When parties in a cross-border contract need to resolve a dispute, they’re not just picking a law firm—they’re picking a seat. And in 2025, two Asian cities—Hong Kong and Singapore—are locked in a quiet, high-stakes race to be the world’s top choice. Neither is flashy. Neither is loud. But both are relentless. And this year, the gap between them grew more interesting than ever.
The Numbers Don’t Lie
In the latest International Arbitration Survey, Hong Kong and Singapore tied for second place globally, each securing 31% of respondents’ preference. That’s not a fluke. It’s the result of decades of institutional discipline. The Hong Kong International Arbitration Centre (HKIAC) handled 352 cases in 2024, with an average value of $48.1 million per dispute. Meanwhile, the Singapore International Arbitration Centre (SIAC) managed 625 cases—but with a lower average value of $34.4 million. The twist? SIAC’s volume is nearly double, but HKIAC’s cases are heavier, often involving larger Chinese-linked deals. Compare that to mainland China’s CIETAC and SHIAC, which together handled over 10,000 cases in 2024, yet averaged just $1 million to $4.3 million per dispute. The message is clear: when the stakes are high, parties go to Hong Kong or Singapore.
Why Hong Kong Has the Edge—For Now
Here’s the real differentiator: access. Since August 2025, parties to HKIAC-seated arbitrations have been able to apply directly to courts in mainland China for interim relief—freezing assets, blocking shipments, securing evidence—without needing to go through a foreign court first. That’s thanks to the Arrangement Concerning Mutual Assistance in Court-Ordered Interim Measures. No other arbitration seat has that. Not London. Not Paris. Not even Singapore. It’s a game-changer for companies doing business with Chinese entities. If you’re negotiating a joint venture in Guangdong or a supply deal in Shanghai, having a seat in Hong Kong means you can move fast if things go south.
And it’s not just about access—it’s about predictability. In August 2025, the Hong Kong Court of First Instance handed down CNG v G & Anor (HKCFI 3598), a landmark ruling that slammed the door on frivolous challenges to arbitral awards. The case involved claims that an arbitrator had fallen asleep during hearings and showed hostility. The court didn’t just dismiss the challenge—it set a new, extremely high bar. "Mere allegations of inattention," the judge wrote, "do not equate to bias." That kind of judicial restraint is exactly what multinational corporations crave.
Singapore’s Quiet Strength
Singapore doesn’t need flashy arrangements. It thrives on consistency. Its courts are famously pro-arbitration, its legal system ranked among the world’s most transparent by the World Justice Project. SIAC’s case load isn’t just big—it’s diverse. Companies from India, Indonesia, Australia, and even Europe choose Singapore because they know the process won’t be disrupted by political noise. The International Chamber of Commerce ranked Singapore ninth globally for new cases in 2024, with 28 tribunals seated there. That’s not the highest, but it’s steady. And in a world where unpredictability is the real risk, steady is gold.
Plus, Singapore’s infrastructure is seamless. The AAA-ICDR Asia Case Management Centre operates out of its city-state, offering U.S.-style efficiency with Asian pragmatism. Foreign lawyers can appear without restriction. Arbitrators from any nationality can be appointed. The rules are modern, clear, and enforced without delay.
The China Factor: A New Law, A New Dynamic
On September 12, 2025, the Standing Committee of the National People's Congress adopted China’s New Arbitration Law, set to take effect March 1, 2026. For the first time in Chinese law, the concept of an "arbitration seat" is formally recognized—and defined by a three-stage test: (1) party agreement, (2) arbitration rules, (3) tribunal determination. That’s a huge step toward international alignment.
But here’s the catch: the new law strips mainland courts of their power to assist in appointing arbitrators. That means if parties can’t agree on an arbitrator, and the seat is in mainland China, they’re stuck—no court can step in. Hong Kong and Singapore, by contrast, have courts that will intervene to keep proceedings alive. That’s not just procedural—it’s strategic. It makes Hong Kong an even more attractive alternative for Chinese-linked disputes, because you get the benefits of Chinese market access without the legal friction.
Global Shifts, Local Reactions
Meanwhile, the United Kingdom Arbitration Act 2025 came into force on August 1, 2025. It changed a fundamental rule: if a contract doesn’t specify a governing law for the arbitration agreement, it defaults to the law of the seat—not the main contract. That aligns England with France and Sweden, and overturns the Supreme Court’s 2020 ruling in Enka v Chubb. It’s a quiet revolution. Parties now have more certainty. And it reinforces why seats matter more than ever.
Hong Kong didn’t sit still. In October 2025, Hong Kong Arbitration Week 2025Hong Kong marked the 40th anniversary of the Hong Kong International Arbitration Centre (HKIAC). Dozens of global practitioners gathered—not for spectacle, but for substance. The message was clear: Hong Kong isn’t just surviving. It’s evolving.
What’s Next?
The next 12 months will be decisive. Will mainland China’s new law lead to more disputes being seated in Hong Kong? Will Singapore’s efficiency lure even more European clients? Will the UK’s new default rule make London a more attractive alternative for parties who want common law but avoid Asia’s geopolitical weight?
One thing is certain: the arbitration world is no longer about where you’re from. It’s about where you can get a fair, fast, enforceable outcome. And right now, Hong Kong and Singapore are the only two places that consistently deliver that.
Frequently Asked Questions
Why is the arbitration seat so important?
The seat determines the legal framework governing the arbitration—everything from how arbitrators are appointed, to whether courts can intervene, to how awards are enforced. A seat like Hong Kong or Singapore offers predictable, pro-arbitration laws under the UNCITRAL Model Law, while a seat in a less stable jurisdiction could lead to delays or unenforceable outcomes.
Can I still use mainland China as a seat for international disputes?
Technically yes, but it’s risky. While China’s new law formally recognizes the "arbitration seat," it removes court support for appointing arbitrators and limits judicial assistance. For foreign parties, this creates uncertainty. Most multinational firms avoid it unless they’re contractually bound, preferring Hong Kong or Singapore for their neutrality and enforceability.
What makes Hong Kong better than Singapore for Chinese-related disputes?
Hong Kong’s unique Interim Measures Arrangement lets parties seek asset freezes and evidence preservation directly from mainland Chinese courts—a right no other international seat offers. Combined with mutual enforcement of awards under the 1999 arrangement, this makes Hong Kong the only bridge between Western-style arbitration and China’s legal system.
How do HKIAC and SIAC compare in terms of speed and cost?
SIAC handles more cases and has lower administrative fees, making it popular for mid-sized disputes. HKIAC, while slower in volume, is preferred for complex, high-value cases—especially those involving Chinese parties. Both offer expedited procedures, but HKIAC’s 2025 rulings show stronger judicial backing, reducing the risk of post-award challenges that can delay enforcement.
Is the UK’s new arbitration law a threat to Hong Kong and Singapore?
Not really. The UK’s default rule aligns it with global standards, but London still lacks the regional access Hong Kong offers to Asia and the neutrality Singapore maintains in U.S.-China tensions. For parties with Asian exposure, Hong Kong and Singapore remain unmatched. London is strong for Europe-centric disputes, but not a substitute.
What’s the biggest risk for parties choosing either seat?
The biggest risk isn’t the system—it’s assuming either seat is "safe" without understanding the nuances. Hong Kong’s political climate is under scrutiny, and Singapore’s neutrality can be tested in U.S.-China trade wars. Parties must still draft arbitration clauses carefully, specify the seat clearly, and choose institutions with proven track records—not just convenience.
