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Recognition and Enforcement of Arbitral Awards in Japan: Procedure, Defences, 2023 JAA Reforms and Business Courts

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Japan offers a transparent, dependable pathway for parties aiming to enforce arbitral awards. Its legislation reflects global best practice, and the courts typically take a pro-arbitration approach when dealing with enforcement.

Legal framework for arbitration award enforcement in Japan Applicable laws and Conventions

Japan is a member State of the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (the New York Convention), having acceded on 20 June 1961. This early accession underscores Japan’s enduring arbitration-friendly outlook. That said, Japan declared under Article I(3) that it applies the Convention solely to awards issued in other contracting States, thereby confining its effect to reciprocal recognition and enforcement.

The Japan Arbitration Act (JAA) (Act No. 138 of 2003, as amended by Act No. 53 of 2023) governs every arbitration seated in Japan, domestic or international. The JAA incorporates the UNCITRAL Model Law, including the 2006 revisions, keeping Japan’s regime in step with international standards and recent dispute resolution developments, among them provisions connected to the United Nations Convention on International Settlement Agreements Resulting from Mediation (the Singapore Convention).

Distinction between domestic and foreign awards Enforcement framework for both award types

Under Japanese law, ...

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Michael Mroczek
Michael Mroczek

Partner, Nozomi Sogo Attorneys at Law | President, Swiss Chamber of Commerce and Industry in JapanMichael Mroczek is a Swiss-qualified attorney and Registered Foreign Lawyer in Japan with over 15 years of experience in international arbitration. He regularly acts as counsel and arbitrator in complex commercial disputes involving Japanese and European parties. He has experience with arbitrations under major institutional rules, including the ICC, JCAA, SIAC, and the Swiss Rules of International Arbitration, and frequently advises on enforcement, recognition, and post-award proceedings.Based in Tokyo since 2012, Michael currently serves as President of the Swiss Chamber of Commerce and Industry in Japan, a position he also held from 2015 to 2019. He previously served as President of the European Business Council in Japan and is a strong advocate for the use of Swiss arbitration in Asia-related contracts.He lectures on...

Aiko Ota
Aiko Ota

Of Counsel, Nozomi Sogo Attorneys at LawMs. Ota has extensive experience in handling international disputes, including arbitration, arbitration-related court proceedings, and cross-border commercial litigation. She regularly advises multinational clients on dispute resolution strategies in complex, multi-jurisdictional matters. Her practice also includes compliance, risk management, data protection, employment law, and general corporate matters. ...

Web page updated on 21/05/2026

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