International arbitration is largely concentrated in a few dominant centers, with most cases decided in arbitration-friendly jurisdictions by internationally recognized arbitrators. The cases are frequently administered by institutions originating from the same jurisdictions, conducted largely under rules developed by those same institutions, and decided by arbitrators who also often come from those jurisdictions.
According to 2025 International Arbitration Survey – The path forward: Realities and opportunities in arbitration, prepared by Queen Mary University of London and White & Case LLP, London ranks at the top of the preferred seat chart, with 60% in Africa, 48% in the Caribbean/Latin America, 59% in Europe, and 63% in the Middle East. Paris and Singapore occupy the second and third positions among the most preferred seats in Africa, Europe, and the Middle East. As for preferred arbitration rules by region, ICC and LCIA rules lead the rankings in Africa, Europe, and the Middle East, according to the same survey. According to the ICC Dispute Resolution 2024 statistics, the 2,392 parties involved in cases that year came from 136 countries or independent territories. The seat of arbitration was located in North and West Europe for 53.4% of cases. Similarly, nearly half of all appointed arbitrators (49.9%) came from North and West Europe.
It has long been discussed that cultural and linguistic competence matters when deciding cross-border disputes or international disputes in general. Most international disputes are multilingual and multicultural. But it is not only about understanding the language and the culture.
Deciding an arbitration case requires not merely understanding the matter but also believing the story put forward by the parties. The case is decided on the basis of the tribunal’s internal conviction, formed after analyzing the totality of the evidence, including witness statements, testimonies, expert reports and other submissions. From the standpoint of a practicing arbitration lawyer, one might argue that it is difficult task to persuade even a well-educated and experienced professional to believe something that is deeply rooted in the relationships existing within a particular legal system and society.
In his well-known article “The Use of Knowledge in Society,” Nobel laureate economist Friedrich August von Hayek famously argued that:
“The peculiar character of the problem of a rational economic order is determined precisely by the fact that the knowledge of the circumstances of which we must make use never exists in concentrated or integrated form but solely as the dispersed bits of incomplete and frequently contradictory knowledge which all the separate individuals possess”.
I would argue that this well-known economic principle developed by Hayek, commonly referred to as the “knowledge problem,” is highly relevant to the field of arbitration. No matter how diligent an arbitrator may be, it is impossible for a single individual to familiarize themselves fully with the myriad peculiarities of all jurisdictions in which the facts of a dispute may arise.
Consequently, if we seek to enhance the quality of justice delivered through international arbitration, we should pursue a greater decentralization of the arbitral landscape and the global arbitration community.
This is not to suggest, of course, any limitation on party autonomy; nothing should be done that contravenes the parties’ freedom to select the preferred seat of arbitration as well as whomever they trust and consider best suited to decide their case. On the contrary, our objective should be to expand the range of meaningful choices available to users. To that end, it is essential to promote the development of additional regional arbitration hubs – the jurisdictions capable of serving both as healthy competitors and as credible alternatives to the long-established arbitration-friendly jurisdictions and the institutions situated within them.
With the above in mind, we also face a long-discussed question: What can emerging economies do to earn such trust and become a trusted home (or “seat,” in arbitration terminology) for arbitration? Do Eastern European countries have a chance to become regional hubs for arbitration?
Let’s consider Georgia as an example. Two neighbors of Georgia, Azerbaijan and Armenia achieved a historic peace deal on August 8, 2025. This agreement creates an opportunity for the two countries to reestablish economic relations, which have been virtually nonexistent for more than 30 years. Once economic ties are restored – through trade, energy, construction, infrastructure, and other projects – disputes will naturally arise.
Where should Armenian and Azerbaijani businesses resolve their cases?
The conventional and most likely outcome would be arbitration in Paris, London, Stockholm, etc. However, Georgia has historically been a preferred destination for both countries—whether for business, travel, or leisure. The ties between Azerbaijani and Georgian, as well as Armenian and Georgian, business communities are strong. Culturally, the three countries also share significant history and traditions.
Therefore, Georgia has a natural advantage as a trusted, neutral forum for Armenian and Azerbaijani businesses to resolve their disputes. The costs of travel, legal services and other related expenses would also be significantly lower. There is a historic opportunity for Georgia, as a jurisdiction, to earn this trust. Georgian arbitrators are also well positioned, given their knowledge of the region and their understanding of both cultures – not only as neighbors, but also because thousands of Georgian citizens have Azerbaijani or Armenian roots. This provides a genuine geographical and cultural advantage, allowing Georgian arbitrators to better understand, assess, and decide cases involving parties from these countries.
A similar argument can be made about Ukraine. Once the war ends, companies from the region and beyond will invest in Ukraine’s rebuilding process. Naturally, this will lead to disputes in areas such as construction, infrastructure, trade, and energy.
The race is on. Whoever builds trust in their jurisdiction – whoever maintains a corruption-free justice system with clear and predictable case law that supports arbitration and properly recognizes and enforces awards in line with the New York Convention – will win these upcoming cases.
To conclude, as international arbitration continues to evolve, its future need not remain confined to a handful of traditional centers. The realities of today’s globalized, multilingual, and multicultural disputes demand a system that values local insight as much as global expertise. Emerging jurisdictions have a genuine opportunity to contribute to this evolution by offering culturally informed arbitrators, geographic neutrality, and cost-efficient venues. Their ability to build trust – through transparent courts, predictable case law, and steadfast adherence to international standards – will determine whether they can join the ranks of credible regional arbitration hubs. Ultimately, broadening the geography of arbitration is not merely about diversifying the map; it is about strengthening the legitimacy, inclusivity, and effectiveness of international dispute resolution itself.
