Annulment And Vacatur: Challenging ICSID And Non-ICSID Awards

This article was first published by Global Arbitration Review in October 2025 and can be accessed at GAR Guide to Investment Treaty Protection and Enforcement Third Edition

Introduction

Finality of an award is not just a desired but an essential feature of international arbitration; however, such finality must be balanced with the need to ensure the sanctity and integrity of the arbitral process.¹ Accordingly, as considered in this chapter, both International Centre for Settlement of Investment Disputes (ICSID) and non-ICSID treaty awards are subjected to limited grounds for challenge within fixed limits.²

The scope of the grounds for challenging an investment treaty award depends on whether the arbitration is governed by the ICSID Convention.³