Should Asia’s Primary Sports Arbitration hub be in Hong Kong?
- 2 February 2026
- SLAM
Should Asia’s Sports Arbitration hub be in Hong Kong?
Arbitration in Sport
CAS was established in 1984 in response to the growing number of international sports disputes and the absence of a specialised binding authority. Following reforms in 1994, prompted by Gundel v La Fédération Équestre Internationale [1991], CAS became an independent arbitral institution, serving as a model for national and international sports federations. Since then, federations worldwide have adopted or been influenced by the CAS structure to ensure timely, effective decisions. Notably, in London Welsh v Rugby Football Union, where a fair and reasoned outcome was reached in less than six weeks, an efficiency unattainable through court litigation.
Since 1996, the CAS Ad Hoc Division has overseen numerous disputes arising during major events like the Olympics and FIFA World Cup. Guided by the principles of being “fast, fair and free,” the Division ensures decisions are rendered swiftly, often within 24 hours, maintaining fairness and upholding the integrity of competitive sport.
These features illustrate why arbitration is the preferred method in sport: it combines speed, specialised expertise, and enforceable outcomes in a way that litigation cannot, making it uniquely suited to the fast-paced and high-stakes environment of international competitions. As Han Xiangfei, deputy secretary-general of the China Commission for Arbitration of Sports (“CCAS”)CCAS, observed “Football is a sport with high social attention and frequent disputes.”
The landscape of commercial dispute resolution is one of constant evolution. To understand how Hong Kong is positioning itself within this evolving landscape, it is useful first to examine the international context, then compare Hong Kong’s approach to that of Singapore – Asia’s two leading arbitration centres.
The Race to Arbitration
The Demand
Hong Kong
Since the British handover of Hong Kong on 1st July 1997, China and Hong Kong have operated under “one country, two systems” principle. In recent years, both have embarked on a strategic mission to establish to position themselves as global leaders in dispute resolution, both within and beyond the sports sector. A notable example is the Convention on the Establishment of the International Organization for Mediation (IOMed). Founded on 30 May 2025 and headquartered in Hong Kong, IOMed aims to provide a mediation-focused platform for resolving international disputes and aspires to rival the International Court of Justice (“ICJ”), the world’s leading conflict resolution body.
Hong Kong, as a common law jurisdiction, has aligned itself with international arbitration standards in the western world. This alignment is most clearly demonstrated in C v D [2022] HKCA 729, where the Court of Appeal held that a failure to comply with pre-arbitration ADR procedures concerns admissibility rather than jurisdiction. This decision enforced Hong Kong’s status as aligning itself with international standards encouraging party autonomy, procedural uniformity, and arbitration as a “one-stop shop” for dispute resolution. Hong Kong’s judiciary has further confirmed its pro-arbitration stance in L v M N & Anor [2021] HKCFI 2829, holding that once a prima facie case of an arbitration agreement is established, court proceedings should be stayed even if issues of admissibility or jurisdiction remain, as these are matters for the tribunal. The court clarified that abandonment of an arbitration agreement will only be recognised where there is clear and unconditional intent. Together, these decisions highlight Hong Kong’s commitment to enforcing arbitration agreements and ensuring procedural uniformity in line with international standards.
Its geographic proximity to mainland China positions it as a gateway between China and the global market, making it particularly attractive for disputes involving Chinese parties. Hong Kong’s arbitration regime benefits from a unique position under the “One Country, Two Systems” framework, creating a legal gateway to mainland China. This allows mutually supportive mechanisms between Hong Kong and mainland Chinese courts, simplifying matters such as interim measures and enforcement where Chinese assets or parties are involved. Hong Kong’s approach also features a unified statutory regime covering both domestic and international arbitration, potentially offering greater clarity to users navigating complex cross-border disputes.
Despite its advantages, arbitration has one significant limitation: it is a consensual process. It is a pre-requisite that parties must agree to submit their dispute to arbitration before proceedings can begin. For example, Sports Resolutions (UK) may only hear a case where the parties have expressly consented to “bring the matter to Sports Resolutions.” Similarly, the starting point for any CAS arbitration is the source of jurisdiction, which will take the form of an agreement by the parties to submit their dispute to arbitration pursuant to the CAS Rules. Without such agreement, arbitration cannot proceed, regardless of how suitable the forum may be.
Singapore
Singapore, by contrast, is perceived as a neutral and independent jurisdiction detached from the political and legal environment of China. The Singapore International Arbitration Centre (SIAC) facilitates both regional and global arbitration cases, with 91% of cases submitted in 2024 being international, involving parties from 72 jurisdictions.[1] Its arbitration practice has a reputation for efficiency, procedural innovation, and rapid case administration, making it particularly suitable for purely international disputes in which neutrality, predictability, and time-efficiency are paramount. Unlike Hong Kong, Singapore operates a dual statutory regime distinguishing between domestic and international arbitration, but this does not detract from its status as a globally preferred seat for commercial parties from a wide range of jurisdictions.
Analysis
When choosing between Hong Kong and Singapore, it is not about a decision between a “good” and “bad” jurisdiction. The core arbitration infrastructures of both jurisdictions are broadly comparable in quality, accessibility, and procedural sophistication. Each is internationally recognised for its institutional support, through the HKIAC in Hong Kong and SIAC in Singapore, and both have embraced modern mechanisms for funding, including third-party funding and flexible outcome-related fee structures.
The practical implication is that neither Hong Kong nor Singapore can be described as universally superior; their relative advantages depend on context. In practice, the decision often turns on nuances that may influence the arbitral process or outcome. For disputes involving Chinese parties, investment flows, assets, or enforcement risks, Hong Kong may offer distinct strategic value. For disputes without a China connection, particularly where procedural efficiency and neutrality are key, Singapore may be more attractive. Ultimately, while the infrastructures of both jurisdictions are broadly comparable, these nuanced distinctions can be decisive when aligning procedural strategy with commercial realities.
China’s Approach on Arbitration in Sport
Hong Kong has made clear its intention to capitalise on the growing demand for specialised sports arbitration in Asia. As Patrick Chan and Isobel Asti (Charles Russell Speechlys) observe, with major sporting events such as the 2026 Asian Games, Hong Kong’s embracing of sports arbitration is “not just a necessity but a strategic move to ensure fair play”. The establishment of a dedicated sports dispute mechanism has the potential to reinforce Hong Kong’s status as a leading international arbitration hub and, importantly, to contribute to the integrity and development of sport within the region. Achieving this aim requires not only the expertise of existing arbitral institutions but also the creation of a comprehensive framework specifically tailored to sports disputes. The fact that the world’s most populous country has working, cultural, language, social and geographical ties with Hong Kong further supports the argument that Hong Kong should become the primary base for Sports Arbitration in Asia.
Sport Arbitration Rules: Establishment of CCAS and Sports Arbitration Centre
China operates a ‘government-led, associations-administered, clubs-operated’ sporting governance model overseen by the General Administration of Sport of China (“GASC”). Formed in 1952, GASC, a ministry-level agency under the State Council, governs all sport nationwide, setting strategy, drafting policy and supervising disciplinary issues.
Pursuant to the revised Law of the People’s Republic of China on Sports (“the Sports Law”), on 1st January 2023, the Sport Arbitration Rules (“the Rules”) came into force. The primary aim, as set out in Article 1, is “to ensure the impartial and timely resolution of sports-related disputes, while safeguarding the legitimate rights and interests of all parties involved”. To achieve this, the Rules include key provisions, such as minimum qualifications for CCAS Arbitrators (Article 5), ability for parties to apply for arbitration in the absence of internal dispute resolution mechanisms (Article 14) and the final and binding nature of arbitral awards (Article 71).
In accordance with the Rules, on 11th February 2023 the GASC established the China Commission of Arbitration for Sport (“CCAS”) as China’s sole statutory sports arbitration body. In the absence of a specialised and effective mechanism, its creation addressed a critical gap in independent dispute resolution and reflected the Sports Law’s emphasis on the rule of law. The CCAS handles appeals against disciplinary decisions, athlete registration and eligibility disputes, as well as other non-commercial, non-labour disputes arising from competitive sports. The need for such a specialised mechanism is evidenced by the CCAS 2024 Annual Report, which recorded over 100 cases handled by the end of 2024.
Arbitration is a continually evolving process – rules must be refined, systems modernised, and governing bodies supported to effectively manage rising caseloads while ensuring outcomes remain fair, timely, and credible. Initially innovations such as consolidated arbitration, online hearings, and a 24-hour emergency procedure for competition disputes were satisfactorily adaptations. As both the volume and complexity of disputes have grown, additional support has been provided to the CCAS. On 31st December 2024, the CCAS established the Sports Arbitration Centre to enhance operational capacity. Representing a significant step in sports governance, the Centre now undertakes the day-to-day routine work of the CCAS “to ensure the independent, impartial and professional operation of the sports arbitration system and sports arbitration institutions.”
Hong Kong’s Role in the National 14th Five-Year Plan
Drafted in October 2020, against the backdrop of the Covid-19 pandemic and worsening China-US relations, the National 14th Five-Year Plan “supports Hong Kong to develop into a centre for international legal and dispute resolution services in the Asia-Pacific region” both within and beyond the context of sports. As the only common law jurisdiction in China, Hong Kong is strategically positioned to provide a trusted legal environment familiar to international businesses while maintaining strong ties with Mainland China.
On 16 October 2024, John Lee, Chief Executive of the Special Administrative Region of Hong Kong (“SAR”), delivered his 2024 policy address in which he announced, amongst other initiatives, plans to develop the SAR into a hub for mega international and national sporting events. With China’s huge success in the Paris 2024 Olympics, the Sports Federation and Olympic Committee of Hong Kong (“SF&OC”) provided its full support. The Committee believed that a fair and reasonable dispute resolution system will be beneficial to hosting international sports competitions and promoting sports development in Hong Kong.
As part of this Plan, the 15th National Games took place in November 2025 in the Greater Bay Area. It highlighted how sport can strengthen unity between Hong Kong, Macao, and Mainland China under the “one country, two systems” framework, while showcasing China’s growing sporting development.
Conclusion: What’s next?
On 21st November 2025, Hong Kong Regional Arbitration Centre (“AALCO-HKRAC”) announced its landmark appointment by the Department of Justice of the Hong Kong SAR Government (DoJ) to administer the city’s first-ever Pilot Scheme on Sports Dispute Resolution (“the Scheme”). This marks a cornerstone initiative under China’s 14th Five-Year Plan, which expressly envisions Hong Kong becoming a “referee” in regional and international sports disputes.
One of the most striking features of the Scheme is its integration of LawTech and Online Dispute Resolution (“ODR”). AALCO-HKRAC will utilise eBRAM’s self-developed ODR platform to deliver a seamless, one-stop system for filing claims, exchanging documents, and conducting hearings. This technology-driven approach is designed to enable efficient resolution of disputes across jurisdictions, time zones and removing traditional logistical barriers to international proceedings. eBRAM’s involvement provides the necessary technological infrastructure and supports the broader objective of promoting the uptake of LawTech and ODR services throughout Asia.
Whether Hong Kong’s model evolves to mirror CAS, compete alongside it, or innovate beyond it remains to be seen. What is clear is that Hong Kong has not merely followed global developments – it is positioning itself to shape the future architecture of sports arbitration in Asia. The next two years will likely determine whether Hong Kong becomes Asia’s de facto CAS, but the momentum, strategy, and infrastructure are now firmly in place.