Different Seats, Different Traditions: What Role for National Courts in Investment Arbitration?

On 9 September 2026, on the eve of the Swedish Arbitration Days, the Swiss Arbitration Association and Westerberg & Partners will host an afternoon event at Westerberg’s Stockholm offices on “Different Seats, Different Traditions: What Role for National Courts in Investment Arbitration?”

Co-organised by Michele Potestà (LKK Arbitration) and Maria Fogdestam Agius (Westerberg & Partners), this event forms part of the ASA Investment Arbitration Task Force’s ongoing series examining key questions surrounding the choice of seat in investor-State arbitration. Sweden and Switzerland have developed distinctive traditions of judicial supervision in international arbitration. Differences in institutional design, procedural culture, standards of review and the relationship between domestic and supranational legal orders have shaped how courts in each jurisdiction approach challenges to investment awards.

Bringing together leading practitioners from Sweden and Switzerland, this seminar will examine how these different traditions operate in practice, explore the advantages and trade-offs associated with each approach, and consider how such differences may influence the strategic considerations underlying the choice of seat in investor-State arbitration.

Speaker details will be announced shortly.

We look forward to welcoming you to Stockholm for what promises to be a timely and thought-provoking discussion on one of the most important strategic decisions in investor-State arbitration: the choice of seat!