International Arbitration

Institutional Arbitration

ICC, LCIA and SCCA proceedings involving Saudi and cross-border disputes.

Interim & Emergency Relief

Tribunal, emergency-arbitrator and court measures supporting arbitration.

Cross-Border Enforcement

Recognition, enforcement and challenges involving foreign arbitral awards.

Government Contracts

Saudi approval requirements and special rules for public-sector contracts.

International arbitration involving Saudi Arabia requires careful coordination between the arbitration agreement, the institutional rules selected by the parties, the law of the seat, Saudi mandatory law and the enforcement strategy that will apply once an award is issued.

Our dispute resolution team advises on complex commercial and cross-border disputes involving Saudi Arabia and the wider region, including matters arising in the energy, infrastructure, construction and commercial sectors. We advise on arbitration under leading institutional rules, Saudi-seated proceedings, cross-border enforcement and arbitration-related court applications.

Service 01

Institutional and Cross-Border Arbitration

We advise on arbitrations under the rules of leading institutions, including the International Chamber of Commerce (ICC), the London Court of International Arbitration (LCIA) and the Saudi Center for Commercial Arbitration (SCCA), as well as arbitration-related issues arising under the Saudi Arbitration Law.

—	ICC arbitration under the 2026 Rules. The 2026 ICC Arbitration Rules took effect on 1 June 2026. We advise on proceedings under the current framework, including its revised case-management approach, the applicable Expedited Procedure provisions and the opt-in Highly Expedited Arbitration procedure.
—	SCCA arbitration. We advise on Saudi and cross-border disputes under the SCCA Arbitration Rules, including tribunal appointment, procedural strategy, language, seat, interim measures and the SCCA's Emergency Arbitrator framework.
—	Arbitration and mediation strategies. Where appropriate, we advise clients on multi-tier dispute-resolution clauses combining negotiation, mediation and arbitration, including available SCCA mediation mechanisms as a step before commencing arbitration, to manage cost and time before a dispute escalates to a full arbitral proceeding.
—	Arbitration-clause drafting. We draft and review dispute-resolution clauses covering the arbitral institution, seat, governing law, language, number and method of appointment of arbitrators, escalation procedures and related enforcement considerations. These elements should be addressed deliberately rather than left to a generic institutional reference.
—	Saudi-seated arbitration and arbitrator qualifications. Where Saudi Arabia is the seat, we consider the mandatory requirements of the Saudi Arbitration Law together with the selected institutional rules. Under Article 14 of the Saudi Arbitration Law, arbitrators must satisfy the statutory qualification requirements, including that the chairman or sole arbitrator hold a university degree in Sharia, legal studies, or a recognized equivalent legal qualification where required. We assess proposed tribunal members against these requirements to reduce procedural risks affecting the validity of the arbitration process.
—	Seat, governing law and institutional rules. The seat of arbitration, the substantive law governing the dispute and the chosen institutional rules perform different legal functions. We advise clients on these distinctions at both the contract-drafting and dispute stages, particularly where Saudi law or Saudi assets are involved.
—	Tribunal strategy. We advise on tribunal composition, arbitrator selection and the procedural considerations relevant to complex commercial, construction, infrastructure and energy-related disputes.

Service 02

Interim and Emergency Relief

A party may require urgent protection before the arbitral tribunal is fully constituted or before a final award can be obtained. The appropriate route depends on the arbitration agreement, institutional rules, seat and location of the assets or evidence requiring protection.

—	Tribunal interim measures. Once constituted, an arbitral tribunal may have authority under the applicable arbitration law and institutional rules to order provisional or precautionary measures. We assess the tribunal's jurisdiction, the relief available and the practical steps needed to preserve the client's position.
—	Saudi court support. Seeking an interim measure from a competent judicial authority does not necessarily conflict with the arbitration agreement. We assess when Saudi court relief may be available in support of an existing or contemplated arbitration.
—	Emergency Arbitrator procedures. The SCCA Rules and other institutional frameworks provide mechanisms for obtaining urgent relief before constitution of the tribunal. Under the current SCCA framework, an Emergency Arbitrator can issue an interim award or order addressing urgent provisional or precautionary relief.
—	Enforcement of emergency relief. Emergency Arbitrator decisions require careful assessment where court enforcement is needed. Depending on the circumstances, parties may consider voluntary compliance, tribunal confirmation of the relief after the tribunal is constituted, or seeking supporting judicial measures before the competent court. An Emergency Arbitrator's interim order or award should not automatically be assumed to receive the same Saudi enforcement treatment as a final arbitral award.
—	Asset and evidence preservation. We advise on interim and precautionary measures that may be available to protect assets, preserve evidence or maintain the status quo while the arbitration proceeds, and coordinate related applications in other jurisdictions with appropriate foreign counsel where necessary.

Service 03

Recognition and Cross-Border Enforcement

Arbitration strategy should take enforcement into account before the final award is issued. The location of the counterparty, assets, seat of arbitration and applicable treaty framework can materially affect the route available after an award. We consider enforcement requirements at the beginning of the arbitration strategy, including asset location, recognition requirements, public-policy issues and document preparation, rather than treating enforcement as a separate stage after the award. We advise on recognition and enforcement of foreign arbitral awards in Saudi Arabia and on defenses or challenges where a client is facing enforcement.

—	The New York Convention. Saudi Arabia applies the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards subject to its reciprocity reservation. Under that reservation, the Convention applies to arbitral awards made in the territory of another Contracting State, so the originating jurisdiction of the award should be confirmed as a Convention member state before enforcement is pursued on this basis. We review the applicable enforcement requirements at the outset, before an application is filed, rather than assuming every foreign award is automatically enforceable.
—	Saudi Enforcement Law. Recognition and enforcement must also be assessed under the Saudi Enforcement Law and any applicable international treaty. The Enforcement Law contains separate conditions governing foreign judgments and extends the relevant framework to foreign arbitral awards.
—	Document preparation and authentication. Following Saudi Arabia's accession to the Hague Apostille Convention, eligible foreign public documents issued by member states — including arbitral awards, arbitration agreements and supporting foreign documents — may benefit from simplified authentication procedures through Apostille certification instead of traditional legalization chains, subject to applicable requirements. We assist with preparing the enforcement documentation, coordinating the applicable authentication or Apostille process for the specific originating jurisdiction, arranging certified Arabic translations and addressing deficiencies in the supporting documents before filing.
—	Judgment-debtor identity verification. Before an enforcement application is filed, the debtor's correct legal identity and commercial-registration details should be verified. This is distinct from identifying executable assets and helps avoid delays caused by proceeding against an incorrectly identified legal entity.
—	Public policy and enforcement defenses. We assess the statutory and treaty grounds that may affect recognition or enforcement, including Saudi public-order considerations. Saudi enforcement courts may refuse enforcement of specific parts of a foreign arbitral award that conflict with Saudi public policy, including certain interest-based amounts or punitive damages, while allowing enforcement of the remaining valid portions of the award where legally possible — rather than the award being rejected in its entirety on that basis alone.
—	Annulment and award challenges. Where an award is Saudi-seated, we assess the grounds for an action to set aside the award under the Saudi Arbitration Law and the statutory deadlines applicable to that challenge. An annulment action is not an appeal on the merits and is limited to the grounds recognized by the Law.
—	Arbitration support jurisdiction. Applications relating to arbitration support measures, annulment actions and certain arbitration-related proceedings are submitted before the competent Commercial Court of Appeal in Saudi Arabia in accordance with the applicable jurisdictional rules.
—	Multi-jurisdictional enforcement planning. Where assets or parties span several jurisdictions, we work with appropriate foreign counsel to coordinate the sequencing of enforcement steps and assess how proceedings in one jurisdiction may affect strategy in another.

Service 04

Government Contracts and State-Related Disputes

Arbitration involving the Saudi public sector requires a separate legal analysis. The fact that a contract contains an ICC, SCCA or other arbitration clause does not, by itself, establish that a Saudi government body had authority to agree to arbitration. A distinction should also be made between a Saudi government body and a company that is merely government-owned or state-linked. The applicable arbitration and procurement rules depend on the legal status of the particular entity and the framework governing the contract, and the approval requirements described below apply to government bodies specifically rather than to every state-linked or state-owned company.

—	General government-body approval rule. Under Article 10(2) of the Saudi Arbitration Law, government bodies may not agree to arbitration without the approval of the Prime Minister, unless a special statutory provision permits otherwise.
—	Government procurement contracts. For contracts governed by the Government Tenders and Procurement Law, arbitration requires the applicable statutory approvals, including approval of the Minister of Finance where applicable, and the additional conditions established by the Implementing Regulations. This procurement-specific route operates alongside, rather than in conflict with, the general Article 10(2) approval requirement for government bodies.
—	Article 154 requirements. Under the current Implementing Regulations of the Government Tenders and Procurement Law, arbitration is generally limited to contracts whose estimated value exceeds SAR 100 million, subject to the Minister's authority to amend that threshold. The arbitration must be conducted in Saudi Arabia through the SCCA or another licensed arbitration centre, Saudi law must govern the subject matter of the dispute, and the arbitration terms must be included in the contract documents.
—	Contracts performed outside Saudi Arabia. The current Article 154 framework contains a specific treatment for government contracts whose subject matter is performed outside the Kingdom. Those contracts may be exempt from the general SAR 100 million threshold, subject to the required approval and the remaining applicable regulatory conditions.
—	Authority and clause review. Before a contractor relies on an arbitration clause against a government counterparty, we assess the legal status of the entity, the procurement framework applicable to the contract, the required approvals and whether the arbitration clause complies with the mandatory statutory conditions.
—	Government contract disputes. We advise on the interaction between arbitration provisions and the Government Tenders and Procurement Law's substantive and procedural requirements, including issues relating to contract administration, extensions, delay penalties and other remedies applicable to the underlying government contract.
—	Cross-border regulatory issues. Where an international dispute also raises sanctions, export-control or other regulatory questions in a relevant jurisdiction, we coordinate the arbitration strategy with the applicable regulatory analysis and, where necessary, appropriate foreign counsel.

Arbitration Experience

Abdulaziz Bin Ali & Partners' dispute resolution practice includes international arbitration as a core capability. The team advises on arbitrations involving Saudi and international parties, including proceedings under major institutional rules and arbitration-related litigation involving enforcement and interim measures. Founding Partner Abdulaziz Bin Ali is an experienced Saudi disputes practitioner and an accredited international arbitrator. Senior Legal Consultant Ammad Manzur also has experience in international arbitration matters under the LCIA, ICC and SCCA rules, including energy and infrastructure disputes and arbitration-related court proceedings.

How We Work

1	Confirm the arbitration framework We begin with the arbitration agreement, seat, governing law, institutional rules and status of the counterparty before determining the procedural route.
2	Protect the client's position early Where urgent action is required, we assess tribunal, emergency-arbitrator and court relief and consider asset and evidence preservation before the dispute progresses further.
3	Build the case around the commercial objective We coordinate the contractual, legal, factual and expert record around the result the client needs rather than treating arbitration procedure as an end in itself.
4	Plan enforcement before the award We consider enforcement requirements from the beginning of the arbitration strategy — including the location of assets, recognition requirements, public-policy issues and document preparation — rather than treating enforcement as a separate stage addressed only after a favorable award is obtained.

Facing an International Arbitration Involving Saudi Arabia?

Whether you are drafting an arbitration agreement, managing institutional proceedings, seeking interim relief or enforcing an award, our International Arbitration team can advise on the applicable Saudi and cross-border framework.

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