Award enforcement in six countries

What is compared and where to start

Enforcement depends on the country where coercive measures are sought and how its law classifies the particular award. Examine the seat, procedural law and arbitral body separately: not every country defines a foreign award solely by where it was made.

The Russian status of an authorised permanent arbitral institution is a national legal concept; other countries set their own institutional requirements. An international dispute does not necessarily yield a foreign award. The table highlights differences; national sections address documents, review limits and practice. See also the state-court comparison for the proper court.

Six countries at a glance

Russia: identify the seat first

For enforcement in Russia: Institutional administration and a foreign award describe different aspects of arbitration. Foreign-seated arbitration may itself be institutional or ad hoc. The parties’ nationality or an institution’s name alone does not determine the legal seat.

See the six-country court comparison for the competent court system and application route.

Institutional arbitration seated in Russia

Compulsory enforcement requires a writ: section 2 of Chapter 30 of the Commercial Procedure Code applies to economic disputes; Chapter 47 of the Code of Civil Procedure applies within general court jurisdiction. This route also covers international commercial arbitration seated in Russia. The tribunal makes the award; the institution administers proceedings.

Ad hoc arbitration seated in Russia

The applicable code likewise provides a writ procedure. Courts examine statutory refusal grounds, including consent, tribunal composition and procedure. Actual organisation matters: paragraph 50 of Plenum Resolution 53 addresses violations under Article 44(20) of 382-FZ.

Foreign-seated institutional or ad hoc awards

Recognition and enforcement involve the New York Convention, Articles 35–36 of the International Commercial Arbitration Law and procedural legislation. Chapter 31 of the Commercial Procedure Code covers economic disputes; Chapter 45 of the Code of Civil Procedure applies in general courts. Required documents, translations and refusal grounds are examined.

Foreign institutions and the seat

When a foreign institution administers arbitration seated in Russia, Article 44 of 382-FZ governs the relevant Russian institutional-status issues. That differs from enforcing a foreign-seated award. Arbitrability and specific statutory requirements also require examination.

One Russian route with different features

Statutory basis: Articles 236–240 of the Commercial Procedure Code / Articles 423–427 of the Civil Procedure Code. Russian-seated institutional and genuine ad hoc awards use the writ procedure. International commercial character alone does not change that route. Tribunal, administration and express-agreement issues are examined under the applicable law, without treating the award as foreign.

Case law: Supreme Court 20-KG23-11-K5, 2023 remanded following an erroneous requirement for ad hoc arbitration; Supreme Court 304-ES19-20506, 2020 itself refused enforcement for evasion of administration rules. The difference lies in the established facts.

Foreign awards and different legal consequences

Statutory basis: Convention Articles III–V, Chapter 31 of the Commercial Procedure Code / Chapter 45 of the Civil Procedure Code, and Articles 35–36 of Law 5338-1. Foreign institutional and ad hoc awards fall within the Convention system. A foreign institution’s lack of Russian authorisation does not replace prescribed foreign-award refusal grounds; Russian-seated administration raises a separate status question.

Case law: Supreme Court 305-ES17-993, 2017 remanded for examination of the agreement; Supreme Court 301-ES18-24455, 2019 itself refused for absent consent. See the complete review grounds, foreign enforcement procedure and separate evidence-assistance comparison.

The filing period: identify its starting point

Case law: paragraph 62 of Plenum 53 gives both a writ application and foreign-award recognition application a period not exceeding three years from the award or the end of its stated voluntary-performance period. This is a court-filing period, distinct from the three-month annulment period and the period for presenting an issued writ for execution.

Restoration is not automatic: submit a reasoned application with evidence of a valid excuse and perform the omitted procedural act at the same time. Read Civil Procedure Code Article 409(3) and Article 112, or Commercial Procedure Code Article 246(2) and Article 117. For arbitral awards, apply the Plenum’s starting-point explanation rather than mechanically copying the finality rule for state-court judgments.

Russian awards: court and documents

Statutory basis: Commercial Procedure Code Article 236 and Civil Procedure Code Article 423. An economic matter within commercial-court jurisdiction goes to a regional commercial court; a general-jurisdiction matter goes to a district court. Normally apply where the debtor is based or resides, or where its property is located if that is unknown. A permitted party agreement may select the court of the award’s seat or creditor’s location. Assess subject matter and participants together.

The package under Article 237 / Article 424 includes the application identifying the award and requested writ, a copy of the signed award, the original agreement or certified copy, fee evidence and representative authority. The Commercial Procedure Code separately requires evidence of sending the application to the other party; the Civil Procedure Code requires its copy. State the unpaid amount accurately and retain receipt/performance evidence.

Foreign awards: separate venue and package

Statutory basis: Commercial Procedure Code Article 242, Civil Procedure Code Article 410 and Article 416, and paragraph 14 of Plenum 53. Economic matters go to the regional commercial court; general-jurisdiction matters go to a regional-level court, such as an oblast court or federal-city court, rather than a district court. Venue follows the debtor or, where the statute permits, its property.

Under Convention Article IV, Commercial Procedure Code Article 242(4) and Civil Procedure Code Article 416(2), provide the duly authenticated award and agreement or appropriate certified copies, with the required certified Russian translation. Address fees, authority and procedural attachments. Do not replace the arbitral-award package with the separate foreign-state-court judgment list in Article 242(3).

Russia: comparing three models

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The comparison of court assistance in obtaining evidence does not cover the separate preservation-of-evidence mechanism. See paragraph 41 of Plenum Resolution 53.

Armenia: judicial enforcement and the special institutional route

In Armenia, both institutional and ad hoc awards seated there may be enforced, but a permanent institution can sometimes change the route itself. Code Article 321 provides for a judicial application where the special statutory application through the institution was unavailable. Commercial Arbitration Law Article 6(2) assigns the relevant supervisory and enforcement functions to the Yerevan first-instance civil court of general jurisdiction.

For direct electronic referral by the institution to the enforcement service, Article 35(4) cumulatively requires a permanent institution, an Armenian seat, parties consisting only of Armenian citizens or legal entities registered in Armenia, and recovery not exceeding 5,000 times the minimum wage. Its monetary equivalent is determined under the applicable calculation rules. Ad hoc proceedings, or a party who is not an Armenian citizen or Armenian-registered legal entity, do not satisfy those cumulative conditions.

Under Article 35.1, an application to the institution is made within one year of receipt, but no earlier than three months after receipt; if the institution no longer operates, the application goes to court. Under Article 35.3, a pending judicial annulment application or an award not yet binding leads the institution to leave the application unexamined. This is not unconditional enforcement of every institutional award.

For an Armenian award, Code Article 321(4) gives one year from receipt for the judicial application; for a foreign award requiring enforcement, Article 326(4) gives three years from entry into force. Foreign institutional and ad hoc awards follow recognition and enforcement under Law Articles 35–36, the Convention and the applicable reciprocity framework. Code Article 327(3) permits institutional certification of copies and provides for notarisation in ad hoc cases.

Annulment and enforcement are related but distinct: Code Article 323(6) provides for joint consideration of related applications, while paragraph 7 restricts later annulment after submission for enforcement, subject to an exception for obstacles beyond the applicant’s control. Law Article 35.4(4) has a separate rule for the direct institutional route. Annulment timing should therefore account for enforcement already initiated; see the national guide.

In Unibank, 12 January 2022, cassation itself restored the period for presenting writs already issued: the file did not establish proper delivery to the creditor. This illustrates a third distinct stage after the award and judicial permission to enforce—presenting the enforcement document. The historical one-year period applied there should not be treated as the current general rule for every enforcement procedure.

Belarus: domestic, international and foreign awards

For awards covered by Code Chapter 44—of domestic tribunals, international arbitral tribunals or other permanent arbitral bodies in Belarus—Article 492 provides a creditor’s writ application after non-performance, at the debtor’s location or, if unknown, its assets. Its specific filing period is six months after the period for voluntary performance expires, subject to restoration for a valid reason. An international name does not automatically make an award foreign.

Ad hoc form does not itself exclude a writ, but changes document requirements. Under Article 493(5), an ad hoc award copy requires notarised certification; a permanent institution’s chair may certify its award copy. The agreement, proof of non-performance and other attachments are also needed. Domestic ad hoc proceedings under Law 301-Z additionally require examination of the statutory justice-authority notification: procedural validity begins before the award, not merely with preparing copies.

Foreign awards follow Chapter 51, applicable treaties and Code Article 527. Paragraph 4 covers both an award made abroad and an award made in Belarus by a tribunal situated in a foreign State. The geographical place where the award was made is therefore not the only criterion. Articles 44–45 and 528 govern the court and venue; a foreign award does not automatically go to the same court as an Article 492 domestic writ application.

Setting aside awards covered by Code Chapter 41 is a separate application: Article 467 provides three months from receipt, with rules for post-award requests and restoration. The grounds in domestic Law 301-Z and international Law 279-Z differ. The court considering a foreign award applies the prescribed refusal grounds; the debtor’s Belarusian assets do not give it general authority to annul that award.

In Supreme Court case 156EIkh21155, 19 October 2021, refusal to enforce a Vilnius award was upheld: in the circumstances, claimant-location wording did not establish selection of that particular institution; pre-claim procedure also mattered. This concerns proof of the agreement at enforcement, rather than a prohibition of foreign or ad hoc arbitration. The case arose under the former commercial procedural code; current courts and periods follow the Code in force since 2026. See the Belarus guide.

Kyrgyzstan: writs, foreign recognition and limited annulment

For an award made in Kyrgyzstan, Code Article 418 provides for a writ from a district or equivalent court on the successful party’s application. Filing is within three years of the award at the debtor’s location, or its assets if that location is unknown. Law 135 Articles 40–41 distinguish voluntary and compulsory performance. This general model covers permanent and ad hoc tribunals without Russia’s authorised-institution distinction.

Form still matters: Law Article 35 requires notarised authentication of the arbitrators’ signatures on ad hoc tribunal acts. That differs from certification of the copy submitted under Code Article 419. The application includes the award, agreement, fee and authority documents, and proof that the application was sent to the other party. Russian formalities cannot substitute for these requirements.

For awards of foreign or international arbitrations made in a foreign State, Code Article 438 applies with its references to Articles 429–431 and 433–436, excluding Article 430(3); Article 439 contains refusal grounds. Certified award and agreement, authority, proof of sending to the debtor and a proper translation are required. “International” in the institution’s name does not replace Article 438’s territorial condition; institutional or ad hoc form does not remove scrutiny of documents and refusal grounds.

Ordinary finality under Law Article 28 differs from the special annulment procedure in Article 36¹, which concerns the State or municipal participation disputes specified in Article 28(2). For those cases, filing is within 30 days of the award at the tribunal’s location, and filing itself suspends execution. This is not general annulment of every Kyrgyz award. Article 41, as amended on 22 July 2026, separately refers Tamchy territory awards to its special enforcement framework.

The Constitutional Chamber decision of 9 December 2015 upheld the then-current finality rule linked to voluntary written selection of arbitration. It does not displace the 2025 reform or establish absence of judicial protection today: writ scrutiny, foreign-award recognition and statutory special annulment remain distinct. Compare the national guide and annulment and refusal.

Kazakhstan: two organisational models, domestic and foreign awards

Kazakhstan’s permanent and ad hoc arbitration operate under the same Law 488-V. Articles 54–55 make the award binding and require a state-court writ for compulsory enforcement when voluntary performance is absent. A foreign party does not make a Kazakhstan-made award foreign. Identify the place of the award, the applicable arbitration framework and the enforcement country separately; the AIFC Court and its framework require separate consideration.

Domestic awards follow Code Articles 253–255. The organisational model affects certification, among other things: a permanent institution’s head certifies its award copy, while an ad hoc award copy requires notarisation; the agreement is provided as an original or notarised copy. The application goes to a first-instance court, with district-court versus SMES jurisdiction determined by the parties under paragraph 18 of Supreme Court Resolution 3/2023. Article 253(3) provides three years after the voluntary-performance period expires, with restoration subject to statutory conditions.

A foreign award follows Code Articles 503–504, the relevant treaty and their conditions. Article 503 requires the certified award or its copy, the agreement if available, and a certified Kazakh or Russian translation where the documents are in another language. Applicable treaty requirements must also be checked, including New York Convention Article IV. A foreign ad hoc award does not become unenforceable merely because no permanent institution administered it; consent, procedure, binding effect and refusal grounds require examination.

Setting aside and refusing enforcement remain different outcomes. Code Article 464(2) assigns setting aside a Kazakhstan-made award to the relevant appellate court and separately addresses awards made abroad under Kazakhstan law. Paragraph 7 of Resolution 3 excludes national annulment of awards by foreign international commercial and investment tribunals through the procedure it describes. A Kazakhstan debtor therefore does not confer general power to annul a foreign award. Law 488-V Article 57(3) prohibits merits reconsideration when the court addresses refusal to issue a writ.

The practical authority is Supreme Court Resolution 3/2023. Paragraphs 44–45 require regard to treaty priority for foreign awards; where European Convention Article IX applies, the significance of annulment at the seat is limited to its specified grounds. I would not stop at the label “annulled” or the institution’s name: identify the governing treaty, the precise annulment ground and the complete supporting documents first. The country guide explains review grounds and deadlines further.

Moldova: domestic enforcement, international character and foreign awards

Domestic arbitration under Law 23/2008 and international commercial arbitration under Law 24/2008 are different statutory regimes. An international dispute does not necessarily produce a foreign award. Code Article 475(1) classifies an award made abroad as foreign, as well as one made in Moldova where foreign law governed the arbitral procedure. The hearing location alone is therefore insufficient: identify the legal seat and the procedural law applied.

An award falling within the domestic enforcement route follows Chapter XLIV, Code Articles 482–486: the writ is issued by the court that would hear the dispute without the clause. Article 483(4) distinguishes certification of award copies: the permanent tribunal’s president certifies an institutional copy, while an ad hoc copy requires notarisation. The agreement, prescribed payments, application copies and proof of authority are also required. An institution’s name does not replace checking the basis for issuing a writ, and ad hoc status does not preclude that route.

A foreign institutional or ad hoc award is presented for recognition and enforcement under Code Articles 475–476 and the applicable treaty. Article 475¹ sends the application to a court of appeal with the prescribed connection to the debtor or assets; the general deadline is three years from the award becoming binding under the law of the arbitration’s location. Check the award, agreement, certification, legalisation requirements with treaty exceptions, and Romanian translation. This differs from applying to a judecătorie for a domestic writ.

The enforcement court does not replace the annulment court. Law 24/2008 Article 37 governs setting aside in international arbitration seated in Moldova, together with the Code; Article 1 does not extend that route to every foreign award. On a foreign-award application, the Moldovan court examines Article 476 refusal grounds, including annulment or suspension by the competent authority. Where annulment remains pending, Article 476(7)–(9) provides for adjournment or suspension, rather than automatic reconsideration of the dispute’s merits.

In CSJ case 2r-570/23 of 23 July 2024, recognition of a Russian ICAC award was upheld after the Moldovan court independently assessed enforcement conditions and the limits of review. In case 2r-525/2020, enforcement of a Belarusian award survived examination of the particular notice evidence. These cases demonstrate why procedural proof matters alongside the award itself. New Law 198/2026 takes effect on 1 March 2027; this comparison concerns the provisions applicable before that date.