ICSID’s Rule 37(2) introduced into the ICSID system a process by which a
non-disputing party may make submissions as an amicus curiae. While
amicus submissions have existed in the ICSID system for nearly 20 years, the
majority of Rule 37(2) applications have been filed only recently by one party
– the EU Commission – on one issue – the applicability of the arbitration
agreements in intra-EU BITs. In this article, we explore how tribunals and ad
hoc committees have addressed these applications, which do not seek to provide
insight on a particular issue in relation to the merits (as past amicus have),
but to strip the ICSID process of jurisdiction over all intra-EU BIT disputes.