If you are holding an arbitral award and your counterparty has assets in Israel, Israel modernized its rules in your favor. This matters whether you are a private individual chasing what you are owed, an Israeli business, or a company or investor based abroad with an Israeli connection. In February 2024 Israel enacted the International Commercial Arbitration Law 5784-2024, adopting the UNCITRAL Model Law (as amended in 2006), and recognition and enforcement of a foreign award now runs through the New York Convention's narrow, closed list of grounds on which a court may refuse it. Guidance written before 2024, which leaned on the older Arbitration Law 5728-1968, is now outdated for international matters, and anyone planning enforcement strategy off that older commentary should treat it with care.
What actually changed in February 2024
For decades, international arbitration in Israel sat inside the same statute that governed a domestic dispute between two Israeli parties, the Arbitration Law 5728-1968. That framework was workable, but it was not built around the international standard that cross-border parties expect.
The International Commercial Arbitration Law 5784-2024 changed that. It brings Israel into line with the UNCITRAL Model Law, the template that a large share of arbitration-friendly jurisdictions have adopted, including the 2006 amendments to that Model Law. For an investor, a fund, or a company choosing a seat or weighing where to enforce, this matters. It signals that Israel now speaks the same procedural language as the major international seats, which tends to reduce the friction and the surprises that used to come with enforcing here.
It is not retroactive to your contract, it is keyed to when the arbitration began
One point that frequently confuses parties is timing. The new law applies to international commercial arbitrations initiated after it came into force, and it does this regardless of when the underlying arbitration agreement was signed. So the question is not whether your contract predates the 2024 law. The question is when the arbitration itself was commenced. A dispute under a contract signed years ago can still fall under the new regime if the arbitration was started after the law took effect. The firm generally reviews the commencement date early, because it determines which set of rules governs everything that follows.
The New York Convention has been in play in Israel since 1959
Although the headline is the 2024 law, the backbone of foreign-award enforcement in Israel is older than that. Israel ratified the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, which entered into force for Israel on 7 June 1959. Israel later incorporated the Convention into its domestic arbitration framework through a 1974 amendment.
What the 2024 law does is channel the recognition and enforcement of a foreign award through the Convention's framework, and the practical heart of that framework is its closed list of refusal grounds.
What a closed list of refusal grounds means for you
This is the part that changes the odds. Under the Convention, a court asked to recognize and enforce a foreign award is not free to re-open the merits and decide the case again. It may refuse enforcement only on a defined, limited set of grounds. The list is closed, meaning the resisting party has to fit its objection into one of the recognized categories, and it cannot simply argue that the arbitrators got the facts or the law wrong.
Broadly, and without tying this to a specific section number that the firm would only cite after confirming it against the official Hebrew text, the recognized grounds track the familiar Convention categories. These generally include matters such as the following.
The strategic takeaway is that a debtor cannot relitigate the dispute in Israel. That is exactly what makes a Convention award a strong asset. At the same time, these grounds are real defenses, and a well-advised debtor will probe procedural fairness, scope, and public policy, so the integrity of how the arbitration was run often matters as much as the result.
Two regimes now run in parallel
An important practical consequence of the 2024 law is that Israel now operates two arbitration regimes side by side. The new International Commercial Arbitration Law 5784-2024 governs international commercial arbitration. The older Arbitration Law 5728-1968 continues to govern domestic arbitration between Israeli parties. They are not interchangeable, and the first analytical step in any matter is deciding which regime applies.
For a client enforcing a foreign award, the international column is almost always the relevant one, whether that client is an Israeli resident, an Israeli business, or a party based abroad. Because the line between domestic and international can occasionally be argued, confirming the characterization at the outset protects the whole strategy.
Why this is good news for award creditors with an Israeli connection
Put the pieces together and the direction of travel is clear. Israel was already a New York Convention country, and the 2024 law layered a modern, internationally recognized procedural standard on top of that. For a creditor who has already won an international arbitration, the combination generally means a more predictable enforcement path, a court that is asked to recognize rather than to retry, and a closed set of defenses the debtor must squeeze into.
That predictability is itself a negotiating tool. A counterparty who understands that an Israeli court will not reopen the merits, and that its objections are confined to a short list, often has more reason to settle or to satisfy the award voluntarily. The firm frequently uses that reality in pre-enforcement correspondence before any motion is filed. The same recognition-not-retrial logic governs enforcing a foreign court judgment in Israel, so a creditor weighing arbitration against litigation should understand both enforcement paths before choosing.
A short checklist before you move to enforce in Israel
How Maya Ziv Law works these matters
The firm acts for clients enforcing arbitral awards and judgments with an Israeli nexus, private individuals and businesses alike, based in Israel or abroad. The approach is to characterize the regime first, pressure-test the award against the Convention's closed grounds before filing, and combine recognition with asset tracing so enforcement is not a two-step delay. Where the underlying dispute is a shareholder fight rather than a contract claim, the same enforcement mindset carries into a Section 191 oppression buyout, and where the asset to collect against is a court judgment the firm applies the parallel framework for recognizing a foreign judgment in Israel. Because elements of the surrounding procedure continue to develop after the 2024 reform, the firm confirms the live position rather than relying on pre-2024 material, and tells clients plainly where a point is settled and where it is still moving.
This article is general information about Israeli law and is not legal advice, and it does not create a lawyer-client relationship. For advice on a specific award or dispute, speak with a qualified Israeli lawyer.
Last reviewed June 2026.
Frequently asked questions
Does Israel's 2024 law apply to my old arbitration agreement
The 2024 law applies to international commercial arbitrations initiated after it came into force, regardless of when the arbitration agreement was signed. The deciding factor is when the arbitration was commenced, not the date of your contract. A dispute under an older agreement can still fall under the new regime if the arbitration itself began after the law took effect.
Can an Israeli court reject my foreign arbitral award
Only on a limited, closed list of grounds drawn from the New York Convention, such as improper notice, an award that exceeds the scope of the arbitration, a defect in how the tribunal was composed, or a conflict with public policy. An Israeli court is not permitted to re-examine the merits and decide the underlying dispute again, which is what makes a Convention award a strong asset.
Has Israel been part of the New York Convention for long
Yes. The New York Convention entered into force for Israel on 7 June 1959, and Israel incorporated it through a 1974 amendment to its arbitration framework. The 2024 law builds on that foundation and channels foreign-award enforcement through the Convention's grounds.
What is the difference between domestic and international arbitration in Israel now
Two regimes run in parallel. International commercial arbitration is governed by the International Commercial Arbitration Law 5784-2024, which follows the UNCITRAL Model Law. Domestic arbitration between Israeli parties remains under the Arbitration Law 5728-1968. The first step in any matter is identifying which regime applies, because the rules differ.
Should I still rely on guidance written before 2024
For international matters, pre-2024 commentary built on the 1968 Arbitration Law is generally outdated, and the firm treats the procedural specifics with caution and confirms them against the current rules. The substantive enforcement backbone, the New York Convention, has been in place since 1959, but the 2024 reform changed the framework around it, so older material should be checked before you act on it.
Adv. Maya Ziv advises private individuals and businesses on real estate, estate, and commercial matters, serving clients based in Israel and abroad. Before practicing law she trained in finance, holding a degree from Baruch College and working at Citi and at Vornado Realty Trust. She is admitted to the Israel Bar.