Russian International Arbitration Tribunals

Institutional Framework

Russian international arbitration is served by a network of permanent arbitration institutions (postoyanno deystvuyushchie arbitrazhnye uchrezhdeniya, PDAUs) that have been authorised to administer international commercial arbitration in accordance with the Federal Law on Arbitration in the Russian Federation (No. 382-FZ of 29 December 2015) and the Federal Law on International Commercial Arbitration (No. 5338-1 of 7 July 1993), which adopts the UNCITRAL Model Law. The 2015 arbitration reform significantly restructured the Russian arbitration landscape, introducing mandatory authorisation of arbitration institutions by the Government and restricting the admissibility of ad hoc arbitration for domestic disputes.

The reform was motivated by concerns about the quality and integrity of arbitration in Russia, the proliferation of pocket arbitration (karmanny arbitrazh) institutions that favoured one party, and the need to comply with international standards. The Ministry of Justice was designated as the authorising body, with the Council on the Development of Arbitration acting as an advisory body evaluating applications for the creation of arbitration institutions.

ICAC at the RF CCI

The International Commercial Arbitration Court at the Chamber of Commerce and Industry of the Russian Federation (MKAS pri TPP RF, ICAC) is the oldest and most prestigious Russian international arbitration institution. Established in 1932 as the Foreign Trade Arbitration Commission (Vneshnetorgovaya Arbitrazhnaya Komissiya, VAK), the ICAC has administered thousands of international disputes involving Russian and foreign parties. The ICAC operates under the Rules of Arbitration approved by the RF CCI, which are based on the UNCITRAL Arbitration Rules with adaptations for Russian practice.

The ICAC has jurisdiction over disputes arising from international commercial contracts, investment disputes, and other private law disputes involving foreign parties. The tribunal applies substantive law determined by the parties’ choice or, in the absence of choice, the conflict of laws rules it considers applicable. The ICAC’s awards are final and binding and are enforceable under the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards.

The ICAC’s panel of arbitrators includes leading Russian and international legal practitioners and academics. The arbitration procedure is conducted in Russian, English, or another language agreed by the parties. The ICAC has developed a substantial body of arbitral practice that contributes to the development of Russian international commercial law.

NAF MCU Maritime Arbitration

The Maritime Arbitration Commission at the RF CCI (Morskaya Arbitrazhnaya Komissiya pri TPP RF, NAF MCU ITU) specialises in disputes arising from maritime commerce. Established in 1930, the NAF MCU ITU is one of the oldest maritime arbitration institutions in the world. Its jurisdiction covers disputes from: contracts of carriage of goods by sea; charter parties; shipbuilding and ship repair contracts; marine insurance; collisions and salvage; and other maritime commercial relationships.

The NAF MCU ITU operates under separate rules adapted to the specific requirements of maritime disputes, including provisions for the appointment of arbitrators with specialised knowledge of maritime law and practice. The tribunal may order provisional measures, including the arrest of vessels, and its awards are recognised internationally under the New York Convention. The NAF MCU ITU maintains close cooperation with other leading maritime arbitration institutions, including the London Maritime Arbitrators Association (LMAA).

Trade and Commodity Arbitration

The Trade Arbitration Commission at the RF CCI (NAF MCU Torg, TAC) administers arbitration of disputes arising from domestic and international trade transactions, including sale of goods, distribution agreements, agency, and commercial representation. The TAC was established in 2017 as part of the arbitration reform to provide a specialised forum for trade disputes, complementing the ICAC’s broader international commercial arbitration mandate.

The Saint Petersburg International Commercial Arbitration Court (AMF SPB) was established in 2018 as the first regional international arbitration institution in Russia. Located in Saint Petersburg, the AMF SPB administers international and domestic commercial arbitrations under rules designed to meet international standards. Its establishment reflected the decentralisation of Russian arbitration and the growing demand for arbitration services outside Moscow.

Corporate Disputes Arbitration

The most significant development in Russian arbitration law was the 2015 reform’s gradual opening of corporate disputes to arbitration. Prior to the 2015 reform, corporate disputes — including disputes over the acquisition of shares in companies, challenges to decisions of corporate bodies, and disputes between shareholders and companies — were considered non-arbitrable under Russian law.

The 2015 Federal Law on Arbitration amended the procedural codes to permit the arbitration of corporate disputes under strict conditions. The arbitrability of corporate conflicts (arbitrabilnost korporativnykh sporov) was introduced through amendments to Articles 33 and 225.1 of the Arbitration Procedure Code (APK RF) and Articles 248–250 of the Civil Procedure Code. Corporate disputes may be referred to arbitration only if: the seat of arbitration is in Russia; the arbitration institution is a PDAU authorised to administer corporate disputes; and the arbitration agreement is concluded after the dispute has arisen or is contained in the company’s charter.

The ICAC at the RF CCI and several other authorised PDAUs have established specialised panels for corporate disputes. The panels include arbitrators with expertise in corporate law, securities regulation, and corporate governance. The possibility of arbitrating corporate disputes has been cautiously received by the Russian legal community. While some practitioners have welcomed the flexibility and confidentiality of arbitration, concerns remain about the appropriateness of arbitration for disputes involving mandatory company law provisions and the protection of minority shareholders.

Authorisation of Arbitration Institutions

The 2015 reform established a mandatory authorisation regime for arbitration institutions. Under Article 44 of Law No. 382-FZ, only PDAUs that have received authorisation from the Government of the Russian Federation may administer arbitrations seated in Russia. The authorisation process assesses the institution’s independence, impartiality, financial stability, and compliance with international standards.

By early 2026, approximately 30 PDAUs have been authorised, including the ICAC at the RF CCI and its specialised commissions, as well as arbitration centres affiliated with the Russian Union of Industrialists and Entrepreneurs (RSPP), the Moscow Chamber of Commerce, the Saint Petersburg International Commercial Arbitration Court, and regional chambers of commerce. The authorised list is maintained by the Ministry of Justice and published on its official website.

Challenge and Enforcement of Awards

Awards rendered by Russian arbitration tribunals may be challenged before the state courts on grounds set out in Law No. 5338-1 and the Arbitration Procedure Code. The grounds for setting aside are limited to: incapacity of a party; invalidity of the arbitration agreement; lack of proper notice or opportunity to present the case; the award exceeding the scope of the submission; irregular composition of the tribunal; or the subject matter being non-arbitrable under Russian law or contrary to public policy.

Enforcement of Russian arbitral awards is governed by the Arbitration Procedure Code and the Federal Law on Enforcement Proceedings. The courts apply a pro-enforcement approach consistent with the New York Convention. The public policy exception is narrowly construed, with courts setting aside awards only where enforcement would violate fundamental principles of Russian law, state security, or constitutional order.