Publication date: February 6, 2026

In cross-border trade, businesses often opt for alternative dispute resolution (ADR) methods, such as international arbitration. This solution ensures, above all, a more neutral, faster, more flexible, and highly professional procedure. Naturally, in such a situation, the parties do not want to be at the mercy of a domestic court, foreign laws, unfamiliar traditions, doctrines, and established interpretations. Hence the need to submit the dispute to resolution by one or more arbitrators appointed by the parties from among global experts in their respective fields of business. The fundamental condition for such a solution is an arbitration agreement (the terms “arbitration court” and “arbitral tribunal” are often used interchangeably and refer to the same body resolving disputes through arbitration), included either in the initial agreement or in a separate agreement between the parties, which specifies the legal relationship from which the dispute arises or may arise. Obtaining an arbitration award does not, however, definitively conclude the case, but rather initiates the sometimes problematic issue of enforcing such an award in domestic courts. A foreign creditor who obtains an arbitration award that obligates a Polish entity to pay can generally expect its recognition and enforcement in a Polish domestic court.

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