The Singapore Convention: The Future of International Mediation Enforcement

For decades, international commercial arbitration had a significant advantage over mediation: arbitration awards could be enforced globally under the New York Convention. Mediated settlements could not.

The Singapore Convention changes this.

What Is the Singapore Convention?

The United Nations Convention on International Settlement Agreements Resulting from Mediation — known as the Singapore Convention — was adopted by the UN General Assembly in December 2018 and opened for signature in Singapore in August 2019.

Its purpose is straightforward: to do for international mediation what the New York Convention did for arbitration — create a global framework for enforcing mediated settlement agreements across national borders.

How Is It Different From the New York Convention?

The New York Convention applies to arbitration awards — decisions made by an arbitrator or arbitration panel. To use it, parties must structure their dispute resolution as arbitration, not mediation.

The Singapore Convention applies directly to mediated settlement agreements — the outcome of a mediation process where parties voluntarily reach their own agreement with the help of a neutral mediator.

This distinction matters because mediation and arbitration serve different purposes. Mediation is collaborative and preserves relationships. Arbitration is adversarial and produces a binding decision. Many parties prefer mediation but historically lacked the enforcement mechanism that arbitration provided.

The Singapore Convention fills this gap.

Which Countries Have Signed?

As of 2026, the Singapore Convention has been signed by over 55 countries. Key signatories include:

United States
China
India
Singapore
South Korea
Saudi Arabia
Qatar
Israel
Ukraine
Many African and Asian nations

Notably, the EU has not yet signed as a bloc, though individual EU member states may ratify independently. The UK has not yet ratified. The Convention is still relatively new and adoption is growing.

How Does Enforcement Work?

When a party wants to enforce a Singapore Convention settlement in a signatory country:

Apply to the competent authority in the country where enforcement is sought
Provide the signed settlement agreement and evidence that it resulted from mediation
The authority reviews basic requirements — including that the mediator was neutral and the agreement was not obtained by fraud or duress
If satisfied, the authority enforces the agreement as binding

Like the New York Convention, courts may only refuse enforcement on limited grounds — primarily fraud, incapacity, or public policy violations.

What Are the Requirements for a Settlement to Qualify?

For a settlement to be enforceable under the Singapore Convention:

It must result from mediation — a process facilitated by a neutral third party
It must be in writing and signed by the parties
It must involve an international commercial dispute — parties in different countries
The mediator must have been neutral and not imposed the outcome

Akordans' mediation process is designed to meet these requirements. The AI mediator proposes a resolution; the parties voluntarily accept. The process is documented and overseen by a human reviewer.

The Relationship Between the Singapore Convention and Parley

As the Singapore Convention gains wider adoption, Akordans' mediation outcomes will have an increasingly global enforcement footprint — particularly in Asia, the Middle East, and the Americas where key signatories are located.

For disputes involving parties in Singapore Convention countries, Akordans is building compliance documentation to support enforcement applications under the Convention.

For now, parties seeking the broadest possible enforcement should use Akordans's Enforcement tier, which produces a consent arbitration award enforceable under the New York Convention — currently the most widely adopted international enforcement framework.

Use Akordans' enforceability checker to see which frameworks apply to your specific country combination.