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United Kingdom
Key definition
Award definition

What does Award mean? In arbitration practice, an award is the arbitral tribunal’s written decision that determines the parties’ claims, defences and the relief granted. Legislation governs its effect and form in England & Wales and Northern Ireland (Arbitration Act 1996), Scotland (Arbitration (Scotland) Act 2010) and Ireland (Arbitration Act 2010 implementing the UNCITRAL Model Law). Key features commonly include: writing, signatures, the date, identification of the seat, and reasons unless the parties agree otherwise. An award is generally final and binding as to the matters decided, subject only to limited statutory challenges (for example, lack of jurisdiction, serious irregularity, and in England...

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Setting aside arbitral awards in Mainland China: jurisdiction, procedure, time limits, grounds, suspension of enforcement, and Prior Reporting under the 2023–2026 legal reforms

Practice notes
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The National People’s Congress of the People’s of China

Under PRC law, a party to arbitration may petition a PRC court to challenge or set aside an arbitral award. In many jurisdictions, the set-aside is termed vacation or annulment. This Practice Note has been updated to account for the 2025 amendments, which come into force on 1 March 2026. All references to articles of the Arbitration Law are to the law as amended.

Jurisdiction of the PRC courts and general procedure

As a matter of statute, PRC courts may annul only those arbitration awards seated in Mainland China and issued by arbitration institutions in Mainland China (Article 72 of the Arbitration Law, as amended in 2025). The Arbitration Law has no binding effect on awards seated outside those territories. Consequently, PRC courts have no power to set aside awards seated in Hong Kong, Macau, Taiwan, or in foreign states. Accordingly, the Arbitration Law binds only Mainland-seated proceedings and Mainland institutions within the PRC...

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Arthur (Xiao) Dong
Dr. Arthur (Xiao) Dong chambers

Qualified Year: 1996 Bar qualification of the People’s Republic of ChinaDr. Arthur (Xiao) Dong is a partner from JunHe LLP. He has worked as a PRC lawyer nearly 30 years. He has focused on complex matters of international commercial arbitration and litigation in relation to cross-border transactions. His expertise covers a wide spectrum, including: international trade, technology transfer and intellectual property protection, cross-border investments, antitrust private litigation and M&A, as well as distribution and franchise disputes. He has been continuously recognized as a leading practitioner in arbitration by renowned organizations such Chambers, Who’s Who Legal, Legal 500, Benchmark, and Asialaw.Arthur has been enrolled in the listed Panel of Arbitrators/Mediators of several well-established arbitration institutions such as HKIAC, SIAC, KCAB, CIETAC, BAC, SHIAC, SCIA, AIAC, WIPO. He is also a council member of the HKIAC. Arthur is a sought-after arbitrator among the...

Alex Yuan
Alex Yuan

Year qualified: 2010 Bar qualification of the People’s Republic of ChinaMr. Alex Yuan began his career in international trade and related dispute resolution in his undergraduate years. Before becoming a licensed lawyer, he had been working in an international trade company for years and practiced in diverse sectors in export and import business.  As a lawyer, Alex focuses on arbitration and litigation, including international sales of goods, commodity trade, transportation, settlement, insurance, technology services, and emission reduction transaction. He has also helped clients dealing with legal issues arising from several cross-border governmental procurements. He has served clients from many jurisdictions and has handled a quite a number of international arbitration cases before ICC, SIAC, HKIAC, JAMS, CIETAC, BAC, SHIAC as well as ad hoc arbitrations seated outside Mainland China. He is particularly skilled in appearing before overseas tribunal and conducting...

Web page updated on 21/05/2026

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