We successfully acted in proceedings leading to two landmark judgments concerning the recognition and enforcement in Cyprus of an LCIA Final Award exceeding USD 1.5 billion and a separate LCIA Costs Award exceeding GBP 3 million.
For the first time, the Cyprus courts have provided clear judicial guidance on the application of the "more favourable" regime under Article VII(1) of the New York Convention, confirming that, where appropriate, parties may rely directly on the domestic framework of Law 101/1987 for the recognition and enforcement of international commercial arbitral awards.
These important judgments reinforce Cyprus' position as a modern, arbitration-friendly jurisdiction and provide greater certainty for parties enforcing international arbitral awards.
Congratulations to our team, Stavros Pavlou and Katerina Philippidou, who successfully handled these landmark proceedings.
Continue reading below for an overview of this important legal development and its implications for international arbitration in Cyprus.
A Landmark Judgment on the Recognition and Enforcement of International Arbitral Awards in Cyprus Under the "More Favourable" Regime Provision.
Our firm recently acted successfully in two applications for the recognition, registration and enforcement in Cyprus of an LCIA Final Award exceeding USD 1.5 billion and a separate LCIA Costs Award exceeding GBP 3 million.
In two judgments issued by the President of the District Court of Limassol, the Court provided, for the first time in Cyprus, clear judicial guidance on the relationship between the International Commercial Arbitration Law of 1987 (Law 101/1987) and the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards.
A Novel Issue Before the Cyprus Courts
Cyprus is a Contracting State to the New York Convention. However, Article VII(1) of the Convention, commonly referred to as the "more favourable regime" provision, expressly preserves the right of Contracting States to apply domestic legislation that provides a more favourable regime for the recognition and enforcement of arbitral awards, instead of the potentially more onerous provisions of the Convention.
Relying on this provision, our firm commenced proceedings for the recognition, registration and enforcement of an LCIA arbitral award solely under the International Commercial Arbitration Law, Law 101/1987, rather than under the New York Convention as implemented in Cyprus by the Recognition and Enforcement of Foreign Arbitral Awards (Ratification) Law, Law 84/1979, which has traditionally been the legal basis for such applications.
Our position was that the purpose and spirit of Law 101/1987, particularly following its recent amendment by Law 11(I)/2024, is to simplify the recognition and enforcement of international commercial arbitral awards in Cyprus. Unlike Law 84/1979, Article 35 of Law 101/1987 imposes fewer documentary requirements, thereby providing a more efficient and arbitration-friendly procedure. More specifically, the Court can proceed solely on the basis of a certified true copy of the award and not require either a true copy of the arbitration agreement or a certified sworn translation of the submitted documents into Greek.
The respondents argued, inter alia, that the application lacked a proper legal basis because it was not brought under Law 84/1979 and the New York Convention and argued that Law 101/1987 could not constitute the legal basis of the application and that the application ought to have been brought under the New York Convention and its implementing legislation (Law 84/1979), which, by virtue of Article 169 of the Constitution, prevails over any domestic legislation.
Our firm, on the other hand, argued that Article 35 of Law 101/1987 constitutes a complete, autonomous and self-contained statutory framework for the recognition, registration and enforcement of international commercial arbitral awards in Cyprus. We further submitted that, by virtue of Article VII(1) of the New York Convention, a party is entitled to rely on a more favourable domestic regime where one exists.
We also drew the Court's attention to the fact that Law 101/1987 postdates the ratifying legislation implementing the New York Convention and that the more liberal wording of Article 35 was introduced by the 2024 amendments. In our view, this reflected a clear legislative intention to establish a broader and more practical framework for the recognition and enforcement of international arbitral awards in Cyprus.
The Court accepted that the Applicant was entitled to rely on Law 101/1987 as the legal basis for the recognition, registration and enforcement of the international arbitral award. It concluded that Law 101/1987 contains more favourable provisions than the New York Convention in relation to the documentary requirements for recognition and enforcement and may therefore be relied upon pursuant to Article VII(1) of the Convention.
In reaching that conclusion, the Court recognised that Law 101/1987 constitutes the substantive and procedural law governing international commercial arbitration in Cyprus and that Articles 35 and 36 establish a complete statutory framework for the recognition and enforcement of international commercial arbitral awards. The Court further held that the documentary requirements prescribed by Article 35 were sufficient to support the applications and rejected all objections advanced by the respondents, issuing orders recognising, registering and enforcing both the LCIA Final Award and the LCIA Costs Award.
The Significance of the Judgments
These judgments represent an important development in Cypriot arbitration law.
For the first time, a Cypriot court having considered in detail the relationship between Law 101/1987 and the New York Convention, confirmed that, in appropriate circumstances, parties may rely directly on the domestic regime established by Law 101/1987 pursuant to Article VII(1) of the Convention.
The judgments also reinforce Cyprus' arbitration-friendly approach and its commitment to the principles of the UNCITRAL Model Law, providing clarity and certainty for parties seeking to enforce international arbitral awards in Cyprus.
The proceedings also involved one of the first instances under the new Cyprus Civil Procedure Rules in which the Court granted permission for expert legal opinion evidence to accompany the applications, addressing issues on which no previous Cypriot authority existed.
These judgments confirm a legal position that our firm has consistently maintained: namely, that parties seeking the recognition and enforcement of international commercial arbitral awards in Cyprus may, where appropriate, rely directly on the domestic regime established by Law 101/1987, pursuant to the "more favourable" rule of the New York Convention.
We now have judgments of the Cyprus Court recognising that more favourable regime, while at the same time preserving and reaffirming the strict requirements of the New York Convention.
(1) Halimeda International Ltd v. Μaple Ridge Limited, Claim No 2/2025, two Judgments dated 12/06/2026, District Court of Limassol
