Jurisdiction(s):
United Kingdom

Enforcing Mainland China arbitral awards in Hong Kong: common law and statutory routes (Arbitration Ordinance Cap 609)

Published by a LexisNexis Arbitration expert

Practice notes

Before the handover on 1 July 1997, both Hong Kong and the Mainland were already parties to the New York Convention. That Convention, however, only regulates the recognition and enforcement of arbitral awards between distinct contracting states, and does not extend to enforcement between provinces or regions within a single state. To overcome this enforcement gap, the authorities in Hong Kong and the Mainland entered into the ‘Arrangement Concerning Mutual Enforcement of Arbitral Awards between the Mainland and the Hong Kong Special Administrative Region’...

Note: Hong Kong judgments below are not reported by LexisNexis®.

Mainland awards

A party successful in a Mainland arbitration may pursue enforcement of the award in Hong Kong by either:

relying on the common law, by issuing proceedings founded on an implied promise to honour the award (commonly known as an ‘action on the award’); or
proceeding under statute, through the summary procedure in the Arbitration Ordinance (Cap 609).

This statutory route removes the need to follow all the formal steps of an action to enforce an award. The prevailing party may apply ex parte, supported by an affidavit, for leave of the court to enforce the award as though it were a court judgment...

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Valerie Li

DLA Piper

Valerie Li is an Of Counsel in the Litigation and Regulatory team, based in DLA Piper's Hong Kong office. Valerie has extensive experience in international arbitration and commercial litigation. She is the Co-Chair of HK45 for the Hong Kong International Arbitration Centre (HKIAC). In 2018, Valerie is accredited as a Tribunal Secretary at the HKIAC. She regularly handles commercial disputes covering areas including intellectual property and technology, investment funds, joint ventures, licensing and distribution, energy and natural resources, and international trade and sale of goods in arbitrations seated in jurisdictions including Hong Kong, London, Singapore and Mainland China under rules including HKIAC, CIETAC, UNCITRAL, SIAC, ICC, and LMAA Terms. Valerie has represented clients from the Middle East, Americas, United Kingdom, Europe, Mainland China, Hong Kong, and other parts of Asia. Valerie has also acted for clients in...

Bryan Chan

DLA Piper

Bryan is a senior associate at DLA Piper Hong Kong. He has substantial experience in commercial litigation and arbitration. He has advised and acted for banks, funds, joint ventures and companies in various industries including real estate, pharmaceutical, sports, TMT, hotel, property management and shipping.Bryan has a particular focus on handling shareholders disputes, breach of directors’ duties, contractual disputes, insolvency and winding-up, breach of trust, fraud, property management and defamation.Bryan regularly advises and represents clients in proceedings at various levels of the Hong Kong courts, as well as arbitrations in the HKIAC, CIETAC, LCIA and SIAC.Most recently, Bryan has acted for a leading global investment manager in an HKIAC administered arbitration in respect of a shareholders' dispute which concerns a USD200 million investment in a joint venture in Mainland China, and also acted for one of the largest commercial real estate services and...

Janice Li

DLA Piper

I am currently an associate in DLA Piper's litigation and regulatory group. I am a solicitor admitted in the High Court of Hong Kong and an US attorney qualified to practice law in the New York State. My practice focuses on international arbitration and commercial litigation. I have handled disputes covering areas including financial instruments, licensing and distribution, construction, insurance, international trade and sale of goods, shipping, energy and natural resources and general commercial disputes in the High Court of Hong Kong, and arbitrations seated in jurisdictions including Hong Kong, Singapore, London, the US and Mainland China.I have advised clients in all aspects of disputes including asset preservation, injunctions, as well as enforcement of arbitral awards in various jurisdictions....

Web page updated on 21/05/2026

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