European commercial arbitration has had a busy two years. Legislative reform, institutional rule changes, and court decisions across the region during 2024–2025 raise a question worth asking: is a distinctively European approach to commercial arbitration taking shape? This article – the first in what is intended as a continuing series – surveys developments across a range of jurisdictions, including the United Kingdom, Germany, Belgium, and France, as well as changes to the rules of several major European arbitral institutions. The picture that emerges is mixed. There is real convergence around efficiency, procedural discipline, and the supervision of arbitral awards. But significant differences persist – in how far courts will intervene, how public policy is defined, and how the obligations of EU membership bear on arbitration practice. These are not merely theoretical questions. They bear directly on how parties structure dispute resolution clauses, choose their seat, and manage the risk of enforcement across borders.
Arbitration: The International Journal of Arbitration, Mediation and Dispute Management