The Kingdom of Bahrain is one of the Arab countries that has adopted the UNCITRAL Model Law with very few changes. Bahrain’s arbitration regime is governed by Legislative Decree No. 9 of 2015 (Bahrain Arbitration Law), which is based on the UNCITRAL Model Law on International Commercial Arbitration. This adoption ensures that Bahrain’s legal system is aligned with globally recognized arbitration standards, fostering legal certainty, transparency, and neutrality for parties engaged in arbitration.

 

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The Kingdom of Bahrain is the hub for two important arbitration centres operating in the GCC region. Bahrain has hosted the headquarters of the GCC Commercial Arbitration Centre since 1993. On 11 January 2010, the Bahrain Chamber of Dispute Resolution was established, which works in partnership with the American Arbitration Association and will be known as the BCDR-AAA. The Bahrain Chamber for Dispute Resolution (BCDR-AAA) is pivotal in Bahrain's institutional arbitration. Established in 2009 as a partnership with the American Arbitration Association (AAA), the BCDR-AAA offers institutional and ad hoc arbitration platforms. Its procedural rules are designed to ensure efficiency, fairness, and flexibility, appealing to both domestic and international parties.

 

Key features of Bahrain’s Arbitration Law include:

• Independence and impartiality of arbitrators

• The competence-competence principle, allowing arbitral tribunals to decide on their own jurisdiction

• Minimal judicial intervention, with courts playing a supportive role in the arbitration process

• Recognition and enforcement of foreign arbitral awards under the New York Convention (to which Bahrain has been a signatory since 1988)

 

 

Bahrain ratified the New York Convention on 6 April 1988 (by Bahrain 323 Decree Law No. 4 of 1988)

Bahrain was one of the first Gulf countries to adhere to the New York Convention (the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards), which was adopted by the United Nations in New York on June 10, 1958 (the “New York Convention”).

Date of accession: 6 April 1988.
Entry into force on 5 July 1988.

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As a signatory to the New York Convention, Bahrain facilitates the recognition and enforcement of foreign arbitral awards with limited exceptions. The country’s judicial system supports arbitration, with the courts having a consistent record of enforcing arbitral awards, barring exceptional circumstances such as violations of public policy or invalid arbitration agreements.

Under Bahraini law, enforcement is generally smooth, provided that the arbitral award does not contravene public policy. This enforcement framework reinforces Bahrain’s reputation as a pro-arbitration jurisdiction.

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Bahrain has entered into numerous Bilateral Investment Treaties (BITs) and Free Trade Agreements (FTAs), many of which include provisions for investor-state dispute settlement (ISDS) mechanisms, such as arbitration.

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Conclusion:

Bahrain has firmly established itself as a prominent player in international arbitration within the Middle East. The country’s modern arbitration law, the presence of institutions like the BCDR-AAA, and its strong commitment to arbitration-friendly policies have made it an attractive jurisdiction for resolving commercial and investment disputes. Bahrain’s efforts to continuously promote arbitration as an alternative dispute resolution mechanism, both regionally and internationally, ensure its place as a leading hub for arbitration in the years to come.

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