Costs in international arbitration

Costs in international arbitration

This Practice Note discusses the types of costs that can be incurred in international arbitration proceedings and considers practical steps that can be taken to assist with the recovery of costs. It covers the costs incurred in the arbitration (legal fees and disbursements and costs of the arbitration, including the tribunal’s fees), allocation and recoverability of costs and the award on costs. It also covers security for costs and links out to further content on this subject.

See Practice Note: Costs in international arbitration.

Fees of the arbitral institutions

This Practice Note sets out the fees incurred in arbitration under key institutional rules including International Chamber of Commerce (ICC), London Court of International Arbitration (LCIA), Singapore international Arbitration Centre (SIAC), Dubai International Arbitration Centre (DIAC), Stockholm Chamber of Commerce (SCC), China International Economic Trade Arbitration Commission (CIETAC), American Arbitration Association (AAA), Hong Kong International Arbitration Centre (HKIAC) and Swiss Arbitration Centre (SAC). This Practice Note also covers links to cost calculators provided by the various institutions to estimate the cost of arbitral proceedings under their Rules.

See Practice Note:

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Latest Arbitration News

French courts re-affirmed how the irreconcilability between an arbitral award and a foreign judgment may amount to a breach of international public policy (SNEL v Congo and FG Hemisphere)

Arbitration analysis: On 16 September 2025, the Paris Court of Appeal (the Court) dismissed Congolese company Société Nationale d’Électricité (SNEL)’s application to set aside an ICC award rendered against it and the Democratic Republic of Congo, confirming France’s pro-enforcement stance. The Court held that as a matter of principle, the irreconcilability between an arbitral award and a non-EU foreign judgment may amount to a breach of international public policy in circumstances where the foreign judgment has first obtained exequatur in France and the irreconcilable decisions result in mutually exclusive consequences. In the present case, because the Congolese judgment relied upon by SNEL had been denied exequatur for lack of proper notice to the opposing party, no irreconciliability could arise. The Court reaffirmed that the mere disregard of a foreign judgment’s res judicata effect by an arbitral award is not, in and of itself, contrary to international public policy. The Court further clarified that the exequatur judge exercises only limited review, verifying the existence of the arbitral award and the absence of any manifest breach of international public policy, dismissing SNEL’s other arguments based on capacity to arbitrate, arbitrability, and foreign procurement rules, which did not amount to a breach of French international public policy. Written by Julie Spinelli, partner at Le 16 Law, and Carl Szymura, associate at Le 16 Law.

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