Top 10 Hot Topics of Commercial Arbitration in China (2025)

Top Ten Hot Topics 1：Innovation in Maritime Arbitration Mechanisms, Advancement of the New “Mediation + Arbitration” Models and Construction of a New Framework for the Diversified Resolution of Maritime Disputes

Reason for Selection:

In response to the increasingly complex foreign-related elements and diversified forms of maritime disputes, multiple coastal and river-port cities across China have actively promoted innovations in arbitration mechanisms. Tailored to local conditions, these regions have introduced a series of maritime dispute resolution models that deeply integrate “mediation + arbitration”, thereby providing new, rule-of-law-based pathways for the diversified resolution of maritime disputes in China.

On 28 March 2025, the Nanjing Arbitration Commission and the Nanjing Maritime Safety Administration signed the first cooperation framework agreement nationwide on the maritime “mediation + arbitration” mechanism. This agreement aims to further improve the diversified resolution mechanism for maritime and admiralty disputes and to give full play to the respective professional strengths of maritime authorities and arbitration institutions. With respect to the implementation of specific regulatory frameworks, on 19 August 2025, the Zhoushan Maritime Safety Administration and the China Maritime Arbitration Commission (Zhejiang) Pilot Free Trade Zone Arbitration Center formally signed a maritime “mediation + arbitration” cooperation agreement in Zhoushan. At the same time, they jointly released their first cooperative outcome—the Guidelines on the Interface between Maritime Mediation and CMAC Arbitration, namely the Mediation–Arbitration Interface Guidelines. This marks the first set of such guidelines nationwide jointly formulated by a maritime authority and a specialized maritime arbitration institution.

On 19 August 2025, the China Maritime Arbitration Commission (Zhejiang) Pilot Free Trade Zone Arbitration Center officially released the Guidelines on the Interface between Maritime “Mediation + Arbitration”. On the same day, together with the Zhoushan Maritime Safety Administration, it held a signing and promotional event for the “Mediation + Arbitration” cooperation agreement, along with a themed seminar on “the diversified resolution of maritime traffic accident disputes”.

On 22 October 2025, the Tianjin Arbitration Commission and the Tianjin Maritime Safety Administration jointly established the first mobile arbitration tribunal in China, located within a maritime administrative authority—the “Jinhai Fatong” Mobile Arbitration Tribunal. The tribunal was officially unveiled and commenced operations at the Tianjin Xingang Maritime Safety Administration.

On 10 October 2025, multiple authorities—including the Xiamen Area of China (Fujian) Pilot Free Trade Zone Administrative Committee, Xiamen Municipal Bureau of Justice, Xiamen Maritime Safety Administration, Xiamen Maritime Court, and Xiamen Intermediate People’s Court—jointly issued the Measures Supporting Institutional Innovation in Foreign-Related Commercial and Maritime Arbitration in the Xiamen Area of China (Fujian) Pilot Free Trade Zone. These measures comprehensively established a support framework for maritime arbitration innovation in terms of institutional coordination, judicial safeguards, and ancillary services. Meanwhile, the Maritime Silk Road Chamber of International Arbitration Promotion released the Maritime Silk Road Maritime Disputes Ad Hoc Arbitration Rules.

Shanghai has also provided new ideas for dispute resolution in the maritime sector through innovations in arbitration mechanisms by “introducing maritime mediation into arbitral confirmation”, with successful case outcomes. In April 2025, the Shanghai Arbitration Court of International Shipping, under the Shanghai Arbitration Commission, issued an arbitral confirmation of a mediated settlement in a vessel collision compensation dispute. This marked the successful implementation of a case in which “maritime mediation” was effectively incorporated into “maritime arbitration”. This case provided a “Shanghai model” for building a distinctive “maritime mediation + maritime arbitration” mechanism and contributed to the development of China as an international commercial arbitration center.

In addition, Shanghai has actively advanced a new dispute resolution model combining “maritime mediation + ad hoc arbitration.” In October 2025, in a dispute over outstanding payments involving a shipping company, the Pudong New Area Bureau of Justice and the Shanghai Maritime Safety Administration jointly explored resolving the dispute through a mediation–arbitration integrated approach. During the mediation process, and subject to the parties’ mutual consent, it was agreed in advance that the settlement reached would be given legally enforceable effect through an ad hoc arbitral award. This arrangement ultimately facilitated the efficient conclusion of a settlement agreement between the parties.

Through institutional coordination, rule alignment, and service decentralization, these innovative practices in maritime arbitration have effectively integrated the professional expertise of administrative mediation with the enforceability of arbitral awards. This has significantly enhanced both the efficiency and enforceability of maritime dispute resolution, providing important support for China’s efforts to build an international maritime arbitration center and to optimize the rule-of-law-based business environment in the shipping sector.

Top Ten Hot Topics 2：Enhanced Arbitration Cooperation Between the Chinese Mainland and the Hong Kong and Macao SARs Through Rule Coordination, Achieving Practical Breakthroughs

Reason for Selection:

Through coordinated development of arbitration rules, the Chinese mainland and the Hong Kong and Macao SARs have actively explored a pragmatic and innovative path of inter-regional arbitration cooperation with Chinese characteristics. Breakthrough progress has been achieved in areas such as consumer dispute resolution, evidence collection, mutual recognition of arbitral awards, and rule harmonization, marking a new stage in which regional arbitration cooperation has evolved from institutional linkage toward rule convergence.

In terms of innovation in arbitration mechanisms, the Macao SAR and Shenzhen, for the first time, successfully resolved a cross-border consumer dispute by relying on an inter-regional arbitration mechanism, making this case a landmark event in arbitration cooperation between the two jurisdictions. In this dispute, a Chinese mainland consumer became involved in a dispute arising from the purchase of cross-border goods of a Macao brand. The case was arbitrated by the Macao Consumer Mediation and Arbitration Center, with the Shenzhen Consumer Council providing online arbitration support to the consumer. This practice marked the first instance in which Shenzhen and Macao conducted cross-regional consumer arbitration through remote video technology, offering a new resolution pathway for cross-border consumer disputes in the Greater Bay Area.

With respect to evidence collection, on 27 June 2025, the Zhuhai Court of International Arbitration (Hengqin International Arbitration Center) obtained an investigation order from the Zhuhai Intermediate People’s Court in China’s first commercial arbitration case involving Macao. (For details, see Chinese Courts Improve the Coordination Between Arbitration and Litigation to Support the High-Quality Development of Arbitration.)

In terms of the mutual recognition and enforcement of cross-border arbitral awards, two landmark cases in 2025 jointly propelled breakthroughs in arbitration practice between the Chinese mainland and the Hong Kong and Macao SARs: First, after the China International Economic and Trade Arbitration Commission Hong Kong Arbitration Center rendered an arbitral award in a dispute arising from a Package Agreement between a Samoan enterprise and a Chinese mainland entity, the Suzhou Intermediate People’s Court recognized and enforced the award by ruling (2024) Su 05 Recognizing Hong Kong Award No. 3. Second, the Shenzhen Intermediate People’s Court concluded the first-ever “Hong Kong-invested enterprise, Hong Kong arbitration” case nationwide, granting recognition to an arbitral award rendered by the South China (Hong Kong) International Arbitration Court upon application by a Hong Kong-invested enterprise in Shenzhen. The amount in dispute exceeded RMB 60 million. This case represents the first judicial application following the effectiveness of the Reply of the Supreme People’s Court on the Validity of Agreements Choosing Hong Kong or Macao Law as the Governing Law of Contracts or Designating Hong Kong or Macao as the Place of Arbitration for Hong Kong- or Macao-Invested Enterprises Registered in the Mainland of the Guangdong-Hong Kong-Macao Greater Bay Area (Fa Shi [2025] No. 3).

In terms of arbitration rule innovation, on 28 April 2025, the Zhuhai Court of International Arbitration (Hengqin International Arbitration Center) officially released the Hengqin-Macao Arbitration Rules of the Arbitration Cooperation Platform, together withthe supporting Rules of Evidence. This represents a milestone achievement in the coordination of arbitration rules between the two jurisdictions following the establishment of the Hengqin-Macao Arbitration Cooperation Platform in 2021. The new rules deeply integrate the legal characteristics of both the Chinese mainland and Macao, fully drawing on the strengths and experience of the Macao Arbitration Law and the Macao Civil Procedure Code. They are particularly designed to serve Macao and Macao-invested commercial entities, facilitating rule convergence and institutional linkage between Macao and the Chinese mainland. The promulgation of the new rules marks the transition of Hengqin-Macao arbitration cooperation from joint platform development to shared rules, providing more inclusive solutions for cross-border civil and commercial disputes and contributing to the optimization of the rule-of-law-based business environment in the cooperation zone.

In addition, on 30 December 2025, the Guangdong Provincial Department of Justice, together with the Department of Justice of the Hong Kong SAR Government and the Secretary for Administration and Justice of the Macao SAR Government, officially released the Panel of Arbitrators of the Guangdong–Hong Kong–Macao Greater Bay Area, which includes 143 professional arbitrators in its first cohort. This initiative aims to promote rule coordination, institutional linkage, and talent connectivity among Guangdong, Hong Kong, and Macao, thereby improving the diversified dispute resolution mechanisms in the Greater Bay Area.

Cooperation in the field of arbitration between the Chinese mainland and the Hong Kong and Macao SARs covers both everyday consumer disputes and complex commercial disputes. It encompasses full-chain innovations and practices, including procedural support, such as investigation orders, substantive rule coordination, such as specialized arbitration rules, and cross-border recognition and enforcement of arbitral awards. These developments have strongly promoted the optimization of rule convergence and dispute resolution mechanisms.

Top Ten Hot Topics 3：Mainland Arbitration Institutions Continue to Deepen Rule Innovation, Advance Arbitration in the Securities and Futures Sector, Expand Arbitration Practice and Enhance the Effectiveness of Arbitration

Reason for Selection:

Chinese mainland arbitration institutions have focused on enhancing practical effectiveness and pursued rule innovation on multiple fronts. By actively advancing arbitration in the securities and futures sector and continuously expanding arbitration practice, these institutions have attracted widespread public attention.

At the level of arbitration in the securities and futures sector, on 26 December 2025, the Shanghai Arbitration Commission issued the Shanghai Arbitration Commission Securities and Futures Arbitration Rules. The Rules are guided by the principles of “professionalism, efficiency, flexibility, and cost-effectiveness”. Through pragmatic provisions, they promote the development of the China (Shanghai) Securities and Futures Arbitration Center and enhance the service capacity of financial arbitration in Shanghai. Previously, the institution released the Recommended List of Arbitrators of the China (Shanghai) Securities and Futures Arbitration Center (Trial) in June 2025, held a themed training session on “Arbitration Practice in Securities and Futures Dispute Resolution” on 31 October, and on 24 November jointly held a signing and inauguration ceremony for the mediation–arbitration linkage mechanism for securities and futures disputes together with the China Securities Investor Services Center, thereby promoting the “mediation–arbitration linkage” dispute resolution pathway. These initiatives received extensive coverage from media outlets such as Xinhua News Agency and China National Radio, generating broad social impact.

In addition, on 25 September 2025, the Beijing Arbitration Commission / Beijing International Arbitration Center initiated the establishment of the China (Beijing) Securities and Futures Arbitration Center and released the Securities and Futures Arbitration Rules along with ten classic arbitration cases.

At the level of rule innovation, effective 1 January 2025, the Guangzhou Arbitration Commission adjusted its arbitration fees from administrative and institutional charges to market-based service fees and promulgated new fee standards. At the same time, it introduced fee incentive measures for “mediation–arbitration linkage”, under which arbitration fees are reduced by 50% where a settlement agreement has been reached prior to arbitration, and the parties request the arbitral tribunal to issue an award or mediation statement in accordance with the settlement.

In February 2025, the Dalian Arbitration Commission / Dalian International Arbitration Court formulated and introduced 20 measures to support and safeguard the high-quality development of the private economy, providing arbitration-based guiding solutions to optimize the business environment for private enterprises and to better leverage the rule of law in strengthening foundations, stabilizing expectations, and benefiting long-term development.

In March 2025, the Shanghai Arbitration Commission amended the Shanghai Arbitration Commission Arbitration Rules, which had been in force since 1 July 2022, by adding Article 63, introducing an early dismissal procedure and specifying in detail the grounds for application, scope of application, time limits, and forms of decision, resulting in the Shanghai Arbitration Commission Arbitration Rules (March 2025 Revision).

On 31 March 2025, the new Arbitration Rules of the South China (Hong Kong) International Arbitration Court came into effect. These rules are based on the UNCITRAL Arbitration Rules (2021 Edition) and incorporate the latest developments in international arbitration rules.

On 7 April 2025, the Beijing Arbitration Commission / Beijing International Arbitration Center adopted the Mediation–Arbitration Expedited Rules, which came into effect on 15 April 2025.

In June 2025, the Shanghai International Economic and Trade Arbitration Commission (Shanghai International Arbitration Center) formulated and issued the Guidelines (Trial) on Enhancing Procedural Efficiency through Early Determinations, aimed at assisting parties and arbitral tribunals in utilizing the early determination mechanism to improve arbitration efficiency. The Guidelines comprise nine articles and enrich the arbitral tribunal’s procedural toolbox by allowing the dismissal of claims or defenses that are manifestly without legal merit or the issuance of preliminary determinations, thereby avoiding unnecessary delay and expense and aligning with international arbitration practice and the UNCITRAL Notes on Preliminary Dismissal and Preliminary Determinations.

On 21 October 2025, the Wuhan Arbitration Commission issued the Adjudication Guidelines (Trial) for Disputes Arising from Construction Project Contracts. The issuance of these Guidelines is of significant importance, under the current economic circumstances, for standardizing the adjudication of arbitration cases involving construction project contracts and for the proper resolution of related disputes.

On 29 October 2025, the Beijing Arbitration Commission / Beijing International Arbitration Center / China (Beijing) Securities and Futures Arbitration Center adopted the Domestic Arbitration Rules and the International Arbitration Rules, marking the formal establishment of a “1+1+N” rules framework, one set of domestic rules, one set of international rules, and multiple specialized rules.

In practice, on 22 January 2025, the first case involving “professional mediation + arbitral confirmation (mediation–arbitration linkage mechanism)” jointly handled by the Guangzhou Financial Dispute People’s Mediation Committee and the Guangzhou Arbitration Commission was successfully concluded. The case was efficiently concluded within three working days, saving the parties half of the dispute resolution costs and fully demonstrating the advantages of the “mediation–arbitration linkage” mechanism in terms of efficiency, flexibility, and cost-effectiveness.

In October 2025, a technology service contract dispute accepted by the Jiaxing Arbitration Commission, in which both parties were located in Shanghai, was successfully completed with a cross-regional arbitral hearing. The Shanghai Arbitration Commission provided professional hearing facilities and venue support for the case. This cooperation fully demonstrated the advantages of coordinated development among arbitration institutions in the Yangtze River Delta, ensuring procedural regularity while enhancing service efficiency, and constituting an innovative arbitration practice aligned with national development strategies.

In October 2025, following the issuance by the China International Economic and Trade Arbitration Commission (CIETAC) of the Procedures for the Administration of Cases under the UNCITRAL Arbitration Rules (the Administration Procedures), the first international commercial arbitration case administered under those Procedures was successfully concluded, marking a landmark event in the enhancement and upgrading of the internationalized services provided by China’s arbitration institutions.

In this case, a Chinese manufacturing enterprise and a European trading company became involved in a dispute arising from international trade, concerning the quality of goods and payment obligations. The parties agreed in their contract to apply the UNCITRAL Arbitration Rules and designated CIETAC as the administering institution. Pursuant to the Administration Procedures, CIETAC efficiently completed key procedural tasks, including the constitution of the arbitral tribunal—composed of arbitrators from China, Europe, and Southeast Asia—the multilingual transmission of documents, and the organization of online cross-border hearings. CIETAC innovatively adopted a model combining “core procedures under the UNCITRAL Arbitration Rules + CIETAC’s localized services”, strictly adhering to internationally accepted rules while enhancing efficiency through supporting measures such as electronic evidence preservation and clarification of key issues in dispute. The final award was accepted by both parties, providing a clear operational paradigm for similar cases in the future. The conclusion of this “first case” signifies CIETAC’s successful achievement of deep integration between mainstream international arbitration rules and its localized service capabilities.

The above series of practical innovations and rule enhancements have not only strengthened the professional foundations of China’s arbitration system, but also highlighted a development orientation characterized by “localized adaptation combined with international alignment,” thereby promoting improvements in the quality and effectiveness of arbitration services. Looking ahead, as mechanism coordination and rule innovation continue to deepen, China’s arbitration institutions will further enhance their role in serving the real economy and supporting high-level opening-up, providing higher-quality dispute resolution solutions for various market participants and contributing to the advancement of China’s international commercial arbitration centers to a new level.

Top Ten Hot Topics 4：Mainland Arbitration Institutions’ Arbitral Awards Continue to Be Recognized and Enforced Overseas, with Growing International Credibility and Influence

Reason for Selection:

In 2025, commercial arbitral awards rendered by multiple  Chinese mainland arbitration institutions continued to be recognized and enforced in a number of foreign jurisdictions, achieving new breakthroughs.

Some representative cases are listed below: On 5 February 2025, the United States District Court for the Northern District of Texas recognized and enforced an arbitral award rendered by the Shenzhen Court of International Arbitration. In April, the Central Jakarta District Court of Indonesia recognized and enforced an arbitral award rendered by the China International Economic and Trade Arbitration Commission (CIETAC). On 8 April, the United States District Court for the Southern District of Florida recognized and enforced an arbitral award rendered by the Shanghai International Economic and Trade Arbitration Commission (Shanghai International Arbitration Center). In May, the United States District Court for the Central District of California recognized and enforced an arbitral award rendered by the Shenzhen Court of International Arbitration. Also in May, a Malaysian court recognized and enforced an arbitral award rendered by the Hainan International Arbitration Court. On 10 July, the United States Court of Appeals for the Ninth Circuit rendered a judgment affirming the decision of the United States District Court for the Northern District of California to recognize and enforce an arbitral award rendered by the Chengdu Arbitration Commission. On 31 July, the Appeal Division of the Saudi Enforcement Court ruled to enforce an arbitral award rendered by CIETAC. On 20 October, the Eastern High Court of Denmark rendered a judgment (25th inst. no. B-280-25) upholding the first-instance judgment of the country’s Maritime and Commercial High Court and Bankruptcy Court, recognizing an arbitral award rendered by the Shanghai International Economic and Trade Arbitration Commission, and, based on the facts as determined in the said final and binding judgment, ordering the respondent against whom enforcement was sought to be declared bankrupt.

The above arbitral awards covered a wide range of areas, including commercial contract disputes, equity transfers, cross-border investment, and data resources, involved substantial amounts in dispute, and had broad commercial impact. The recognition and enforcement of Chinese arbitral awards by courts at the places of enforcement have further enhanced the international influence of China’s arbitration institutions and reflect new progress in the development of China’s foreign-related rule of law. The continued recognition and enforcement of arbitral awards rendered by Chinese mainland arbitration institutions by foreign courts have further enriched the practical experience of obtaining recognition and enforcement of such awards overseas, demonstrating that the credibility and professionalism of Mainland arbitration institutions are gaining increasing international recognition.

Top Ten Hot Topics 5：Multiple Regions in China Take the Lead in Systematically Advancing Innovation and Practice in  Ad Hoc Arbitration

Reason for Selection:

Under the dual impetus of legislative breakthroughs and practical exploration, China’s ad hoc arbitration system experienced a pivotal year of rapid development and effective implementation in 2025. Through multidimensional measures including judicial support, rule innovation, and service guarantee, various localities actively promoted the transition of ad hoc arbitration from institutional design to concrete practice. These efforts have provided strong support for building a market-oriented, rule-of-law-based, and internationalized business environment, while also accumulating valuable “local models” for the comprehensive implementation of the new Arbitration Law.

At the level of local legislation, on 22 April 2025, the Shanghai Municipal Bureau of Justice issued the revised Measures of Shanghai Municipality for Promoting Ad Hoc Arbitration in Foreign-Related Commercial and Maritime Affairs, which came into effect on 1 June 2025.

At the level of arbitration rules, Chinese arbitration institutions formulated a series of service rules for ad hoc arbitration. On 28 August 2025, the Beiwaitan Ad Hoc Arbitration Service Guidelines (Trial) and the Beiwaitan Ad Hoc Arbitration Service Handbook were officially released. On 16 July 2025, the Nansha International Arbitration Center of the Guangzhou Arbitration Commission and the People’s Court of Nansha District, Guangzhou jointly issued the Ad Hoc Arbitration Service Rules of the Nansha International Arbitration Center, which represent the first specialized rules and supporting measures in the Guangdong–Hong Kong–Macao Greater Bay Area to systematically regulate auxiliary services for ad hoc arbitration. On 15 September 2025, the China Maritime Arbitration Commission and the Guangdong Council for the Promotion of International Trade jointly released the China (Guangdong) Pilot Free Trade Zone Ad Hoc Arbitration Guidelines. On 26 September 2025, the Operational Guidelines for Ad Hoc Arbitration of the Shanghai Arbitration Association were officially issued. Also on 26 September 2025, the Ad Hoc Arbitration Service Rules of the Qingdao Arbitration Commission / Qingdao International Arbitration Center were adopted, filling a regional institutional gap in the ad hoc arbitration framework. On 14 October 2025, the China Maritime Arbitration Commission, together with the Yunnan Council for the Promotion of International Trade, the Yunnan Law Society, and the Yunnan Lawyers Association, jointly released the China (Yunnan) Pilot Free Trade Zone Ad Hoc Arbitration Guidelines.

At the practical level, on 27 February 2025, the first foreign-related ad hoc arbitration case in the Hainan Free Trade Port was heard in Danzhou Yangpu. During the stage of property preservation, the Haikou Maritime Court proactively guided the parties to change the originally agreed arbitration in Singapore to ad hoc arbitration conducted in Hainan, successfully achieving the “local resolution” of a cross-border dispute. Through a model of judicial–arbitration coordination, the judicial system actively promoted the use of ad hoc arbitration measures, fully demonstrating its affirmative support for the ad hoc arbitration system.

On 2 July 2025, Guangdong Province successfully concluded an ad hoc arbitration case with guidance and assistance provided by an arbitration institution. After the dispute arose, the parties entered into an ad hoc arbitration agreement, expressly agreeing to resolve the dispute through ad hoc arbitration, applying the Hengqin Pilot Free Trade Zone Ad Hoc Arbitration Rules, designating the Hengqin Guangdong–Macao In-depth Cooperation Zone as the seat of arbitration, and appointing the Zhuhai International Arbitration Court (Hengqin International Arbitration Center) to provide procedural assistance and secretarial services. From the commencement of the arbitration proceedings to the conclusion of the case, the entire process took only nine days, fully demonstrating the efficiency, professionalism, and cost-effectiveness of ad hoc arbitration.

On 22 December 2025, following the adoption of the new Arbitration Law, the first ad hoc arbitration case nationwide involving a designated service institution was concluded in the China (Shanghai) Pilot Free Trade Zone Lin-gang Special Area. In this case, both the applicant and the respondent were shipping enterprises registered in the Shanghai Pilot Free Trade Zone and the Lin-gang Special Area, and agreed to apply the Ad Hoc Arbitration Rules of the Shanghai Arbitration Association. On 16 December 2025, the parties jointly designated the Shanghai Headquarters of the China Maritime Arbitration Commission as the service institution and selected the arbitrator from the recommended panel of ad hoc arbitrators of the Shanghai Arbitration Association. On 22 December 2025, the arbitral tribunal rendered the ad hoc arbitral award. On the same day, the respondent fulfilled its payment obligation to the applicant in accordance with the award, bringing the dispute to a successful resolution. The entire process—from the constitution of the tribunal, to the hearing, to the rendering and enforcement of the award—took only seven days. This case not only set a new domestic efficiency benchmark for ad hoc arbitration procedures, but also innovatively developed a replicable and scalable “Lin-gang model” of ad hoc arbitration, providing valuable practical experience for the comprehensive implementation of China’s ad hoc arbitration system.

Overall, the practice of ad hoc arbitration in China has formed an integrated development pattern characterized by “judicial guidance and support, systematic rule-building, and innovation in service models.” From Hainan’s “repatriation of disputes”, to Shanghai’s “efficiency benchmark”, and further to the “rule alignment” achieved in the Guangdong–Hong Kong–Macao Greater Bay Area, these explorations not only respond to international commercial parties’ demand for efficient, flexible, and low-cost dispute resolution mechanisms, but also signify China’s accelerated integration into internationally accepted arbitration practices, laying a solid practical foundation for building an international commercial arbitration center with global competitiveness.

Top Ten Hot Topics 6：China’s Arbitration Institutions Take Multiple Measures to Deepen International Cooperation, Cultivate Foreign-Related Arbitration Talent, and Expand Global Influence

Reason for Selection:

Through multi-dimensional and high-level international exchanges and cooperation, China’s arbitration institutions have made steady and substantive progress on the path toward internationalization, significantly enhancing their participation in and influence within the global dispute resolution system.

China’s arbitration institutions have actively hosted high-level international forums. On 25 April 2025, the China International Economic and Trade Arbitration Commission (CIETAC) and the People’s Government of the Xinjiang Uygur Autonomous Region jointly hosted the “Shanghai Cooperation Organization Arbitration Law Forum” in Urumqi. As China served as the rotating chair of the Shanghai Cooperation Organization for 2024–2025, this forum constituted one of the major activities during China’s chairmanship. China Arbitration Week 2025 was grandly launched worldwide from 15 to 21 September 2025. In practice, the event cycle extended from August through late October, during which more than 100 thematic events were held across multiple countries and regions around the world. Key events included the “2025 China Arbitration Summit Forum and China–Latin America International Arbitration Forum” and “BRICS Arbitration: BRICS Strength Contributing to Global Governance and Shared Development”, among others.

China’s arbitration institutions have actively participated in international affairs, deepened cooperation with international organizations, and engaged in international standard-setting processes. From 3 to 7 February 2025, the Shanghai International Economic and Trade Arbitration Commission (Shanghai International Arbitration Center), in its capacity as an observer to UNCITRAL Working Group II (Dispute Settlement), attended the 81st session of the Working Group at the United Nations Headquarters in New York. From 24 to 28 March 2025, the Beijing Arbitration Commission / Beijing International Arbitration Center, as an observer to UNCITRAL Working Group IV (Electronic Commerce), participated in the 68th session of the Working Group at the United Nations Headquarters in New York, during which the Default Rules on Data Provision Contracts were reviewed.

On 8 September 2025, a total of ten representative dispute resolution institutions from BRICS member states and partner countries—including the China International Economic and Trade Arbitration Commission, the China Maritime Arbitration Commission, the International Commercial Dispute Prevention And Settlement Organization, the AALCO Hong Kong Regional Arbitration Centre, the Cairo Regional Centre for International Commercial Arbitration, the Ciesp/Fiesp Chamber of Conciliation, Mediation and Arbitration, the International Commercial Arbitration Court at the Chamber of Commerce and Industry of the Russian Federation, the Maritime Arbitration Commission at the Chamber of Commerce and Industry of the Russian Federation, the Asian Institute of Alternative Dispute Resolution, and the CCPIT Mediation Center—jointly issued the Joint Initiative on Strengthening Legal Services Cooperation among BRICS Countries and Jointly Promoting the Sound Development of the World Economy.

From 3 to 5 November 2025, the Shanghai International Economic and Trade Arbitration Commission (Shanghai International Arbitration Center) and the International Institute for the Unification of Private Law (UNIDROIT) jointly hosted the first “2025 International Moot Arbitration Competition on the UNIDROIT Principles of International Commercial Contracts” (the “UPICC Moot”). This was the world’s first international moot arbitration competition to take the UNIDROIT Principles of International Commercial Contracts (UPICC) as both its theme and core applicable law. The competition attracted 38 teams from home and abroad. Among them, 26 teams from 10 countries and regions, including China, Hong Kong (China), Turkey, Iran, Pakistan, and the Republic of Korea, with more than 200 students and coaches, participated in the on-site rounds in Shanghai, while over 70 Chinese and foreign arbitrators served as judges.

In addition to the above inaugural moot arbitration competition, China’s arbitration institutions have continuously organized a series of moot arbitration competitions to cultivate foreign-related arbitration talent and enhance practical skills. On 28 March 2025, the 15th Moot Shanghai International Commercial Arbitration Invitational, jointly hosted by the Shanghai International Economic and Trade Arbitration Commission (Shanghai International Arbitration Center) and the Shanghai Arbitration Commission, concluded successfully. In June 2025, the Shanghai Arbitration Commission, as a co-organizer, participated in hosting the Fifth Mainland–Hong Kong–Macao University Student Moot Court (Arbitration Tribunal) Competition. In July 2025, the Shenzhen Court of International Arbitration hosted the 2025 Foreign Direct Investment Moot Arbitration Competition (FDI Moot Shenzhen). From 28 November to 5 December 2025, the 23rd “CIETAC Cup” International Commercial Arbitration Moot Court Competition, hosted by CIETAC, was successfully held. From 18 to 20 December 2025, the Wuhan Arbitration Commission successfully hosted the Fifth “Wuhan Arbitration Cup” Moot Arbitration Competition.

Through the above activities hosted or participated in by China’s arbitration institutions, characterized by a high degree of internationalization, forward-looking topic design, and in-depth practical exchange, the vigorous development and open posture of China’s arbitration sector were effectively demonstrated. These efforts have made important contributions to deepening international arbitration cooperation and jointly shaping the future of dispute resolution. At the same time, through these activities, China’s arbitration institutions have achieved a transition from “institutional participation” to “rule dissemination and practical transformation”, accelerating their evolution within the global dispute resolution system from “participants” to “contributors” and “drivers”. This transformation has enhanced China’s international discourse power in the rule of law and provided strong support for the development of foreign-related arbitration.

Top Ten Hot Topics 7：The New Arbitration Law Consolidates Domestic Experience and Aligns with International Standards, Marking a New Stage of Innovative Development in China’s Arbitration Legal Framework

Reason for Selection:

On 12 September 2025, the 17th Session of the Standing Committee of the 14th National People’s Congress voted to adopt the newly revised Arbitration Law, which will enter into force on 1 March 2026. The new Arbitration Law is of great significance for strengthening the development of foreign-related rule of law, enhancing the credibility and international competitiveness of China’s arbitration system, and better serving high-quality development and high-level opening-up.

The new Arbitration Law comprises eight chapters and ninety-six articles, introducing numerous innovations in areas such as alignment with internationally accepted rules, strengthening institutional coordination, and regulating the performance of arbitrators’ duties. For example, drawing extensively on international experience, the revision further enhances judicial support for arbitration, including in areas such as interim measures and evidence collection, by strengthening the role of the people’s courts and other relevant authorities. As another example, based on a comprehensive review of domestic practice, the revision further standardizes the qualifications for arbitrators, broadens the channels for arbitrator appointment, introduces enhanced disclosure obligations for arbitrators, and improves the procedures for the selection and appointment of arbitrators, thereby laying an institutional foundation for ensuring the fair and orderly conduct of arbitral proceedings and for building a high-quality corps of arbitrators.

The year 2025 marks both the 30th anniversary of the promulgation and implementation of China’s Arbitration Law and a critical milestone in the high-quality development of commercial arbitration in China. The promulgation of the new Arbitration Law signifies a transition of China’s arbitration system from a phase of incremental and imitative development to a new stage of integrated innovation, characterized by alignment with international standards and the strengthening of foreign-related rule of law. The new Arbitration Law will provide institutional safeguards for resolving economic disputes through arbitration, fostering a sound business environment, addressing prominent issues in arbitration practice, enhancing the credibility of arbitration, strengthening the foreign-related rule of law, cultivating internationally first-class arbitration institutions, and establishing China as a preferred seat for international commercial arbitration.

Top Ten Hot Topics 8：Arbitration Empowers Strategic Emerging Industries, builds a Legal Services Coordination Mechanism Platform to Safeguard the Development of the Low-Altitude Economy

Reason for Selection:

Promoting the sound development of the low-altitude economy constitutes a major strategic decision made by the Central Committee of the Communist Party of China with a view to overall coordination and long-term planning. The Recommendations on Formulating the Fifteenth Five-Year Plan for National Economic and Social Development, adopted at the Fourth Plenary Session of the 20th CPC Central Committee, clearly state that efforts should be accelerated to develop strategic emerging industrial clusters, including the low-altitude economy, and identify this as an important component in fostering and expanding emerging industries and future industries.

On 26 December 2025, the National Development and Reform Commission (NDRC) officially released the Statistical Classification of the Low-Altitude Economy and Its Core Industries (Trial) (Fa Gai Low-Altitude [2025] No. 1676). This document aims to implement the major decisions and arrangements of the CPC Central Committee and the State Council concerning the development of the low-altitude economy, define the statistical scope of the low-altitude economy and its core industries, and measure the scale, growth rate, and structural composition of the low-altitude economy, so as to meet the statistical needs of Party committees, governments at all levels, and various sectors of society.

While the industry is experiencing rapid growth, the cross-sectoral nature of the low-altitude economy has also given rise to a range of complex challenges. Commercial arbitration, by virtue of its professionalism, flexibility, confidentiality, and advantages in cross-border enforcement, has become an important pillar for safeguarding the security baseline of the low-altitude economy and supporting its high-quality development.

On 24 July 2025, the China Law Society Aviation Law Research Association initiated the establishment of, and arbitration institutions including the Shanghai International Economic and Trade Arbitration Commission (Shanghai International Arbitration Center) and the Zhuhai Arbitration Commission (Zhuhai International Arbitration Court) jointly participated in the construction of, “the China Low-Altitude Economy Legal Services Coordination Mechanism Platform”, which was officially launched. As of November 2025, 77 institutions had applied to join the platform. Its core objective is to build a full-chain collaborative system covering rule-of-law research, rule-making, dispute resolution, and talent cultivation in the low-altitude economy, and to create a cross-disciplinary and cross-institutional research and service network.

On 18 November 2025, a Symposium on Legal Services for the Low-Altitude Economy, hosted by “the China Low-Altitude Economy Legal Services Coordination Mechanism Platform” and organized by the Shanghai International Economic and Trade Arbitration Commission (Shanghai International Arbitration Center), was convened in Shanghai. The symposium brought together representative stakeholders across the entire chain, including legislative research, rule formulation, industry regulation, professional services, enterprise practice, and dispute resolution. In-depth discussions were held on key issues such as legislative needs for the low-altitude economy, development of model contract texts, selection of representative cases, compilation of legal reference materials, establishment of legal service evaluation mechanisms, improvement of talent training systems, and expansion of the platform, resulting in a number of pragmatic consensuses and providing important support for the sound and orderly development of the low-altitude economy on a rule-of-law basis.

On 26 November 2025, the Zhuhai International Arbitration Court, together with eleven other institutions, jointly hosted “the Second Zhuhai General Aviation Legal Salon” in Guangdong–Macao In-depth Cooperation Zone in Hengqin. Nearly 100 experts and industry professionals participated in the event. The discussions focused on topics such as the construction of a tiered and categorized legislative framework for the low-altitude economy and diversified dispute resolution mechanisms combining “mediation + arbitration,” offering systematic solutions with both theoretical depth and practical value for the high-quality development of the low-altitude economy in the Guangdong–Hong Kong–Macao Greater Bay Area.

In addition, on 21 June 2025, the Shenyang Arbitration Commission hosted the Seminar on “Aviation Arbitration + Legal Risk Prevention in the Low-Altitude Economy Industry,” bringing together experts and practitioners from arbitration institutions, higher education institutions, legal practice community, and the aviation industry to jointly explore pathways for legal risk prevention in the low-altitude economy industry and the specialization of aviation arbitration.

Earlier, in 2024, the Guangzhou Arbitration Commission promulgated the Arbitration Rules for Disputes Arising from the Low-Altitude Economy. These Rules represent not only the first of their kind in China, but also the first specialized arbitration rules worldwide dedicated to disputes arising from the low-altitude economy, carrying milestone significance.

With a forward-looking vision and a systematic approach, China’s arbitration community is actively building a corresponding legal services and dispute resolution coordination framework to serve the national strategic decision to accelerate the development of strategic emerging industrial clusters such as the low-altitude economy. Through the power of the rule of law, these efforts are safeguarding the safe and sound development of this new quality productive forces.

Top Ten Hot Topics 9：Admitting Foreign Arbitration Institutions into Pilot Free Trade Zones: The Coordinated Evolution of Top-Level Design and Local Practice Marks a New Stage in the Opening-Up of China’s Arbitration Market

Reason for Selection:

With respect to the opening-up of arbitration systems in Pilot Free Trade Zones, China has established a complete and well-defined institutional framework characterized by central-level top-down design, authorization under the new law, and implementation through local detailed rules, marking a new stage of institutionalized and standardized opening-up of China’s arbitration market.

On 21 April 2025, the CPC Central Committee and the State Council issued the Opinions on Implementing the Strategy for Upgrading Pilot Free Trade Zones. The Opinions provide that well-known foreign arbitration institutions may be permitted to establish business offices in eligible Pilot Free Trade Zones. From the perspective of national strategy, the Opinions set out the policy direction for opening up arbitration.

Article 86 of the new Arbitration Law, adopted on 12 September 2025, provides that: “Foreign arbitration institutions may be permitted to establish business offices, in accordance with relevant state regulations, in Pilot Free Trade Zones approved by the State Council, the Hainan Free Trade Port, and other designated areas, and to conduct foreign-related arbitration activities.” This provision addresses, at the legislative level, the issue of the legality of foreign arbitration institutions conducting business in China.

At the level of local practice, pioneering regions represented by Shanghai have promulgated and updated specific operational rules. On 22 April 2025, the Shanghai Municipal Bureau of Justice issued the revised Measures for the Administration of the Establishment of Business Offices by Foreign Arbitration Institutions in Shanghai, which came into effect on 1 June 2025. The Measures require that foreign arbitration institutions meet conditions such as having been lawfully established and in continuous operation for more than five years and enjoying a relatively high level of international recognition. Upon registration with the judicial administrative authorities, such institutions may conduct arbitration of foreign-related commercial, maritime, and other disputes, and are required to comply with Chinese laws and regulations and submit periodic reports on their operations.

These institutional innovations precisely respond to the growing demand for internationalized and diversified dispute resolution mechanisms in Pilot Free Trade Zones, providing Chinese and foreign enterprises with a broader choice of arbitration institutions and enhancing the convenience and predictability of dispute resolution. At the same time, by introducing internationally renowned arbitration institutions together with their mature rules and management models, a “catfish effect” is created, incentivizing and pressuring domestic arbitration institutions to improve service quality and international competitiveness and to accelerate alignment with internationally accepted rules. In addition, the opening-up of arbitration helps transform Pilot Free Trade Zones into hubs for international arbitration resources, serving as a key measure to support the Belt and Road Initiative and to strengthen China’s position as a preferred venue for international commercial arbitration. The establishment of the WIPO Arbitration and Mediation Shanghai Center in 2019 and KCAB International in 2023 in Shanghai are concrete manifestations of the institutional dividends generated by this policy framework.

Top Ten Hot Topics 10：The Supreme People’s Court and Local Courts Release Reports/White Papers and Case Studies on Judicial Review of Arbitration, Summarizing Experience in Judicial–Arbitration Coordination, Promoting Unified Adjudicatory Standards, and Supporting the Development of Arbitration

Reason for Selection:

The institutional coordination between arbitration activities and judicial activities constitutes a critical juncture for enhancing the quality of arbitration practice and for building a law-based dispute resolution environment. Over the past year, multiple courts have released white papers and typical cases relating to judicial review of arbitration and arbitration-related adjudication, summarizing practical experience, contributing Chinese perspectives, and exploring pathways for the development of arbitration from a judicial standpoint.

On 18 December 2025, the Supreme People’s Court released “the Selected Questions and Answers from the Legal Response Platform (Batch 34) — Special Topic on Judicial Review of Arbitration (Second Series)”. This batch of questions and answers focuses on core issues in arbitration-related judicial review, including rules on accepting repeated applications to set aside arbitral awards, the applicable boundaries of re-arbitration in non-enforcement review proceedings, statutory review of arbitrator qualification requirements, and the determination of the validity of dispute resolution clauses in contract assignment scenarios, thereby providing authoritative guidance for judicial practice.

On 28 December 2025, the Supreme People’s Court issued the Annual Report on Judicial Review of Commercial Arbitration (2024), timely summarizing experience in arbitration-related judicial review and unifying adjudicatory standards. In 2024, courts nationwide concluded 18,566 cases involving judicial review of commercial arbitration, exhibiting the following key characteristics: fostering an “arbitration-friendly” judicial environment with low award-setting-aside rates and high preservation grant rates; continuously improving interregional judicial assistance and deepening economic and trade cooperation between the Chinese mainland and Hong Kong, Macao, and Taiwan; and actively practicing multilateralism through the accurate understanding and application of the New York Convention.

On 20 May 2025, the Chengdu Intermediate People’s Court released the White Paper on Judicial Review of Arbitration by Chengdu Courts (2019–2024). The White Paper summarizes the handling of commercial arbitration judicial review cases by Chengdu courts from 2019 to 2024, distills general adjudicatory approaches and rules, and puts forward recommendations for improvement in response to issues identified in arbitration-related judicial review practice.

On 27 November 2025, the Fourth Beijing Intermediate People’s Court issued the White Paper on Foreign-Related and Hong Kong, Macao, and Taiwan-Related Commercial Adjudication. The Beijing International Commercial Court has successively recognized and enforced 46 foreign arbitral awards, and the case “Certain Cayman Companies et al. Applying for Recognition and Enforcement of an Arbitral Award” was selected among the Top Ten Typical Cases as a representative example of recognition and enforcement of a Hong Kong arbitral award.

On 27 November 2025, the Dongguan Intermediate People’s Court released the White Paper on Judicial Review of Commercial Arbitration. This White Paper reviews cases handled by the court between 2020 and 2024 in the area of arbitration-related judicial review, outlines working mechanisms and practical highlights, and puts forward recommendations for promoting the sound development of arbitration in Dongguan. It aims to enhance public understanding of the arbitration judicial review system, promote the healthy and orderly development of arbitration in Dongguan, and help create a fairer and more efficient law-based business environment.

On 28 November 2025, the Tianjin High People’s Court, jointly with the Tianjin Arbitration Commission, released the bilingual (Chinese–English) White Paper on Judicial Review of Commercial Arbitration by Tianjin Courts, together with ten typical cases. The released cases focus on key areas such as judicial review procedures, judicial review of arbitration agreements, and judicial review of arbitral awards, and demonstrate exemplary value in upholding the principle of voluntariness in arbitration, accurately applying the New York Convention, promoting one-time resolution of disputes over the validity of arbitration agreements, and properly identifying foreign-related elements.

The release of the above-mentioned reports, white papers, and typical cases represents both a systematic review of arbitration judicial review practice by judicial authorities and the provision of clear adjudicatory guidance for arbitration activities. These efforts effectively unify adjudicatory standards, strengthen the positive interaction and coordination between the judiciary and arbitration, promote the standardized development of arbitration, enhance market participants’ confidence through clear rules and practical guidance, and contribute to the law-based improvement of the business environment.

In addition to the above Top 10 Highlights, the following five cases were shortlisted for the “Top 10 China Commercial Arbitration Highlights of 2025” through public voting and expert evaluation.

Shortlisted Hotspot 1：AI Integration into Arbitration Practice, End-to-End Empowerment of Digital and Intelligent Upgrading, and Systematic Exploration of AI Compliance Guidelines by China’s Arbitration Institutions

Reason for Selection：

Breakthroughs in artificial intelligence (AI) technology in China have triggered comprehensive social transformation. While maintaining the inherent prudence and credibility of arbitration, arbitration institutions have actively embraced this new technological revolution. The development of AI has opened up new possibilities for making arbitration more intelligent, efficient, and open. China’s arbitration institutions are advancing AI adoption in a manner tailored to local conditions, integrating the latest technological achievements to enhance quality and efficiency on the basis of their existing strengths, and proactively responding to the technological wave.

On 15 April 2025, the Shanghai International Economic and Trade Arbitration Commission (Shanghai International Arbitration Center) officially launched an AI-assisted arbitration system based on large language models. By deeply integrating data across the entire case-handling process, the system provides users with highly efficient and intelligent document-drafting assistance tools, marking a new stage in the intelligent production of arbitral documents.

On 28 September 2025, the “three-terminal integrated” smart arbitration platform of the Beijing Arbitration Commission / Beijing International Arbitration Center was comprehensively upgraded and officially launched. Centered on coordination among the three terminals of parties, arbitrators, and arbitration institutions, the platform fully realizes collaborative, paperless, and intelligent processing across the entire workflow, including case filing, tribunal constitution, hearings, and case closure, signifying that BAC’s arbitration services have entered a new phase of digitalization.

Article 11 of the new Arbitration Law expressly provides that: “Arbitration activities conducted online through information networks shall have the same legal effect as offline arbitration activities.” This provision removes legal barriers to fully online arbitration at the legislative level and reflects the State’s strong support for the digital and intelligent development of arbitration.

In addition to the direct embedding of AI technologies into the arbitration process, the arbitration community has also paid close attention to compliance issues arising from the use of AI. Based on the spirit of its arbitration rules and its arbitration practice, and with reference to internationally accepted approaches, the China International Economic and Trade Arbitration Commission (CIETAC) formulated the Guidelines on the Use of Artificial Intelligence Technology in Arbitration (Trial). These Guidelines came into effect on 18 July 2025 and will be periodically evaluated and revised on an ad hoc basis. The Guidelines represent the first normative instrument issued by an arbitration institution in China—and indeed in the Asia-Pacific region—specifically addressing the use of AI technology in arbitration. They respond to the growing practical demand of parties, arbitral tribunals, and other arbitration participants to reduce costs and improve efficiency through the use of AI in arbitration.

The application of AI by China’s arbitration institutions demonstrates several distinctive characteristics, including deepening application scenarios, diversified implementation models, and rules taking the lead. From efficiency tools and compliance guidelines in international commercial arbitration, to institutional recognition under national law, these developments collectively depict a multidimensional picture of the arbitration sector’s active yet prudent embrace of intelligent transformation. These practices are not merely responses to the practical challenge of “a high case volume relative to limited human resources”, but also represent an effort to reshape the core values of fairness, efficiency, and professionalism in arbitration in the digital era, contributing Chinese wisdom and Chinese solutions to the innovative development of global arbitration practice.

Shortlisted Hotspot 2：Arbitration Institutions in the Chinese Mainland Accelerate Global Expansion, with Overseas Branches Flourishing and Advancing the “China Arbitration” Brand Worldwide

Reason for Selection：

China’s arbitration institutions have achieved landmark breakthroughs in their internationalization process. A number of institutions have successively put into operation their overseas branches, marking that the global deployment of China’s arbitration services has entered a new stage.

On 15 October 2025, the Sixth Meeting of the Shanghai–Singapore Comprehensive Cooperation Council was held in Shanghai. The Shanghai International Economic and Trade Arbitration Commission (Shanghai International Arbitration Center) and the Government of the Republic of Singapore signed a Memorandum of Cooperation regarding the establishment of the Shanghai International Arbitration (Singapore) Center in Singapore. Following the establishment of the Shanghai International Arbitration (Hong Kong) Center in 2024 under the Shanghai–Hong Kong cooperation framework, the signing of this Memorandum represents a key step taken under the Shanghai–Singapore cooperation mechanism to further expand the institution’s overseas presence and to accelerate the establishment of the Shanghai International Arbitration (Singapore) Center.

On 21 October 2025, the inauguration ceremony of the Shanghai Arbitration Commission European Center (SHAC European Hub) was ceremoniously held at the City Hall of Málaga, Spain. The launch of the Center signifies a new breakthrough in the internationalization of the Shanghai Arbitration Commission, providing a new comprehensive and professional service platform located in Europe for global cross-border trade and investment.

On 12 November 2025, the inauguration ceremony of the Hong Kong Center of the Beijing Arbitration Commission / Beijing International Arbitration Center was held in Hong Kong. As the first overseas branch of the Beijing Arbitration Commission / Beijing International Arbitration Center and the China (Beijing) Securities and Futures Arbitration Center, the establishment of this Center represents both a key step in BAC’s specialized development and global expansion and an important initiative to support and integrate into Hong Kong’s development as an international arbitration center and international financial center.

As of December 2025, a total of seven Chinese arbitration institutions have established nine overseas branches in locations including Hong Kong, China; Vienna, Austria; Vancouver, Canada; Cyprus; and Málaga, Spain. The establishment of these overseas branches signifies that China’s arbitration institutions will further deepen their internationalization strategies, build integrated legal and commercial service platforms to support the global development of enterprises, and serve as overseas showcases of the “China Arbitration” brand. Leveraging these international platforms and working in close cooperation with global partners, China’s arbitration institutions will jointly promote the development of international arbitration practice, contribute wisdom and solutions to dispute prevention and resolution in international trade and investment, and mark China’s transition from a “new destination” for international arbitration to an “important provider” of global arbitration services.

Shortlisted Hotspot 3：China’s Courts Improve Arbitration–Litigation Coordination Mechanisms to Support the High-Quality Development of Arbitration

Reason for Selection：

China’s courts have actively advanced the optimization of coordination mechanisms between arbitration and litigation, with related practices achieving breakthrough progress. By standardizing review procedures and strengthening coordinated cooperation, courts across various regions have provided critical judicial support for evidence collection by arbitration institutions. These efforts have not only addressed the long-standing industry challenge of difficulties in evidence-taking in arbitration, but have also promoted positive and mutually reinforcing interaction between arbitration and the judiciary, laying a solid foundation for the efficient and fair resolution of disputes.

On 19 June 2025, the High People’s Court of Guangdong Province issued the Measures of the High People’s Court of Guangdong Province on Issuing Investigation Orders to Assist Commercial Arbitration Institutions in Evidence Collection (Trial). The Measures provide that, during the hearing of an arbitration case, where an arbitral tribunal determines upon review that it is indeed necessary to collect evidence related to the facts to be proved, but is unable to do so independently due to objective reasons, and where the location of the evidence or the place where it can be collected is within Guangdong Province, the arbitration institution concerned may apply to the people’s court with jurisdiction for the issuance of an investigation order. Where the court, upon review, finds that the application complies with the prescribed requirements, it shall issue an investigation order. Evidence collected by a holder of the investigation order together with a valid identity document shall be deemed equivalent to evidence collection conducted by judicial personnel.

At the level of judicial practice, on 14 May 2025, after examination, the Shanghai International Commercial Court lawfully supported an application for evidence collection submitted by the Shanghai International Economic and Trade Arbitration Commission (Shanghai International Arbitration Center) on the basis of interim measures ordered by the arbitral tribunal, and issued an investigation order to assist the arbitral tribunal in obtaining evidence. This case represents the first instance nationwide in which a people’s court supported interim measures in international commercial arbitration through the issuance of an investigation order, highlighting the coordinated safeguarding role of Shanghai courts in support of international arbitration.

On 27 June 2025, the Zhuhai Intermediate People’s Court lawfully issued an arbitration investigation order to the Zhuhai International Arbitration Court, marking the first investigation order issued nationwide by courts in Guangdong Province in a commercial arbitration case involving Macao-related elements.

On 30 June 2025, upon application by the Jiangmen Center of the Shenzhen Court of International Arbitration, the Jiangmen Intermediate People’s Court issued the first investigation order in a commercial arbitration case involving Hong Kong-related elements, for the purpose of obtaining property rights registration information to ascertain the facts of a cooperation dispute between a Hong Kong enterprise and a Guangdong enterprise.

On 3 July 2025, the Dongguan Intermediate People’s Court of Guangdong Province lawfully issued an arbitration investigation order to the Dongguan Arbitration Commission. In June 2025, the Dongguan Arbitration Commission accepted a loan contract dispute between a Dongguan-based enterprise and Xie, a resident of Taiwan, China. As it was necessary to obtain Xie’s identity information in order to ascertain the facts of the arbitration case, the arbitration institution submitted an application to the court for the issuance of an investigation order. Upon review, the court determined that the requested identity information was indeed necessary and issued the investigation order on the same day the case was placed on the docket.

The continuous improvement of arbitration–litigation coordination mechanisms, and the efficient and coordinated integration of legal resources, have effectively addressed the persistent difficulty faced by arbitration institutions in evidence collection, providing an important institutional safeguard for the high-quality development of China’s arbitration sector. Further deepening of judicial–arbitration coordination mechanisms will enhance the professionalism of commercial dispute resolution and contribute to the law-based improvement of the business environment.

Shortlisted Hotspot 4：Central–Local Coordination in Advancing the High-Quality Development of Arbitration, Cultivating International First-Class Institutions and Strengthening Industry Regulation

Reason for Selection：

In 2025, both central and local governments in China introduced a series of intensive policies and initiatives aimed at systematically promoting the high-quality development of arbitration. These efforts focus on two core directions: first, cultivating arbitration institutions and service hubs with international competitiveness; and second, strengthening supervision and regulation of the arbitration sector to enhance its credibility.

At the central level, on 31 July 2025, the Ministry of Justice convened a symposium on foreign-related arbitration, studying measures to accelerate the high-quality development of foreign-related arbitration and clearly deploying the implementation of the “Project for Cultivating International First-Class Arbitration Institutions with Chinese Characteristics” as a key initiative to serve major national strategies. On 15 December 2025, the Ministry of Justice and the China National Intellectual Property Administration jointly issued the Guiding Opinions on Strengthening Arbitration in Intellectual Property Disputes, calling for the enhancement of specialized arbitration institutions, improvement of professional arbitration rules, expansion of the scope of arbitration application, and advancement of foreign-related intellectual property arbitration, so as to fully leverage the important role of arbitration in the full-chain protection of intellectual property rights.

At the local level, on 26 September 2025, the 19th Session of the Standing Committee of the 16th Beijing Municipal People’s Congress adopted the Regulations on the Development of the Beijing International Commercial Arbitration Center, which came into effect on 1 December 2025. These Regulations constitute a local regulation formulated by Beijing to build a preferred venue for international commercial dispute resolution and to enhance the level of foreign-related rule-of-law services. Their core objective is to establish an international commercial arbitration center characterized by alignment with international standards, high-quality concentration of resources, world-class institutions, professional and efficient services, and robust judicial support.

In August 2025, Jiangxi Province promulgated the Several Measures on Strengthening Supervision and Administration of Arbitration and Enhancing the Credibility of Arbitration. These Measures focus on addressing key challenges in the development of the arbitration sector and on building a regulatory system that integrates internal governance with external supervision. Operable measures include: strengthening the internal governance of arbitration institutions and establishing sound corporate governance structures; enhancing quality management of arbitration cases by conducting quality reviews of arbitral documents at an annual sampling rate of no less than 10%, so as to ensure the quality of arbitral awards; strictly regulating the appointment of arbitrators and establishing an accountability system for arbitrators’ professional conduct; and strengthening the development of arbitration secretariat teams by improving classified and tiered management as well as evaluation and assessment systems.

On 7 May 2025, the physical platform of the International Commercial Arbitration Center (Beijing) was officially launched. The Center integrates functions such as exchange and cooperation, resource aggregation, arbitration promotion, shared services, and talent think tanks, and is positioned to guide the high-quality development of China’s arbitration sector. Arbitration institutions currently stationed on the platform include the China International Economic and Trade Arbitration Commission, the China Maritime Arbitration Commission, the Beijing Arbitration Commission / Beijing International Arbitration Center, the Hong Kong International Arbitration Centre, and the Singapore International Arbitration Centre. On 21 May 2025, the first circuit trial of the Beijing International Commercial Court was publicly heard at the physical platform of the International Commercial Arbitration Center (Beijing).

On 18 November 2025, the Department of Justice of the Inner Mongolia Autonomous Region held a special training session in Hohhot on “Implementing the Newly Revised Arbitration Law and Strengthening Arbitration Supervision and Administration.” The training aimed to thoroughly study and implement the newly revised Arbitration Law, accurately grasp its legislative intent, comprehensively enhance supervisory and administrative capacity, and promote the high-quality development of arbitration in Inner Mongolia.

On 4 December 2025, the Department of Justice of Shanxi Province held a province-wide special training session in Taiyuan on “Implementing the Newly Revised Arbitration Law and Strengthening Arbitration Supervision and Administration.” The training focused on implementing the new Arbitration Law, strengthening supervision and administration of arbitration, and enhancing the quality and credibility of the arbitration sector.

In summary, China is advancing the rule-of-law development of arbitration through a combination of top-level design and local innovation, employing diverse measures to optimize the business environment and promote the high-quality development of arbitration. These efforts further enhance the credibility and competitiveness of arbitration across regions nationwide, forming an arbitration landscape characterized by central coordination and multi-city advancement, and creating a dual-engine drive for the modernization of the arbitration system and the enhancement of its international competitiveness.

Shortlisted Hotspot 5：The Supreme People’s Court and the Ministry of Justice Jointly Advance the “Hong Kong (Macao)–Invested, Hong Kong (Macao) Arbitration” Framework to Support the Development of the Greater Bay Area International Commercial Arbitration Center

Special Note：

The “Annual Selection of China Commercial Arbitration Highlights” has been successfully held for four consecutive years. The Annual Selection Committee of China Commercial Arbitration Highlights hereby extends its sincere gratitude to courts nationwide, arbitration institutions, academic institutions, law firms, experts and scholars, and practitioners for their strong support of this initiative.

The purpose of the Annual Selection of China Commercial Arbitration Highlights is to expand the influence of China’s arbitration, promote exchanges between domestic and international arbitration communities, advance collaboration between arbitration theory and practice, and build an evaluation indicator system with credibility and influence.

In 2025, changes unseen in a century continued to deepen. All sectors in China have come to more acutely perceive the changes in the world, the times, and history itself. Each generation has its own choices and its own mission. “Reviewing major arbitration developments of the year and recording the history of arbitration development” is one of the important missions of our generation of arbitration professionals. It is precisely with this sense of mission that the Annual Selection Committee of China Commercial Arbitration Highlights has continued to organize the Annual Selection of China Commercial Arbitration Highlights, summarizing the development trajectory and major highlight events of China’s commercial arbitration in 2025.

This year’s selection not only systematically reviews the achievements of commercial arbitration in China in 2025, but also focuses on pressing practical issues as well as deeper theoretical and practical questions, with a view to assessing the future development trends of China’s commercial arbitration. We hope to foster a positive atmosphere in which “commercial arbitration serves society, and society pays attention to commercial arbitration,” and to contribute to the construction of a commercial arbitration system that combines both internationalization and Chinese characteristics.

In addition to the Top 10 Highlights and the five shortlisted highlights identified above, there are many other noteworthy developments in China’s commercial arbitration community in 2025. A non-exhaustive list is provided below:

First, arbitration institutions, universities, arbitration organizations, and other entities organized many influential events. Due to limitations on the scale and number of shortlisted highlights, not all such events have been included this year. We will continue to follow these developments.

Second, research institutions, arbitration institutions, law firms, and commercial enterprises in the Chinese mainland released numerous arbitration research reports, landmark cases, and white papers. Owing to limitations on the scale and number of shortlisted highlights, these materials have not all been included this year. We will continue to monitor these achievements.

Third, law firms and legal teams in the Chinese mainland handled a large number of foreign-related commercial arbitration cases involving high amounts in dispute, complex factual backgrounds, and difficult legal issues. Taking into account factors such as representativeness, influence, novelty, and significance, these cases have not been included in this year’s shortlist. We will continue to follow foreign-related commercial arbitration cases handled by law firms in the Chinese mainland.

This initiative is organized and evaluated by the Annual Selection Committee of China Commercial Arbitration Highlights. Members of the Committee participate in the selection in their personal capacities. The Annual Selection Committee of China Commercial Arbitration Highlights consists of review experts and a secretariat.

🔹 Arthur Chiu (United States)  | Juris Doctor (J.D.) from the University of Kansas School of Law; Senior Arbitrator, United States

🔹 Nick Chan | Director of the AALCO Hong Kong Regional Arbitration Centre; Deputy to the National People’s Congress; Member of the eighth Legislative Council of the Hong Kong Special Administrative Region (Legal Sector); Council Member of The Chinese University of Hong Kong; Member of the Faculty Boards of the Law Faculties of The University of Hong Kong and City University of Hong Kong; President of the Hong Kong–Mainland Legal Profession Association; Partner at the international law firm Squire Patton Boggs

🔹 Weimin Diao | Professor at the Civil Aviation Management Institute of China; Director of the Aviation Law Research Center; Research Fellow at the Arbitration Research Institute of China University of Political Science and Law; Senior Arbitrator

🔹 Yinli Gao | Vice Chairman of the Architectural Economics Branch of the Architectural Society of China; Professor-Level Senior Engineer; Senior Arbitrator; Partner / Senior Counsel at Beijing Cyan Law Firm

🔹 Junxiu Guo | President of the Aviation Law Research Association of the China Law Society; Vice President of the Shanghai Arbitration Association; General Counsel and Chief Compliance Officer of China Eastern Air Holding Company; Director of Legal Affairs and Data Protection Officer of China Eastern Airlines Corporation Limited

🔹 Meng Hou | Dean of the School of Law, Dean of the Institute of Digital Rule of Law and Professor at Zhongnan University of Economics and Law; Editor-in-Chief of Law and Social Sciences

🔹 Lifang Huang | Senior Legal Counsel, Samsung (China) Investment Co., Ltd.

🔹 Xiaojun Huang | Chief Representative of Veolia Group in China

🔹 Yanjie Li | General Manager of the Legal Department, Baidu, Inc.

🔹 Hui Ma | Secretary-General of the All-China Federation of Industry and Commerce Chamber of Environmental Services

🔹 Shenying Peng | Chief Risk Officer, General Counsel and Chief Compliance Officer of PowerChina International Group Limited

🔹 Jian Tan | Vice Chairman and Secretary-General of the China Enterprise Reform and Development Research Association

🔹 Jun Wang | Vice President of the International Economic Law Research Association of the China Law Society; Director and Professor of the Institute of International Trade and Financial Law, University of International Business and Economics; Senior Arbitrator

🔹 Lei Wang | General Manager of the Legal and Compliance Department, China Railway Construction International Group Co., Ltd.

🔹 Zhaoxi Xu | Deputy General Manager and Chief Compliance Officer of China Marine Aviation Group Co., Ltd.

🔹 Jusheng Zhang | Director of the Legal and Compliance Department, China National Chemical Engineering Group Corporation

🔹 Shuibo Zhang | Dean of the School of International Engineering Management, Professor and Doctoral Supervisor at Tianjin University; Deputy to the National People’s Congress; Senior Arbitrator

The Secretariat Office is based at the Hong Kong Cyan Research Institute. The members of the Secretariat are as follows:

🔹 Ting Hu | Director of the International Affairs Office, School of Law, Zhongnan University of Economics and Law

🔹 Chen Li | Strategic Partner, Beijing Cyan Law Firm

🔹 Wei Shi | Deputy Secretary-General of the Institute of International Trade and Financial Law, University of International Business and Economics; Ph.D. in Law

🔹 Jingmin Zhang | Program Director, School of International Engineering Management, Tianjin University

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