London and Stockholm: Attractive arbitration hubs for corporate disputes

Arbitration has an important role to play in resolving cross-border corporate disputes. For commercial parties dealing with claims arising from shareholder agreements and joint ventures or post-acquisition warranty claims, arbitration offers a combination of neutrality, enforceability and procedural adaptability that is difficult to replicate in national litigation. As arbitration’s advantages are shaped, in part, by the procedural framework of the arbitral seat, the choice of seat is a strategic decision for international parties.

London and Stockholm have both long been recognised for their stable legal frameworks, arbitration-friendly courts and respected institutions. Their significance extends beyond regional use in England and Sweden. 1  Both legal systems are ranked among the top five most preferred seats of arbitration for European users. 2

Arbitration in England and Sweden rests on the same foundations. Proceedings are private, party autonomy is respected, arbitrators are selected for their expertise, and awards benefit from international enforceability under the New York Convention. These features underpin arbitration’s appeal across both jurisdictions.

The English Arbitration Act 1996 (as amended by the Arbitration Act 2025) is a detailed and structured framework with extensive procedural provisions. The courts have a supervisory role, with powers to support arbitrations, including in relation to the taking or preservation of evidence and granting interim relief. The 1996 Act also has defined but limited grounds for challenge of awards, including jurisdiction, serious irregularity and points of law. This structure ensures a balance between autonomy and judicial oversight.

The Swedish Arbitration Act (1999:116) is brief, permissive and designed to give maximum room to party autonomy, permitting court intervention only where strictly necessary (e.g. to ensure due process and to provide narrow grounds for challenging awards). Swedish law provides for the invalidation of an award that is incompatible with the basic principles of the Swedish legal system or that does not fulfil certain other statutory requirements designed to safeguard public and third-party interests. Grounds for setting aside the award are similarly limited in scope.  Like the English courts, Swedish courts can grant interim measures in support of arbitration, including ordering provisional attachments and urgent injunctions.

Both England and Sweden offer reliable procedures for the enforcement of arbitral awards, supported by the New York Convention, and neither jurisdiction provides a right of appeal on the merits (offering parties some finality).

London and Stockholm are both home to well-established and internationally recognised international institutions. London’s arbitration landscape is closely associated with the London Court of International Arbitration (“LCIA”), while Stockholm’s is anchored by the Stockholm Chamber of Commerce (“SCC”). Both institutions administer a significant number of cross-border disputes involving parties from a wide range of jurisdictions. In 2024, the LCIA registered 318 arbitrations, with 95% of cases involving international parties from 101 jurisdictions. In 2025, the SCC registered 213 new cases (50% international, 50% domestic), involving 568 parties from 50 countries.  3

Both systems are capable of handling corporate disputes. In 2024, 15% of the LCIA’s cases involved shareholders, share purchase or joint-venture agreements,  4  and in 2025, agreements for ‘business acquisitions’ made up over 25% of the types of agreements in the SCC’s cases, with ‘purchase agreements’ and ‘company agreements’ making up nearly another 25%.

These two institutions are regarded as credible, neutral and reliable forums for resolving cross-border corporate disputes.

Both the LCIA and the SCC provide mechanisms for expedited proceedings and emergency relief, reflecting a shared institutional focus on enabling parties to resolve disputes quickly where circumstances require it. These mechanisms can prove valuable in time-sensitive corporate disputes such as earn-out disagreements or shareholder deadlocks.

In Stockholm, expedited arbitration has become particularly prominent, with a striking 38% of SCC cases in 2025 (82 in total) issued under the Expedited Arbitration Rules. 5  Those rules provide a streamlined procedure designed to deliver a final award within six months. In practice, nearly half of the expedited cases have been finalised within just three months. The SCC Rules also provide for the appointment of an Emergency Arbitrator empowered to order interim measures before the tribunal is constituted. There were three Emergency Arbitrator cases in 2025. 

Under the LCIA Rules 2020, parties may apply for expedited formation of the tribunal or appointment of an Emergency Arbitrator. In 2024, parties made 19 such applications, representing a smaller proportion of the LCIA’s overall caseload than its Swedish counterpart (approximately 6%). The threshold for “urgency” is also high. Only two applications were granted (one under each tool). 6

Where the parties have not chosen any institutional rules, the 1996 Act empowers arbitrators to impose expedited procedures and to dispense with procedures that are not appropriate. 7  The 2025 Act also confirms an arbitrator’s power to make summary awards if a party has “no real prospect” of success on an issue (unless the parties agree otherwise). 8  This tool could significantly improve arbitral efficiency.                                             

Beyond rules and institutions, the procedural culture of arbitration reflects the fact that England & Wales is a common law jurisdiction while the law of Sweden is a civil law system. In English-seated arbitration, proceedings tend to be more adversarial, with a stronger emphasis on oral hearings, witness evidence and cross-examination. While disclosure is typically narrower in English litigation, it can still be more extensive than in many other civil law systems.

Swedish arbitration proceedings tend to be more document-driven with cases developed principally through written submissions and documentary evidence. Oral hearings, while available and regularly held, are typically shorter than in English-seated arbitrations. 

Confidentiality has long been a cornerstone of arbitration, and its protection can be crucial in corporate disputes, which may concern sensitive commercial information such as valuation data or management performance.

In England, confidentiality in arbitration is an implied obligation (not imposed by statute), though parties often include confidentiality provisions in their arbitration agreements or through institutional rules, including the LCIA Rules. 9

This contrasts with the English court system, which adheres to the principle of open justice, with court proceedings usually open to the public and judgments on the public record. The courts are moving towards greater transparency by adopting a scheme to make documents more easily available to the public. 10  In view of this increased transparency, arbitration may become a more attractive route for corporates seeking to maintain confidentiality and greater control over the dissemination of their information.

Confidentiality in Sweden is similarly not imposed by statute, but rather is deeply embedded in Swedish arbitral practice and reflected in the SCC Rules. 11

For parties engaged in corporate disputes – where confidentiality can be critical to preserving value – arbitration seated in either London or Stockholm allows parties to avoid public proceedings.

London and Stockholm both offer highly developed and reliable arbitration frameworks with the enforceability of awards assisted by the New York Convention. Each jurisdiction is supported by experienced, efficient and pro-arbitration courts and modern, respected institutions. 

Parties negotiating governing law and jurisdiction clauses in shareholder, joint venture or post-acquisition documents should consider at an early stage whether litigation or arbitration is preferable for dealing with any dispute that may arise. If arbitration is chosen, the parties should then give proper thought to the seat of the arbitration and the institutional rules they wish to adopt. Addressing those issues at the drafting stage should reduce uncertainty later and help ensure that the dispute resolution mechanism is aligned with the commercial objectives of the parties.