Reviewed legal insight

How do Hong Kong–Mainland arbitration awards and interim measures differ?

An arbitration award is the arbitrator's decision, while interim measures provide temporary court protection. These raise different questions about the proceedings, assets and evidence.

Read the arbitration clause before choosing a response to a disagreement. Note the legal seat (the place where arbitration is legally based), the administering institution (the organisation managing the proceedings) and whether an award already exists.

Review state
Human reviewed
Last reviewed
Sep 5, 2026
Applies to
MAINLAND_CHINA_HONG_KONG

An award starts an enforcement question

The Mainland–Hong Kong awards arrangement provides a recognition and enforcement framework. Its supplemental arrangement, fully implemented on 19 May 2021, addresses applications in both places where the party facing enforcement or their property is present in both, with total recovery capped at the award amount. Availability of the procedure does not establish that assets can be recovered.

Interim measures concern protection while proceedings are pending

The Department of Justice describes Mainland court measures to preserve property, evidence or conduct in support of qualifying Hong Kong arbitrations. The arbitration must be seated in Hong Kong and administered by an eligible designated institution or permanent office. Check the current designation and the relevant court's requirements; a Hong Kong hearing location alone does not establish eligibility.

What to prepare

For an initial discussion, organise:

  • The complete arbitration clause, amendments and institutional correspondence.
  • The seat, administering institution and current procedural stage.
  • The award and any challenge documents, if an award has been made.
  • A factual description of the assets or evidence concerned and why protection may be urgent.

Information boundary

This article provides general legal information, not legal advice, and does not create a solicitor-client relationship. A lawyer must assess the relevant facts, documents and current law before advising on a particular matter.

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