China

1.1 Advantages

The advantages of arbitration in China (for the purposes of this handbook, not including Hong Kong Special Administrative Region (SAR), Macau SAR and Taiwan Region) include the following:

• Party autonomy. China allows a high degree of party autonomy in arbitration. The parties may design the arbitration proceedings to meet their special needs by agreeing on the organisation of hearings, submissions of proof, and presentations of arguments.
• Final and binding. In China, arbitral awards become final and binding on the parties as soon as they are rendered.
• Efficiency. Taking cases in the China International Economic and Trade Arbitration Commission (CIETAC) as an example, as revealed by CIETAC, hearings of most cases only take one to three days, and most cases can be closed within six months after the tribunal is formed.
• Confidentiality. Arbitration proceedings are not open to the public.

1.2 Disadvantages and common pitfalls

• No appeal. On the one hand, the feature of final and binding makes arbitral awards very stable in China. On the other hand, however, it is very challenging to overturn wrong or “bad” arbitral awards, especially those that have no procedural defects.
• Efficiency of courts’ support. Compared with litigation, arbitration attracts less attention and support from Chinese courts in respect of property preservation and other interim measures. The exchange of documents between arbitral institutions and courts takes extra time, and many courts’ enforcement departments prefer to handle the same kind of application made in litigation cases first.

1.3 Distinctive features

Institution-administered arbitration is a strong feature emphasised by Chinese law. The current Arbitration Law now does not recognise ad hoc arbitration as a general practice. However, certain local legislations, such as those applicable in the Shanghai Free Trade Zone, permit ad hoc arbitration under specific conditions. The latest revision draft of the Arbitration Law also provides for rules related to ad hoc arbitration.

2.1 Legal framework

The legal framework of arbitration in China is generally composed of the following legal provisions:

• Arbitration Law (latest revision in 2017, under revision now).
• Civil Procedure Law (latest revision in 2023).
• Relevant judicial interpretations. Judicial interpretations are a set of rules formulated by the Supreme People’s Court (SPC) to harmonise the courts’ understanding of specific legal provisions and to unify the trial standards. Judicial interpretations have to be reviewed and filed by the National People’s Congress (NPC), and they have equal effect to the law in practice. Some judicial interpretations closely related to arbitration are:
  • Interpretation of the SPC on the Application of the Arbitration Law (latest revision in 2008, “Judicial Interpretation of the Arbitration Law”).
  • Interpretation of the SPC on the Application of the Civil Procedure Law (latest revision in 2022, “Judicial Interpretation of the CPL”).
  • Provisions of the SPC on Several Issues relating to the Hearing of Cases Involving Judicial Review of Arbitration (Fa Shi [2017] No.22).
  • Provisions of the SPC on Several Issues relating to the Handling of Cases Involving Enforcement of Arbitral Awards (Promulgated in 2018).
• Conference summaries. The SPC holds symposiums on different issues and publishes conference summaries from time to time. Such conference summaries are not judicial interpretations and cannot be cited by judges in their judgments, but the rules indicated therein should be followed by all judges. The latest conference summary related to arbitration is the Conference Summary of the Symposium on Foreign-related Commercial and Maritime Trials of Courts Nationwide (promulgated in 2022, “Conference Summary 2022”).
• Bilateral treaties and international conventions, including the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (“New York Convention”) and the Convention on the Settlement of Investment Disputes Between States and Nationals of Other States (“ICSID Convention”).

2.2 What qualifies under domestic law as “international arbitration”? Is there a specific statute?

The term “international arbitration” is not explicitly defined in Chinese law. In practice, it generally refers to arbitration not governed by Chinese law, especially that administered by arbitration institutions outside China and ad hoc arbitration. In addition, the term “international commercial arbitration” can be found in the arbitration rules of some Chinese arbitration institutions, which generally overlap with foreign-related arbitration below.

As to arbitration governed by Chinese law, there are distinctions between non-foreign-related/domestic and foreign-related arbitration.

In Chinese law, “foreign-related” is a special term describing arbitration, litigation, legal relations, etc. Although there is no definition of “foreign-related arbitration” in the Arbitration Law, the definition of the term “foreign-related” is indicated in Article 522 of the Judicial Interpretation of the CPL, which is utilised to distinguish foreign-related arbitration in practice.

2.3 Ratification of the New York Convention

China ratified the New York Convention in 1987 with certain reservations.

2.4 Ratification of the ICSID Convention

China ratified the ICSID Convention in 1992 with certain reservations.

2.5 Other treaties relating to arbitration

China has 37 bilateral treaties with different countries, 28 of which have provisions relating to arbitration. In addition to bilateral treaties, there are arbitration-related bilateral arrangements between the Mainland of China and Hong Kong SAR, Macau SAR and Taiwan Region, respectively.

2.6 Choice of forum for intra-EU dispute settlement

Not applicable to China.

2.7 Is the municipal law governing arbitration based on UNCITRAL Model Law?

The municipal law governing arbitration is not based on the UNCITRAL Model Law, but the latest revision draft of the Arbitration Law draws some lessons from it.

2.8 Recent amendments or reforms in arbitration laws

The Arbitration Law is under revision now. Please see below, Section 18.

3.1 Presence of local arbitration institutions

China has established 282 arbitration institutions, among which CIETAC is more familiar to foreign parties in general as China’s first arbitration institution, established in 1956. On 1 January 2024, CIETAC’s latest arbitration rules took effect.

3.2 Does the London Court of International Arbitration (LCIA) have a local office?

No.

3.3 Does the Permanent Court of Arbitration (PCA) have a local office?

No.

3.4 Does the ICC International Court of Arbitration have a local office?

The ICC International Court of Arbitration has a local office in Shanghai.

3.5 Does the International Centre for Dispute Resolution (ICDR) have a local office?

No.

3.6 Agreement entered into with local offices of international arbitration institutions

Not available to the public.

4.1 Requirements as to content and form

Regarding the content, a valid arbitration agreement under the Arbitration Law must contain:

• an express willingness to arbitrate;
• the matters being referred to arbitration; and
• a designated arbitration institution.

Regarding the form, a valid arbitration agreement can be incorporated into or can be separate from a contract. It should be in writing, including electronic data exchange, email, etc. Reference to an arbitration clause contained in another contract is allowed.

4.2 Validity of arbitration agreements

Pursuant to Article 17 of the Arbitration Law, an arbitration agreement will be invalid under the following circumstances:

• the agreed matters for arbitration exceed the range of arbitrable matters as specified by law;
• a party that concluded the arbitration agreement has no capacity or limited capacity for civil conduct; or
• a party coerced another party into concluding the arbitration agreement.

Without the above circumstances, if an arbitration agreement provides that the dispute can be submitted to either an arbitration institution or a Chinese court, it is invalid pursuant to Article 7 of the Judicial Interpretation of the Arbitration Law.

In addition, an arbitration agreement submitting a non-foreign-related/domestic dispute to places outside China for arbitration is invalid.

4.3 Special formalities

Not applicable.

4.4 Governing law

The governing law of an arbitration agreement, which is independent from other parts of the contract, should be determined in the following order, pursuant to Article 16 of the Judicial Interpretation of the Arbitration Law: (1) the law as agreed upon by the parties; (2) the law of the place of arbitration, if the parties do not reach agreement on the governing law but reach agreement on the place of arbitration; or (3) the law of the place where the court is located, if the parties do not reach agreement on either the governing law or the place of arbitration.

5.1 Applicable restrictions

Pursuant to Article 3 of the Arbitration Law, the following disputes are not subject to arbitration:

• disputes concerning marriage, adoption, custody, fostering and succession; and
• administrative disputes which shall be dealt with by administrative organs.

In practice, disputes arising from an administrative agreement concluded with administrative organs are administrative disputes not subject to arbitration. Typical administrative agreements include:

• government franchise agreements;
• compensation agreements for expropriation and requisition of land and houses;
• agreements on transfer of the right to use state-owned natural resources, such as mining rights;
• agreements on the leasing and sales of government-invested indemnificatory housing; and
• public–private partnership agreements that meet certain requirements.

6.1 Stay of proceedings

On the one hand, Chinese courts shall not accept a case with a valid arbitration agreement. If any party to a valid arbitration agreement submits the dispute to Chinese courts for litigation, the court shall dismiss the case if the other party objects to the court’s jurisdiction with the arbitration agreement before the first hearing.

On the other hand, Chinese courts will review the validity of an arbitration agreement if any party of the agreement makes such an application. The arbitration proceeding shall be suspended until the court upholds the validity of the arbitration agreement.

6.2 Anti-suit injunctions

There is currently no provision on anti-suit injunctions under Chinese law.

7.1 Restrictions on the parties’ freedom to choose arbitrators

Chinese law does not impose any restrictions on the parties’ freedom to choose arbitrators.

In practice, the arbitration rules of different arbitration institutions may require the parties to choose an arbitrator from the panel of arbitrators of that institution.

7.2 Requirement of arbitrator independence and impartiality

Pursuant to Article 34 of the Arbitration Law, the arbitrator must withdraw, and the parties also have the right to challenge the arbitrator for withdrawal, in any of the following circumstances:

• the arbitrator is a party in the case or a close relative of a party or such party’s representative in the case;
• the arbitrator has a personal interest in the case;
• the arbitrator has another form of relationship with a party or the party’s representative in the case, which may affect the impartiality of the arbitration; or
• the arbitrator has privately met with a party or such party’s representative or accepted an invitation to entertainment or a gift from the same.

In addition, arbitration institutions generally have guides or requirements on arbitrators’ independence and impartiality.

7.3 Mandatory rules applicable to the appointment process

Pursuant to Articles 30 and 31 of the Arbitration Law: (1) for an arbitral tribunal composed of three arbitrators, each shall choose or entrust the chairperson of the arbitration commission to choose one arbitrator respectively, and the third/presiding arbitrator shall be chosen by the parties jointly or the chairperson of the arbitration commission with the parties’ joint entrustment; and (2) for an arbitral tribunal composed of only one arbitrator, the arbitrator shall be chosen by the parties jointly or the chairperson of the arbitration commission with the parties’ joint entrustment.

In practice, the arbitration rules of different arbitration institutions generally have more detailed provisions on the appointment process.

7.4 Appointment mechanism in the absence of party agreement or applicable institutional rules

Chinese law does not provide for an appointment mechanism in the absence of party agreement or applicable rules.

In practice, the arbitration rules of different arbitration institutions generally have detailed provisions on this issue.

7.5 Mandatory rules applicable to the replacement process

Apart from Article 37 of the Arbitration Law, providing that the replacing arbitrator shall be chosen pursuant to relevant provisions of this law, there are no mandatory rules applicable to the replacement process under Chinese law.

In practice, the arbitration rules of different arbitration institutions generally have detailed provisions on this issue.

7.6 Mandatory disclosure obligations

There are no mandatory disclosure obligations under Chinese law.

In practice, the arbitration rules of different arbitration institutions generally have detailed provisions on this issue.

7.7 Grounds for challenge

Please see above, Section 7.2.

7.8 Mandatory rules governing the challenge of arbitrators

Please see above, Section 7.2.

7.9 Removal

Pursuant to Article 38 of the Arbitration Law, an arbitrator will be removed from the panel of arbitrators of the arbitration commission if they have privately met with a party or such party’s representative or accepted an invitation to entertainment or a gift from the same and the circumstance is serious, or they have accepted bribes, resorted to deception for personal gain or perverted the course of justice by the award.

In practice, the arbitration rules of different arbitration institutions generally have detailed provisions on this issue.

7.10 Liability and immunity of arbitrators

In addition to Article 38 of the Arbitration Law mentioned above, Article 399-1 of the Criminal Law provides for the crime of perverting the law in arbitration with the highest sentence of seven years’ imprisonment.

Apart from such provisions, Chinese law does not provide for other liabilities of the arbitrator, including civil liabilities of compensation.

8.1 Interim measures

8.1.1 Overview of interim measures

The term “interim measure” is not indicated in Chinese law. In arbitration governed by Chinese law, Chinese courts provide assistance in terms of property preservation and evidence preservation pursuant to Articles 28, 46 and 68 of the Arbitration Law and other applicable provisions of the Civil Procedure Law and relevant judicial interpretations.

In addition, the latest revision draft of the Arbitration Law provides that the parties in arbitration can apply for act preservation as well. Act preservation is a mandatory measure of the court to order a party to do or refrain from doing certain acts in order to avoid damage to the other party pending an effective judgment of the case, which is highly similar to injunctions in other jurisdictions.

As to arbitration cases not governed by Chinese law, Chinese courts do not provide assistance related to preservation or interim measures.

8.1.2 Relevance of availability of emergency arbitrator mechanism

There is currently no provision on emergency arbitrator mechanisms under Chinese law. CIETAC and other Chinese arbitration institutions have rules on emergency arbitrators.

8.2 Taking of evidence

As mentioned above, the parties can apply to Chinese courts for evidence preservation in arbitration. In practice, however, effective evidence preservation is quite difficult to achieve, so Chinese courts are usually very cautious to approve it.

8.3 Appointment or challenge of arbitrators

Chinese courts can set aside or refuse to enforce arbitral awards if the formation of the arbitral tribunal does not conform to the applicable arbitration rules. Apart from that, Chinese courts do not provide assistance on this issue.

8.4 Other available assistance

No other types of assistance to arbitrations are commonly available.

9.1 Domestic scope of sovereign immunity from jurisdiction

On 1 September 2023, the Standing Committee of the NPC of China enacted the Foreign State Immunity Law (FSIL), which came into effect on 1 January 2024. Exceptions include commercial activities (Article 7), labour contracts (Article 8), tortious acts (Article 9), and certain investment dispute arbitration matters (Article 12). As the FSIL is newly implemented, no publicly reported cases have yet illustrated its practical application.

9.2 Immunity from execution

Under FSIL, foreign state property in China is generally immune from judicial enforcement, except in cases specified under Article 14. Exceptions include express waivers of immunity through treaties or agreements, allocation or designation of property for enforcement, and property used for commercial activities directly related to the dispute. Article 15 provides further protection for certain properties, such as those used by diplomatic or military missions, foreign central bank assets, and cultural or historical items not intended for sale, which remain immune from enforcement.

The minimum procedural requirements for arbitration include the following aspects.

10.1 Form and requirements for hearings

Under the Arbitration Law, arbitration hearings are typically conducted in session, meaning formal in-person proceedings with parties and arbitrators. However, if both parties agree, the arbitral tribunal may render an award based on written submissions. Following the COVID-19 pandemic, arbitral institutions in China have widely adopted virtual hearings as a form of in-session proceedings, which are considered equivalent to in-person hearings rather than written adjudication.

10.2 Rules governing non-participation

If the claimant fails to appear without justification, the arbitration is deemed withdrawn. If the respondent fails to appear, the tribunal may proceed by default and issue an award.

10.3 Composition of the arbitral tribunal

The Arbitration Law stipulates that an arbitral tribunal may be composed of three arbitrators or a sole arbitrator. For a three-member tribunal, a presiding arbitrator must be appointed. Accordingly, Chinese arbitration institutions do not permit tribunals composed of an even number or any other number of arbitrators.

Article 40 of the Arbitration Law explicitly provides: “Arbitration shall not be conducted publicly”. This establishes arbitration as confidential by default, with public hearings permitted only by mutual agreement and in non-sensitive cases. Chinese arbitration rules further clarify that all information—hearing details, submissions, and awards—must remain confidential and apply to all participants. However, in certain cases, such as investment arbitration, a degree of transparency may be required under international practices (e.g., the UNCITRAL Rules on Transparency).

12.1 Requirements as to content and form

Article 54 of the Arbitration Law provides: “The arbitral award shall specify the claims, the facts of the dispute, the reasons for the award, the outcome of the award, the allocation of arbitration costs, and the date of the award. The award shall be signed by the arbitrators and affixed with the seal of the arbitration institution”. In practice, arbitral institutions may adopt internal guidelines to further standardise awards and ensure their quality and consistency; however, these guidelines are generally not mandatory.

12.2 Time limit

The Arbitration Law does not mandate a time limit for rendering awards, but arbitration rules typically set deadlines. For example, the 2024 CIETAC Rules require awards within six months (Article 51(1)) or three months for expedited procedures (Article 65(1)). Extensions are allowed with institutional approval, and in practice, they are often granted for complex cases.

12.3 Remedies

Under arbitration practice, tribunals may grant various remedies tailored to the dispute and subject to the arbitration agreement and applicable law. Common remedies include: monetary compensation; specific performance; declaratory relief; interest or cost allocation; liquidated damages; and other measures such as injunctive relief.

Tribunals’ authority to grant remedies is bound by the arbitration agreement and governing law. For example, under Chinese law, punitive damages are generally unavailable unless explicitly permitted. Tribunals often consider Chinese judicial practices to ensure enforceability and may decline relief that faces significant enforcement challenges in Chinese courts.

13.1 Interpretation and correction of awards

Under the Arbitration Law, tribunals may correct typographical or calculation errors in an award or address omitted matters. Such corrections may be initiated by the tribunal itself or requested by a party within 30 days of receiving the award. Typically, corrections are limited to minor issues, such as typographical or calculation errors. Chinese law does not expressly grant parties the right to request an interpretation of an arbitral award from the tribunal.

13.2 Challenge of an award

Parties may challenge an arbitral award by applying to set it aside or refuse its enforcement. Under Article 58 of the Arbitration Law, a party may set aside an award within six months if there is no arbitration agreement, if the award exceeds the agreed scope, if procedural violations occur, or if evidence is fabricated or concealed, or if there is arbitrator misconduct. Awards violating public policy may also be set aside. Under Article 63 of the Arbitration Law and Article 248 of the Civil Procedure Law, courts may refuse enforcement on the same grounds. For foreign-related awards, the grounds for challenge are narrower, such as the absence of an arbitration agreement, failure to notify the respondent, or procedural non-compliance, with enforcement also subject to public policy considerations.

13.3 Recognition and enforcement proceedings

For arbitral awards rendered by domestic arbitration institutions, regardless of whether they are foreign-related or not, no recognition process is required. Parties can directly apply to the people’s court for enforcement.

For arbitral awards rendered by foreign arbitration institutions (including those in Hong Kong SAR and Macau SAR), parties must apply for recognition and enforcement in Chinese courts, pursuant to the New York Convention.

13.4 Cost of enforcement

Parties applying for enforcement of an arbitral award or mediation statements must pay fees based on the execution amount:

• No execution amount/value: RMB 50–500 per case.
• Up to RMB 10,000: RMB 50 per case.
• Exceeding RMB 10,000–500,000: 1.5%.
• Exceeding RMB 500,000–5,000,000: 1%.
• Exceeding RMB 5,000,000–10,000,000: 0.5%.
• Exceeding RMB 10,000,000: 0.1%.

However, these fees are not required to be prepaid by the applicant but are instead deducted directly from the enforcement proceeds.

13.5 Enforcement of orders of emergency arbitrators

In China, the emergency arbitrator mechanism has gradually been introduced and applied in arbitration practice. However, there are currently no explicit provisions in Chinese law regarding the enforcement of emergency arbitrator orders, so interim measures or decisions by emergency arbitrators may face enforcement challenges.

14.1 Process for enforcing New York Convention awards

China is a contracting state to the New York Convention. For arbitral awards rendered by arbitration institutions of other contracting states, applicants may submit an application for recognition and enforcement to the intermediate people’s court at the location of the respondent’s domicile or the location of the respondent’s assets.

14.2 Grounds for resisting enforcement of New York Convention awards

The Conference Summary 2022 specifies that Chinese courts must strictly adhere to the grounds for refusal under Article V of the New York Convention when reviewing applications for recognition and enforcement of foreign arbitral awards. Courts will not examine grounds not raised by the respondent or grounds beyond the scope of Article V. With respect to public policy, enforcement is refused only if the award egregiously violates China’s fundamental legal principles, national sovereignty, security, or public interests. Additionally, any lower court intending to refuse enforcement must have its decision reviewed and approved by the SPC.

14.3 Enforcing non-Convention awards

For foreign arbitral awards not covered by the New York Convention, Chinese courts rely on judicial assistance treaties or, in their absence, the principle of reciprocity and compliance with Chinese law. Enforcement of such awards often faces greater legal hurdles.

15.1 Applicable to counsel

In China, attorneys acting as representatives in arbitration proceedings are required to comply with the applicable laws and relevant professional standards, such as the Code of Conduct for Lawyers and the Basic Rules of Lawyers’ Professional Ethics. Violations may result in disciplinary actions—including warnings, suspension, or revocation of the licence—and, in cases of criminal misconduct, may also lead to criminal liability.

15.2 Applicable to arbitrators

In China, arbitrators must comply with the Arbitration Law and ethical guidelines set by arbitration institutions. For example, CIETAC’s Code of Conduct requires arbitrators to remain independent and impartial, disclose conflicts of interest, diligently prepare for cases, treat parties equally, avoid impropriety, maintain confidentiality, adhere to procedural rules, and possess the necessary professional competence to ensure the legality and credibility of awards. Arbitrators who fail to meet these obligations may be removed from the arbitrator panel and, if they engage in criminal conduct such as accepting bribes, may also face criminal liability.

16.1 Applicable regulatory requirements

There are no specific laws governing third-party funding in Mainland China. However, some arbitration institutions, such as CIETAC, include provisions on third-party funding in their rules (e.g., Article 27 of its Rules on International Investment Disputes Arbitration). On 4 November 2022, the Beijing Fourth Intermediate People’s Court, in case No. (2022) Jing 04 Min Te 368, affirmed that existing laws do not prohibit third-party funding in arbitration—marking the first explicit recognition by a Chinese court. Previously, litigation funding was generally viewed negatively for conflicting with the public nature of judicial activities.

16.2 Overview of the third-party funding market

Despite the lack of clear legal regulations, interest in third-party funding is growing in China, with professional organisations and investors increasingly offering financial support to parties facing high arbitration or litigation costs. However, the market remains in its infancy due to an underdeveloped regulatory framework, with current practices mainly concentrated in specialised areas such as international investment arbitration. This growing interest highlights the potential of third-party funding in China’s dispute resolution landscape and underscores the need for comprehensive legal and regulatory frameworks for its sustainable development.

While China is not particularly renowned for any single type of arbitration, it has developed mature practices and institutions in various specialised fields. Specialist arbitration is mainly reflected in two ways: establishing specialised sub-centres within comprehensive institutions (e.g., the South China High-Tech and Intellectual Property Arbitration Centre under SCIA) and developing industry-specific rules (e.g., BAC’s rules for international investment arbitration and construction engineering disputes).

17.1 Types of specialist arbitration

China’s specialist arbitration covers the following areas:

• Intellectual property and high-tech arbitration. For example, the South China High-Tech and Intellectual Property Arbitration Centre under the SCIA and the Digital Economy Arbitration Centre of the BAC.
• Construction engineering arbitration. The BAC has developed specialised rules for disputes in construction projects.
• Maritime arbitration. The China Maritime Arbitration Commission (CMAC) specialises in resolving disputes in the shipping and maritime sectors.
• International investment arbitration. The BAC offers tailor-made arbitration rules for resolving international investment disputes.
• Other areas. For instance, disputes in the film, entertainment and sports

17.2 Key legal principles

Established in 1959, the China Maritime Arbitration Commission has a long history. In maritime arbitration, key legal principles include party autonomy, procedural fairness, and the application of maritime law and relevant international conventions. Maritime arbitration is generally conducted in accordance with the Maritime Law of the People’s Republic of China and other applicable regulations, while upholding freedom of contract and resolving disputes as provided in the arbitration agreement. Arbitral tribunals in maritime cases also consider international maritime customs to ensure that awards conform both to domestic law and international standards.

17.3 Types of claim and defences typically brought in that area

Common disputes in maritime arbitration include cargo damage, charter party disputes, disagreements over freight and demurrage payments, and breaches of transportation contracts. Typical defences involve force majeure (e.g., adverse weather or other unforeseen events), inadequate vessel maintenance, deviation, or reliance on contractual limitation of liability clauses. Parties may argue that unforeseen events caused their losses, while the opposing party may invoke contractual provisions to strictly allocate liability, thereby balancing the responsibilities of the parties.

17.4 Issues and strategic considerations to take note of

In Chinese arbitration practice, most institutions adopt a closed panel system, requiring parties to select arbitrators from a predefined list. In specialist arbitration, parties should carefully assess arbitrators’ qualifications and expertise to ensure suitability for the dispute.

On 4 November 2024, the latest revision draft of the Arbitration Law was released for public opinion. Some major revisions are set out in brief as follows:

• Act preservation. Article 36 of the revision draft extends the available support from Chinese courts for act preservation, covering all preservation measures under the Civil Procedure Law.
• Seat of arbitration. The current Arbitration Law does not define the seat of arbitration. Article 78 of the revision draft introduces this concept and provides that the law of the seat will apply to the arbitral procedure and determine the “competent court”.
• Ad hoc Article 79 of the revision draft introduces the concept of ad hoc arbitration in two types of foreign-related cases: (1) disputes arising from foreign-related maritime matters; and (2) foreign-related disputes among enterprises registered in free trade zones. 
• Foreign arbitration institutions. Article 83 of the revision draft provides that foreign arbitration institutions may establish their business branch in free trade zones to conduct “foreign-related arbitration activities”.