period, CIETAC accepted 362 cases with both parties from abroad, including 82 in 2025, a 10.8% increase over the previous year.
Meanwhile, the number of countries involved continues to climb. So far, CIETAC cases involve a total of 170 countries and regions around the globe, with 37 added since 2019. Foreign arbitrators also enjoy a high level of participation, with a good variety of procedural languages and governing laws. The five-year period saw 615 instances of foreign arbitrator participation across 566 cases, with 155 instances in 2025 alone, more than doubling that of 2020. During the five-year period, CIETAC accepted 549 cases with English, or both English and Chinese, designated as the procedural language. In addition, the governing laws are also becoming more diversified.
In view of the continuously growing number of arbitration cases and their mounting level of internationalisation and complexity, technical empowerment of international arbitration is as practically important as it is inevitable. For example, the application of the virtual hearing technology facilitates parties, agents and arbitrators from all over the world to participate in the oral hearings.
For another example, with case facts and legal issues ramping up complexity, AI may be leveraged to help the parties and the arbitral tribunals to streamline the facts and documents, search for laws and cases, and thus improving the quality and efficiency of dispute resolution.
Leveraging digital intelligence strengths is a key engine for driving up arbitration quality and efficiency. During the pandemic, virtual hearing technology played a significant role in arbitration procedures. CIETAC’s self-developed smart hearing system also passed the test, and no case had to be put on pause. Now, with rapid strides made in big data, cloud computing and AI fields, digital intelligence explorations in arbitration have begun to bear fruit.
Taking CIETAC as an example, the number of online case filings has consistently grown in the past three years. A total of 12,247 cases were filed online, involving 28,351 individuals from 129 countries and regions, with an average annual growth rate of more than 50%. In the same period, CIETAC held 6,554 online hearings, serving 14,219 individuals from 79 countries and regions. In 2025, 4,755 cases were filed online, about 2.5 times the number of 2022.
To advance the deep integration of “AI + arbitration”, and to ensure the secure, stable and efficient operation of the digital and intelligent arbitration system, CIETAC has established a digital and intelligent supporting system integrating rule innovation, platform construction, institutional development and ethical governance.
In terms of rule innovation, the 2024 edition of CIETAC’s arbitration rules introduces pioneering provisions, such as prioritising electronic service of arbitration documents, granting arbitral tribunals the authority to decide to conduct the oral hearings by remote virtual conference, recognising the validity of arbitrators’ electronic signatures, and the service of electronic versions of arbitral awards. These measures proactively adapt to the evolving demands of the digital and intelligent era.
In terms of platform development, CIETAC has upgraded its ODR platform centred on “multi-device connectivity, bilingual compatibility and full-process coverage”. This enables efficient co-ordination across the entire arbitration process, including online case filings, document exchanges, virtual hearings, as well as administrative and financial services. All participants – parties, arbitrators and arbitration institutions – are empowered by intelligent role-based technologies.
In terms of institutional development, CIETAC’s digital institution construction has entered a new phase of integration and intelligence. The official Chinese and English websites have been completely revamped, guided by the core principles of “digital connectivity, centralised integration and open sharing”. This has systematically established CIETAC’s digital twin, integrating four key functionalities: the digital arbitration court; the digital office space; the digital event hub; and the digital library. Through systematic resource consolidation and enhanced technological empowerment, the efficiency of arbitration services has been significantly elevated.
In terms of ethical governance, CIETAC issued the Guidelines on the Use of Artificial Intelligence Technology in Arbitration (for Trial Implementation), the first guidance of its kind in the Asia-Pacific region. Grounded in the fundamental principles of party autonomy, auxiliary adjudication and good faith, these guidelines promote the safe and prudent application of AI technology, achieving a scientific balance between enhancing arbitration efficiency and managing risks.
The comprehensive integration of digital and intelligent technologies into arbitration procedures will translate into enhanced efficiency, accessibility and credibility, serving as a new driving force for the high-quality development of international arbitration. In September 2025, the 17th session of the Standing Committee of the 14th National People’s Congress of the PRC passed the newly revised Arbitration Law, explicitly stipulating that “arbitration proceedings may be conducted online via information networks, except where the parties expressly disagree”. This marks a crucial step towards regulating the application of digital and intelligent technologies in arbitration.
Strengthening international co-operation is a crucial cornerstone for building a new ecosystem for future arbitration. While digital and intelligent technologies present development opportunities for international arbitration, they also give rise to new challenges against data security, algorithmic transparency, due process and ethical governance. These issues urgently require joint efforts through enhanced international co-operation.
Looking back, strengthening international co-operation has gained broad consensus within the international arbitration community. On a global scale, CIETAC spearheaded the establishment of an arbitration co-operation mechanism centred on the Beijing Joint Declaration of the “Belt and Road” Arbitration Institutions, deepening multilateral exchanges. Advancing regional legal collaboration, CIETAC has built arbitration co-operation platforms among the Association of Southeast Asian Nations (Asean), Latin America, Central Asia, the Middle East, Africa, and the Shanghai Co-operation Organisation.
At the China Arbitration Summit 2025 & China-Latin America International Arbitration Forum, CIETAC formally launched the Joint Action Plan for Promoting the Development of International Arbitration in the Digital Intelligence Era (the Joint Action Plan). To date, it has garnered broad support from the United Nations Commission on International Trade Law and 74 international organisations and dispute resolution institutions.
The four principal goals of the Joint Action Plan are as follows: (1) promoting inclusiveness and narrowing gaps, and thus advancing technical exchanges and capacity building among global arbitration institutions; (2) respecting rights and safeguarding procedures to ensure the independence and integrity of arbitral proceedings; (3) enhancing transparency and promoting fairness by advocating for appropriate disclosure of AI applications; and (4) advancing collaborative governance and building standards by calling on parties to build international consensus and rules.
Moving forward, CIETAC will be guided by the Joint Action Plan to actively foster collaboration among the global arbitration community, the technology sector and academia, pooling international expertise and resources to jointly explore development pathways for intelligent arbitration, enabling AI to become a significant force in promoting the stability of the international economic and trade order, realising fairness and justice, and advancing the rule of law worldwide.
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