Why companies with no UK connection choose it – and what that means when a dispute arises
English law governs around 40% of the world's cross-border business and financial transactions, according to TheCityUK. It applies to derivatives transactions valued at over £250 trillion, around half of all international seaborne trade worth more than £13 trillion, and 28% of global agricultural trade. It is also chosen in contracts where neither party has any ties to the UK.
That choice carries consequences parties rarely consider at the transaction stage. One of them: around 30% of the claims issued in the London Commercial Court concern not the underlying disputes but support for arbitration proceedings – from interim relief to enforcement of awards.
The figures come from the International Data Insights Report published recently by the Law Society of England and Wales.
Why English law is chosen without a UK connection
The market-by-market estimates come from "Harnessing English Law for Economic Growth", a report commissioned by the UK Ministry of Justice. Alongside the figures above, English law governed an estimated £73–83 billion of the London insurance market in 2024.
The reason for this reach is practical. English law underpins standard-form contracts in shipping, commodities, insurance, trade finance and derivatives. According to the report, this delivers legal certainty and reduces transaction costs for businesses operating internationally.
For companies operating across emerging markets – from the CIS to Africa and the Middle East – the implication is straightforward: English law expertise may be required regardless of where the business operates or where the asset sits.
The English court appears in disputes that did not start there
Around 30% of the claims issued in the London Commercial Court relate to arbitration: applications for anti-suit injunctions, enforcement of arbitral awards and appointment of arbitrators. In these cases the court acts not as the forum deciding the merits, but as the institution supporting the arbitral process.
That support may also be needed by parties to arbitrations seated outside England – for instance, where assets within the UK jurisdiction are to be frozen, or where an award falls to be enforced.
The legal framework was updated by the Arbitration Act 2025, which introduced reforms aimed at enhancing legal certainty and procedural efficiency in arbitrations seated in England and Wales.
Fewer claims, more judgments
New claims in the London Commercial Court are declining: 1,140 between October 2024 and September 2025, against 1,192 the previous year and 1,352 the year before. At the same time, 75% of the court's caseload was international.
The allocation of cases within the court has also changed. With effect from 1 July 2025, claims with a value at risk of £7 million or less are generally allocated to the London Circuit Commercial Court division, while the Commercial Court division focuses on more complex and higher-value disputes. The Commercial Court received 609 new claims against 743 the previous year; the London Circuit Commercial Court received 432 against 339, an increase of 27%.
A second measure is output: 212 written judgments over the period, up 8.2% year on year. Over an equivalent period, the DIFC's Civil and Commercial Division in Dubai recorded 117, the Qatar International Court 89, the New York Commercial Division 78, the AIFC Court in Astana 64, the Singapore International Commercial Court 37 and the Netherlands Commercial Court 14. For the DIFC, the report uses the number of cases received: data on written judgments delivered is not published.
Speed is a separate factor. The court completed 56% of contested trials – 41 out of 73 – in less than a week, that is within four working days. The figure was 54% the previous year and 44% the year before that.
Arbitration: growth almost everywhere, English law in the lead
Most arbitrations seated in London are ad hoc rather than institutional, conducted under the rules of specialist trade bodies. The London Maritime Arbitrators Association recorded an estimated 2,015 new cases in 2025 against 1,733 the previous year: a 16% increase and its highest caseload since 2014. Arbitrator appointments in LMAA cases rose 15% to 3,469.
Year-on-year institutional figures: SIAC up 40%, from 625 to 886 cases; the Swiss Arbitration Centre up 25%; HKIAC up 10%; the ICC up 6%; GAFTA and the SCC up 4%; the LCIA up 0.8%. Only the ICDR-AAA recorded a decline, down 11%.
English law remains the most frequently selected governing law. It governed 79% of LCIA cases. At the ICC it ranked first with 113 new cases (13%), followed by New York law (7.2%), Brazilian law (6%), Swiss law (5.6%), German law (5.4%), French law (4.9%) and Spanish law (4.8%). At SIAC, HKIAC and the SCC, English law ranks second after the respective domestic law.
International caseloads remain high: 96% of LCIA cases in 2025 involved at least one non-UK party, and 69% of ICC arbitrations concerned cross-border disputes. Average amounts in dispute: over USD 50 million at the ICC, USD 53.7 million at HKIAC, USD 24.7 million at SIAC and around USD 18.5 million under the SCC Rules.
More specialist centres are emerging
Specialist commercial courts continue to develop across several jurisdictions: alongside Dubai, Qatar, Singapore, Amsterdam and Astana, similar initiatives are under consideration in Hong Kong, Vietnam and Uzbekistan. Arbitration centres across the Middle East, Africa and Central Asia are also growing.
One indirect indicator is where English solicitors are based. There are 9,066 solicitors outside England and Wales, up 9.6% year on year. The largest overseas location is the UAE with 1,513 (16.7% of all solicitors abroad), followed by Hong Kong (949) and Singapore (862).
The market continues to expand: UK legal services exports reached £10.97 billion in 2025, against £6.81 billion in 2021, with the trade surplus in legal services reaching £9.63 billion. The largest markets are the European Union (£3.67 billion) and the United States (£3.21 billion).
Points to consider when planning a dispute
Choice of law and choice of forum are separate decisions. English law may govern a contract that is arbitrated in another jurisdiction. The ICC, SIAC, HKIAC and SCC figures bear this out.
Plan for the English court scenario in advance. A third of the claims in the London Commercial Court relate to arbitration. Interim relief, anti-suit injunctions and enforcement are planned before proceedings begin, not after.
Speed is measurable. More than half of contested trials in London conclude within four working days. That is a figure to weigh against timelines in alternative jurisdictions.
For commodities and shipping, trade arbitration matters more than institutional. The LMAA and GAFTA operate their own procedures under English law, with England and Wales as the seat.
TRP International acts in international arbitration, English law disputes before the High Court of England and Wales – including worldwide freezing orders – and in enforcement and asset recovery across multiple jurisdictions. We are open to discuss your matter: contact@trp.international.