2025 Arbitration Year in Review
[First published on Daily jus on 19.02.2026]
MIDDLE EAST & NORTH AFRICA - Lebanon
Beirut’s legal heritage is often evoked through the expression Berytus Nutrix Legum (“Beirut, Nourisher of Laws”), which the Beirut Bar Association has adopted as its official motto. The phrase recalls the city’s ancient Law School of Berytus—widely regarded as one of the earliest formal law faculties—which flourished during the Roman Empire and famously hosted jurists such as Ulpian and Papinian. While the city’s legal preeminence has dimmed over the centuries, particularly in light of Lebanon’s recent crises, 2025 offered several signs of a renewed and more modern role for Beirut within the regional arbitration landscape.
A major development was the inaugural of Beirut Arbitration Days, which drew an unprecedented gathering of regional and international practitioners. The event marked the first coordinated effort in years to insert Beirut into the broader arbitration map through substantive panels, institutional participation, and cross-border engagement.
On the institutional front, both of Beirut’s principal arbitral institutions advance important reforms. The LAMC (Lebanese Arbitration & Mediation Centre of the Beirut and Mount-Lebanon Chamber of Commerce) continued to consolidate its position following its 2024 Arbitration Rules overhaul, while the LIAC-BBA (Lebanese and International Arbitration Center of the Beirut Bar Association) presented its new Arbitration Rules in the 2025 Beirut Arbitration Days, further aligning Beirut-based arbitration with contemporary international standards and reinforcing institutional pluralism in the market.
Finally, on the disputes' side, investor–state matters involving Lebanon remained active, while several Lebanon-seated commercial arbitrations tackled questions arising from the country’s financial collapse—particularly the duties owed by banks and financial institutions to their clients, these cases increasingly turned Beirut into a forum for resolving crisis-related commercial disputes. This reflects both necessity and the growing maturity of the local arbitral framework.
Market Highlights
Despite persistent macro-economic headwinds and institutional strain on the court system, Beirut continued to entrench its profile as a regional arbitration forum in 2025. The inaugural Beirut Arbitration Days (20–22 May 2025) convened a large regional and international audience and featured the public presentation of the updated LIAC-BBA (Lebanese and International Arbitration Center of the Beirut Bar Association) Arbitration Rules, which had not yet been made publicly available as of the date of this article. Over the course of the event, several conferences addressing procedure, damages, arbitration, judiciary cooperation and advocacy matters were held. The scale and quality of participation marked a high point in community engagement and signaled a clear intention within the arbitration community to re-position Beirut as a credible regional hub for complex commercial and investment disputes, even as broader structural economic reforms remain outstanding.
In parallel, treaty exposure arising from Lebanon’s de-facto capital controls continued to intensify; driven by foreign investors impacted by the banking crisis. Most notably, Al Habtoor Group (UAE) served a notice of dispute under the Lebanon - United Arab Emirates BIT (1998) alleging impeded transfers of funds and violations of treaty protections—particularly fair and equitable treatment and free-transfer guarantees. The Group publicly announced in January 2025 that it was cancelling all planned investments in Lebanon, a development that highlighted the mounting risk of additional Investor-Sate Dispute Settlement (“ISDS”) claims premised on blocked deposits and transfer-of-funds provisions. Since then, however, Al Habtoor has signaled an intention to resume—or at least reconsider—the operation of its investments in the country.
Significant Cases and ISDS
Developments
On the dispute landscape, investor–state matters with a Lebanese nexus remained active: AVAX v. Lebanese Republic (ICSID) — Annulment Phase: The dispute arises from alleged breaches by the Lebanese Republic of a construction contract concluded with AVAX for the Deir Ammar II power plant, principally relating to non-payment. Following the tribunal’s June 2024 award dismissing the investor’s claims, an ICSID (International Centre for Settlement of Investment Disputes) ad hoc committee was constituted on 14 January 2025 to hear the investor’s annulment application. To date, the annulment proceedings remain pending. The committee’s eventual decision is expected to provide additional guidance on the scope of annulment review under the Convention on the Settlement of Investment Disputes between States and Nationals of Other States (1965) (“ICSID Convention”). While the merits award relieved the State of a substantial potential liability, careful management of the annulment phase—and of any subsequent enforcement or costs issues—remains essential. Practitioners should also monitor any partial or interim decisions addressing the customary annulment grounds, including alleged serious departures from a fundamental rule of procedure or manifest excess of powers.
Abed El Jaouni v. Lebanon (ICSID) — Post-Award Posture: for context, readers will recall that the case stems from the revocation of aviation licenses held by the claimant’s subsidiary. Following the ad hoc committee’s rejection of Lebanon’s annulment application on 5 December 2024, the US$218.2 million award in favour of the investor remains final and in force. In 2025, the focus has therefore shifted to post-award strategy—including settlement dynamics, budgetary/sovereign considerations, and potential foreign enforcement measures. For counsel advising States or investors with similar aviation-licensing fact patterns, the case continues to shape expectations around expropriation analysis and damages quantification under applicable treaties.
Lebanon-seated commercial arbitrations have also addressed matters relating to the Lebanese economic crisis:
Zeyad Salah v Ahli Investment Group and Arab Finance Corporation, BCCI Case No. 232/2021: in the commercial arbitration sphere, 2025 continued to illustrate how Lebanon’s financial crisis is generating non-treaty claims against domestic financial institutions. The dispute arose from an alleged breach of a portfolio management and financial services agreement between a Jordanian investor and the respondent financial entities. In March 2024, a majority LAMC tribunal seated in Beirut rendered an award ordering the respondents to pay approximately US$5.1 million plus interest, finding breaches of their duties to inform, advise, and warn, as well as failures to exercise due diligence and care in managing a conservative-risk portfolio heavily exposed to Lebanese sovereign Eurobonds. Although the Beirut Court of First Instance granted exequatur in late 2024, enforcement has been suspended following annulment proceedings initiated by the respondents under Lebanese law. While the case remains pending, it is likely to shape both the trajectory of future banking-related arbitrations and the strategic risk assessment of foreign investors operating in Lebanon.
Court Support and Enforcement Outlook
Lebanese courts have consistently adopted a favorem arbitrandum approach, reinforcing party autonomy and the effectiveness of arbitration agreements. Traditionally, the courts have held that:
The mere inclusion of an arbitration clause in a contract is sufficient to confer jurisdiction on the arbitral tribunal (See, Court of Cassation of Lebanon (Decision No. 79/2001)).
Arbitral tribunals have primary authority to decide on their own jurisdiction. Courts must decline jurisdiction when a valid arbitration clause is invoked, unless the clause is null or clearly inapplicable (See, First Instance Tribunal of Mount Lebanon, Decision No. 79/2017).
Contractual annexes that form part of the principal agreement are automatically subject to the arbitration clause included in the main contract, even if the annexes do not contain any express arbitration clause (See, Court of Appeal of Mount Lebanon, Decision No. 1/2022).
Annulment proceedings may not serve as a vehicle for merits review; challenges alleging errors in substantive liability fall outside the narrow grounds for annulment (See, Court of Appeal of Beirut, Decision No. 385/2023).
In the post-award phase, Lebanese courts continue to apply the New York Convention (1958) (“NYC”) unless its provisions are less favorable to the arbitration award than Lebanese laws. Notably, Article 814 of the Lebanese Code of Civil Procedure (“LCCP”), limiting refusal of enforcement to awards that manifestly violate international public policy, is considered more arbitration-friendly than the broader public-policy ground of Article V(2)(b) of the NYC.
Nothing in judgments issued in 2025 indicate a departure from these principles, though judicial resource constraints may affect timelines. Counsel should factor this into the enforcement strategy and sequencing.
Legislative and Regulatory Developments
No arbitration-specific legislation was enacted in 2025, and Lebanon continues to rely on the arbitration framework set out in Articles 762–821 of the Lebanese Code of Civil Procedure (“LCCP”). While these provisions remain broadly arbitration-friendly, they do not fully reflect the more modern architecture of the post-UNCITRAL Model Law on International Commercial Arbitration 2006. Throughout 2025, practitioners renewed longstanding calls for legislative modernization—particularly with respect to interim measures, tribunal powers, confidentiality, judicial assistance, and procedural formalities—but to date, no reform bill progressed to the point of enactment.
In July 2025, Parliament adopted a justice-sector reform law aimed at strengthening judicial governance and institutional capacity. Reactions within the legal community were measured, with commentators generally viewing the reform as a limited but constructive step. Although not directed at arbitration, any medium-term improvement in court efficiency, especially in matters involving interim relief, evidence-taking, or the recognition and enforcement of awards, would indirectly reinforce Lebanon’s arbitral infrastructure.
Institutional Developments
LAMC — Rules in Practice: The LAMC Arbitration Rules, which were comprehensively revised in 2024, continued to shape practice in 2025. Users increasingly relied on the rulebook’s complex-case toolkit—multi-contract/multi-party configurations, consolidation, joinder, expedited tracks, emergency arbitrator, and technology-enabled case management (e-filing, virtual hearings). To reduce procedural skirmishes about institutional identity, any previous reference to arbitration under the “Beirut and Mount Lebanon Chamber of Commerce” are deemed to fall under the LAMC Rules of Arbitration. The concurrent implementation of the LIAC-BBA Rules provides parties with two updated institutional options in Beirut, enhancing both institutional competition and party choice.
Conclusion
2025 marked a return of confidence in Lebanon’s arbitration community. The country did not overhaul its legal framework, but it demonstrated that its institutions, practitioners, and courts remain fully capable of supporting meaningful arbitral practice. Growing engagement with international actors, steady jurisprudence, and reinvigorated institutions signal a system moving forward rather than standing still. Whether expressed through judicial consistency, institutional renewal, or broader international visibility, the year revealed a quiet but unmistakably Lebanese resilience within the country’s arbitration landscape.
For 2026, the opportunity is clear: anchor this renewed energy in modernized legislation and consistent institutional practice. If Lebanon seizes that opportunity, Beirut could once again emerge as a natural meeting point for regional dispute resolution.
ABOUT THE AUTHORS
Roy Madkour is the Founding Partner of Madkour Law Firm, a Beirut based law firm with a focus on Arbitration, commercial litigation and cross-border disputes. He has over 25 years of experience advising corporate actors and financial institutions in complex domestic and international matters. Roy regularly acts as counsel in commercial arbitration and investment proceedings and has been involved in disputes spanning the MENA region, Europe and Africa. He is a member of the Beirut Bar Association, President of the Lebanese Penal Law Association and President of the Lebanese Section of the International Prison Watch.
Michel Madkour is an Associate at Madkour Law Firm and a member of the Beirut Bar Association. He is currently on educational leave, pursuing an LL.M. at Columbia Law School. Michel holds an LL.B. and a Master 1 in Business Law from Saint Joseph University of Beirut and a Master 2 in Arbitration and International Trade from Paris 1 Panthéon-Sorbonne University. He joined the firm in 2023 after an internship with a leading American arbitration firm in Paris. Michel specializes in international arbitration and commercial disputes, advising clients across Lebanon, Cyprus, France, and the UAE. He has experience in institutional and ad hoc arbitration under various rules.
Ghady Rizk is an Associate at Madkour Law Firm and a member of the Beirut Bar Association. He holds an LL.B. and a Master 1 in Business Law from Saint Joseph University of Beirut, as well as a Master 2 in Private International Law and International Commerce from Paris-Panthéon-Assas University. Ghady specializes in international dispute resolution. He frequently advises on cross-border disputes and complex civil and commercial matters under both Lebanese and French Law.