INTERNATIONAL COMMERCIAL ARBITRATION LAW IN THE TURKIC STATES OF AZERBAIJAN, TÜRKIYE AND UZBEKISTAN

Abstract

This research paper examines the international commercial arbitration legal frameworks in three jurisdictions: Azerbaijan, Türkiye, and Uzbekistan. These three Turkic States, positioned at the crossroads of Europe and Asia, have emerged as significant players in international trade and investment, necessitating robust arbitration systems to resolve cross-border commercial disputes. The study reveals that while all three jurisdictions have made substantial progress in developing their arbitration frameworks, they exhibit varying degrees of alignment with international standards. Türkiye has established the most sophisticated arbitration regime and developed institutional infrastructure through the Istanbul Arbitration Centre. Uzbekistan has demonstrated remarkable recent progress, particularly with its 2021 Law on International Commercial Arbitration and the establishment of the Tashkent International Arbitration Centre in 2018. Azerbaijan has also modernized its arbitration framework with the adoption of the 2023 Law on Arbitration and the establishment of the Baku Arbitration Centre in 2025. The findings indicate that all three countries are signatories to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards of 1958, demonstrating their commitment to international arbitration standards. However, enforcement mechanisms vary, with all three jurisdictions showing judicial support for arbitration and some issues such as public policy exceptions examined carefully. Recent reforms reflect a regional trend toward harmonization with international best practices, including legislative amendments to streamline enforcement procedures and strengthen institutional capacity. The paper concludes with recommendations for legislative reforms, institutional development and capacity building to position these jurisdictions as competitive arbitration venues in the Eurasian region.