The International Arbitration Review: Finland


In Finland, commercial disputes are frequently referred to either institutional or ad hoc arbitration. A valid arbitration agreement prevents taking the dispute to court, unless all parties wish to deviate from the agreement. The Finnish Arbitration Act (967/1992, as amended, the FAA)2 is structured to set out the legislative regime for arbitration seated in Finland and to provide a simple, flexible and cost-efficient framework for arbitration. In addition, the arbitration-friendly and rather non-interventionist attitude of the Finnish courts is manifested in legal praxis, as discussed in greater detail in Section II.ii.

Finland has provided an institutional platform for commercial arbitration for well over a hundred years.3 In the recent years, the Finland Chamber of Commerce (FAI) has actively developed its rules and practices, with the current rules entering into force in 2020.

The FAI also provides annual statistics on requests for arbitration and cases administered by the FAI. According to the 2020 statistics, the number of requests for arbitration reached a record level of 101 cases, of which 27 per cent were international.4 The FAI statistics will be discussed in Section II.iv.

i The Finnish statutory framework for arbitration

The FAA entered into force in December 1992 and has remained essentially the same from its enactment to date. The FAA applies interchangeably to both domestic and international arbitration cases seated in Finland. The FAA also contains rules governing the recognition and enforcement of foreign arbitral awards in Finland.

Finland has ratified and enacted the 1958 New York Convention without any reservations and most of its provisions are incorporated in the FAA.5 The FAA is based on the 1985 UNCITRAL Model Law on International Commercial Arbitration, but the Model Law was not implemented into Finnish law as such, and thus the FAA deviates from the Model Law in some respects. For example, an arbitration agreement governed by the FAA must be in writing.6 The 2006 amendments to the UNCITRAL Model Law have not been implemented in the FAA. Consequently, the FAA does not, for example, contain provisions relating to interim measures in support of arbitration.

Flexibility is one of the main advantages of the FAA as party autonomy is one of its governing principles.7 The parties are free to organise the proceedings as they deem fit, being subject only to a few mandatory requirements of due process.8 The objective of the FAA is to provide the parties with a final arbitral award with the same legal effects as a conventional court decision. In order to promote the finality of an arbitral award, it may not be challenged based on its merits9 but only on relatively grave procedural irregularities.10 By international comparison, one of the most distinctive features of the FAA is the possibility to challenge an arbitral award on two separate legal grounds: by arguing that is null and void (Section 40) or by requesting it to be set aside (Section 41).

ii The Finnish court system

General information

The Finnish court system is divided into general courts, administrative courts and certain special courts.

The general courts administer justice in civil cases, criminal cases and petitionary matters. The Finnish general courts comprise three tiers: 20 district courts as the courts of first instance, five courts of appeal as the first instances of appeal and the Supreme Court as the final instance of appeal, provided that the Supreme Court grants leave to appeal.

Each district court has general jurisdiction within a fixed geographical area. The district courts handle around 550,000 cases every year, of which 80,000 are criminal cases, 420,000 are civil cases and 50,000 are petitionary matters.11 The active special courts are the Market Court, the Labour Court and the Insurance Court.12

The role of courts in arbitration

As stated above, a valid arbitration clause prevents taking the dispute to court, and the Finnish courts respect the parties' freedom of contract by having a generally arbitration-friendly attitude.

The district courts may provide assistance before, during and after the proceedings upon request. The district courts may appoint arbitrators under certain circumstances13 and also provide assistance in gathering evidence.14 The district courts are also capable of ordering interim measures upon the request of a party before or during the proceedings. However, as the FAA remains silent on precautionary measures, the application is made in accordance with the provisions of the Finnish Code of Judicial Procedure (4/1734, as amended).

The courts also have a significant role when arbitral awards are challenged. It is not possible to challenge the award based on its merits or facts. In cases of procedural or other grave errors, however, the courts may set the award aside or declare it invalid. A party must bring action for setting aside the award within three months of the date on which the party received a copy of the award (Section 41 of the FAA). Taking action for declaring the arbitral award invalid (Section 40 of the FAA) is not time-barred.

If an arbitral award is challenged and the decision of the first instance is appealed, the challenge proceedings may take one to two years to complete. However, the legal praxis of Finnish courts supports the conclusion that challenges rather seldom succeed,15 and the principle of finality of arbitral awards is respected and only clear formal errors and grave procedural errors will cause interference by the Finnish courts.

iii Local institutions

The FAI16 was established in 1911 and it has operated under the auspices of the Finland Chamber of Commerce (FCC) since 1919, administering both domestic and international arbitrations governed by its rules. The FAI is also capable of appointing arbitrators in ad hoc cases and it also acts as an appointing authority under the UNCITRAL Arbitration Rules.

The FAI has two sets of arbitration rules: the FAI Arbitration Rules and the FAI Expedited Arbitration Rules. Both sets of rules were updated in 2020 and will be discussed in detail in Section II.i. Under the FAI Expedited Arbitration Rules, only one arbitrator is appointed to hear the case and the arbitral award is to be rendered within three months from the date on which the sole arbitrator received the case file. The FAI Expedited Arbitration Rules are otherwise mostly similar to the FAI Arbitration Rules, although there are some changes to promote the speed of the proceedings.

The FAI also administers mediations under the Mediation Rules of the Finland Chamber of Commerce (the FAI Mediation Rules). The FAI Mediation Rules entered into force on 1 June 2016. However, thus far the Mediation Rules have only been applied once, in 2017.

iv Statistics and trends

The FAI publishes its own annual statistics for cases it administers.

According to the statistics, the year 2020 was record-breaking in terms of new cases filed. In 2020, the FAI received a total of 101 new requests for arbitration, which converts into a substantial growth of 50 per cent in comparison to 2019 (67 new cases filed).17 Despite the increased case load, the FAI has managed to shorten the 'duration of the procedure before transmission of the case file to the tribunal'. Partially because of this, the FAI has consistently strengthened its already respectable reputation as a reliable and attractive arbitration institute.

In 2020, the majority of requests for arbitration, 75 cases, were filed under the FAI Arbitration Rules and 21 cases were filed under the FAI Expedited Arbitration Rules. The popularity of expedited arbitration is clearly increasing: in 2019, the figure was seven and in 2018 it was only two. A sole arbitrator was appointed to most of the cases filed, and this figure was 88 per cent in 2020. In 2020, the FAI registered four ad hoc cases.

Arbitration under the FAI Rules is fairly expeditious: in 2020, the median duration of arbitration under the FAI Rules was nine months (three months under the FAI Expedited Arbitration Rules).

Of all the cases filed in 2020, 27 per cent were considered 'international', meaning that they involved at least one non-Finnish party. The number of international parties has been approximately 20 to 35 per cent over the course of the last decade.18 On that note, one of the objectives of the discussed revision needs of the FAA is to attract a greater number of international users of arbitration.

The year in review

In terms of arbitration, the past few years have been quite eventful in Finland: the long-awaited revision process of the FAA was initiated, the FAI updated its rules and the Supreme Court rendered several interesting arbitration-related decisions.

i Developments affecting international arbitration

Reform of the Finnish Arbitration Act

From its enactment in 1992 to date, the FAA has remained mostly unchanged, having undergone only minor or technical amendments. In December 2016, the FCC proposed to the Ministry of Justice that the FAA should be updated.19 In 2016, the FCC also submitted the FAA to the Secretariat of UNCITRAL for comments and the secretariat recommended that Finland would modernise its statutory framework for arbitration.20 The reform of the FAA commenced in spring 2019, when the Ministry of Justice set a working group to prepare an international comparison of the statutory framework and arbitration activities of certain other European countries. The working group's report is expected to be published by the end of 2021. A confirmed objective of the reform process is to 'improve the competitiveness of Finnish arbitration activities'.21

The 2020 FAI Rules

The revised FAI Arbitration Rules and the FAI Rules for Expedited Arbitration entered into force on 1 January 2020.22 While a thorough overhaul was not necessary, considering that the 2013 FAI Rules had received good feedback, certain changes were made to increase the speed, efficiency and flexibility of FAI arbitrations. The changes are briefly presented below: 23

  1. Advances on costs are now routinely required in all arbitrations. The 2020 FAI Rules require that in all arbitrations, whether domestic or international, the parties shall pay an advance on costs fixed by the FAI.24 Under the 2013 FAI Rules, the advance on costs was routinely required only in international arbitrations.25
  2. Filing fees are fixed. As of 1 January 2020, the filing fee is set at €3,000 in standard proceedings and €2,500 in expedited proceedings. Under the 2013 FAI Rules, the filing fee depended on the amount in dispute. The new rules did not affect the framework for administrative fees or fees of the arbitrators.26
  3. Document management practices have been improved. Under the 2020 FAI Rules, case documents may be transmitted by electronic means as an alternative to a single hard copy.27 However, the FAI or the arbitral tribunal may still request for one or more hard copies if deemed necessary.28 Under the 2013 FAI Rules, certain documents (such as the request for arbitration and the answer to the request for arbitration) had to be delivered to the FAI in several hard copies.
  4. There is now flexibility in choosing the right set of FAI Rules. In order to encourage the use of expedited proceedings, the 2020 FAI Rules now provide the parties with an option to switch between the FAI Arbitration Rules and the FAI Expedited Arbitration Rules (and vice versa) prior to the confirmation of any arbitrator. The choice is naturally subject to the consent of the parties and the matter must be considered in the request for arbitration or the answer thereof.29 Additionally, the FAI may on its own motion request that the parties comment on the matter.30
  5. The appointment of a three-member tribunal is expedited. A key objective of the revision process was to promote the speed of the proceedings. In the 2020 FAI Rules, the default time limit in nominating the third and presiding arbitrator or all three arbitrators was reduced from 15 days to 10 days.31 If the parties had not agreed on the number of arbitrators and the FAI decides on a three-member tribunal, the time limit for the respondent to nominate an arbitrator has been slightly changed. Under the 2020 FAI Rules, the respondent shall nominate one arbitrator for confirmation within 10 days from the date on which the respondent received the notification from the FAI of the arbitrator nominated by the claimant.32 Under the 2013 FAI Rules, the time limit was calculated from the confirmation of the arbitrator nominated by the claimant.33
  6. An indicative time limit was set for arranging a case management conference. Holding a case management conference as soon as possible promotes the expeditiousness of the proceedings. While the 2013 FAI Rules were silent on a time limit for arranging a case management conference, the 2020 FAI Rules expressly dictate that the arbitral tribunal shall arrange a case management conference as soon as possible, in principle within 21 days of the date on which the arbitral tribunal received the case file from the FAI.34 For expedited proceedings, the indicative time limit is 14 days.35
  7. Arbitral tribunals are now expressly authorised to issue confidentiality orders. In the 2013 FAI Rules, the parties, the FAI and the arbitral tribunal were under an express obligation to respect the confidentiality of the arbitration and the award.36 The arbitral tribunals did not, however, have express mandates to issue confidentiality orders. Under the 2020 FAI Rules, upon the request of any party, the arbitral tribunal may issue orders concerning the confidentiality of the arbitration proceedings or any other matters in connection with the arbitration.37
  8. Party misbehaviour is further sanctioned. Under the 2013 FAI Rules, the arbitral tribunal was entitled to take into consideration party misbehaviour when deciding on the allocation of costs.38 This concept is rooted further in the 2020 FAI Rules, as it is now explicitly stated that if the arbitral tribunal determines that a party has failed to comply with its duties, the tribunal may, in addition to any other measures available under the Rules or otherwise, take such failure into account in its allocation of the costs of the arbitration.39

Arbitration practices

In Finland, court procedures are generally public, including judgments and all written material submitted to the courts, whereas the principle of publicity does not apply to arbitration. Since the enactment of the FAA, the general opinion has been that an award may not be published, unless all the parties otherwise agree or the award has become public through other means (e.g., because of an arbitration-related court proceeding).40 It is generally accepted that not only the disputing parties, but also the arbitrators must give their express consent before an award is to be published.41 Information relating to the arbitration as well as the arbitral award might become public when, for example, the award is contested or enforced.

Pursuant to Article 51.5 of the FAI Arbitration Rules, the FAI reserves the right to publish anonymised summaries or excerpts of selected awards, orders or other decisions, unless otherwise agreed by the parties. Up until 2018, the FAI also published these anonymised excerpts or summaries on its website.42

As a general remark, the FAA does not explicitly require that the final award contains reasoning, unless the parties otherwise agree. Under the current FAI arbitration rules, however, the award has to be reasoned, unless the parties have agreed that no reasons are to be given.43

ii Arbitration developments in local courts

As stated above, Finnish courts have a generally arbitration-friendly and non-interventionist attitude towards arbitration, as indicated by the recent Finnish Supreme Court precedents briefly presented below.

An arbitral tribunal is empowered to disregard arguments presented late in proceedings (KKO 2018:48)

In June 2018, the Supreme Court upheld the validity of an arbitral award in challenge proceedings, where it was assessed whether the respondent was provided sufficient opportunity to present its case.44

During the arbitration proceedings, the respondent opposed the claimant's damages claim without submitting any specific grounds concerning the amount of the claim before the written closing statement submitted after the hearing. The sole arbitrator disregarded these arguments as they were presented late. The respondent subsequently initiated setting-aside proceedings in the Helsinki District Court, arguing that the arbitrator had not given the respondent sufficient opportunity to present its case.45

Eventually, the case was heard before the Supreme Court, which dismissed the respondent's claims. The Supreme Court noted that the FAA does indeed dictate that a party may amend or supplement its claim during the proceedings, unless the arbitration would be unduly delayed.46 However, it is within party autonomy to deviate from the said provision. In this case, the parties had agreed on a procedural timetable, but as it did not expressly include a 'due date' for new arguments, the Supreme Court reasoned that Section 25 of the FAA applied.

According to the Supreme Court, it is within an arbitral tribunal's margin of discretion to decide what kind of party behaviour creates undue delay to arbitration. Moreover, the Supreme Court reasoned that the respondent was given sufficient opportunity to present its case, as no valid explanations were given why the arguments were not presented earlier in the proceedings.

The judgment confirms that an arbitral tribunal has a rather wide margin of discretion in conducting the proceedings and that the threshold is rather high for finding that a party was not given sufficient opportunity to present its case.

Binding effect of an arbitration agreement on the bankrupt pledgor's creditors (KKO 2019:64)

In 2019, the Supreme Court heard a case concerning the binding effect of an arbitration agreement with regard to a pledgor's creditors (i.e., third parties to a pledge agreement, in the pledgor's bankruptcy). The case also concerned the arbitrators' authority in resolving claims pertaining to a pledge agreement.

Companies A and B had entered into a pledge agreement over certain receivables that included an arbitration clause. Later, pledgor A was declared bankrupt and B initiated arbitration against the bankruptcy estate of A. B requested the arbitral tribunal to confirm that the pledge had been duly perfected and that the pledge agreement was in force and bound the bankruptcy estate. The arbitral tribunal granted B's claims.

The Supreme Court set aside the arbitral award in part and held that the arbitral tribunal had exceeded its authority. The Supreme Court stated that, among other things, a bankruptcy estate cannot be bound by an arbitration agreement regarding in rem protection as such agreements cannot be made to the detriment of third parties. In addition, the Supreme Court noted that the arbitral tribunal had confirmed that the pledge had been duly perfected before A was declared bankrupt, and thus confirmed a direct effect on bankruptcy estate A's creditors who were not parties to the pledge agreement or the arbitration agreement.

Consequently, an arbitration agreement remains valid and binding on a bankruptcy estate unless it is a matter on which the debtor could not have agreed on before the bankruptcy with a binding effect towards the bankruptcy estate.

Binding effect of an arbitration agreement on a guarantor (KKO 2019:111)

In the Supreme Court case KKO 2019:111, the question was whether the arbitral tribunal had exceeded its authority when it had decided a matter in respect of a guarantor, a third party to a loan agreement, on the basis of the arbitration clause included in the loan agreement concluded between the parties.

The loan agreement between companies A and B was subsequently amended by separate amendment agreements that all contained a dispute resolution clause that referred to the arbitration clause in the original loan agreement. However, the dispute resolution clause in the guarantee undertaking, where company C became a guarantor for B's debt to A, provided that the disputes arising out of the guarantee undertaking may be heard before Helsinki District Court. In the last amendment agreement between A and B, also C agreed that it would accept the amendment agreement of the loan agreement. A initiated arbitration proceedings against B and C jointly for the repayment of the loan under the loan agreement and the amendment agreements, but C contested the arbitral tribunal's jurisdiction.

When deciding the case, the Supreme Court considered that C was bound by the arbitration agreement in this particular case because of the particular circumstances, including the fact that the loan agreement, the amendment agreements and the guarantee undertaking were parts of the overall arrangement between the companies concerning the principal loan. The Supreme Court also stated that there is a practical need to concentrate the resolution of commercial disputes concerning the same overall arrangement to one dispute resolution method.

However, following the case-by-case assessment rule, the judgment does not provide generally applicable rules as to the binding effect of arbitration agreements in loan agreements extending to all guarantors unless there are particular circumstances.

The validity of an arbitration clause in a business transfer (KKO 2020:89)

In December 2020, the Supreme Court rendered a judgment relating to the validity of an arbitration clause in a transfer of a business.47 The Supreme Court decided that a transferee in a business transfer was not bound by a previous arbitration clause in an agency agreement, irrespective of the fact that the transferee and the agent had conducted mutual business for several years after the initial business transfer. The parties' agreement that contained an arbitration clause followed directly from the business transfer. The agency agreement, and its arbitration clause, was originally drafted between the transferor and the agent.

As the parties disagreed on the financial consequences relating to the termination, the agent was determined to commence arbitration pursuant to the arbitration clause in the agency agreement. The FAI, as the administrative body under the arbitration clause, decided that the arbitration clause was not binding between the transferee and the agent. Consequently, the agent initiated court proceedings, requesting the court to declare the arbitration clause as valid and binding between the parties.

The Supreme Court ruled that the transferee was not bound by the arbitration clause and reasoned that the doctrine of separability requires that the arbitration clause and the main agreement cannot be interpreted interchangeably when determining the validity of an arbitration clause.48 Accordingly, in order for the arbitration clause to be binding, the transferee should have had accepted the arbitration clause separately. Having reviewed the case, the Supreme Court decided that there was not enough evidence to support that the transferee would have accepted the arbitration clause and held that the arbitration clause was not binding between the parties.

The case demonstrates that in the context of business transfers, the arbitration clauses within main agreements need to be clearly defined or otherwise visibly approved to avoid unnecessary disputes.

iii Investor–state disputes

At present, Finland is a contracting party to 64 bilateral investment treaties as well as numerous investment-related instruments, including the International Centre for Settlement of Investment Disputes (ICSID).49 The majority of investment treaties include investor–state dispute settlement provisions in case of a dispute between an investor and a contracting party. To the best of the authors' knowledge, however, there is no case law pertaining to an investor–state dispute involving Finland. However, based on the recent rise in the number of registered ICSID cases, investor–state disputes relating to Finland may also be looming on the horizon.

Outlook and conclusions

Finland is a reliable and expeditious seat for international commercial arbitration. Finland is politically neutral, corruption is virtually non-existent and Finnish courts have a non-interventionist attitude towards arbitration. Furthermore, the Finnish arbitration framework leaves ample room for party autonomy and contains only a few mandatory provisions. The FAI also offers modern state-of-the-art arbitration rules catering to the needs of the most demanding domestic and international cases.

Although the FAA currently in force works well, there has been discussion about needs for reform.50 In the meanwhile, recent FAI statistics go to show that even the current Finnish arbitration regime is suited for the needs of both international and domestic users of arbitration.


1 Kirsi Kannaste and Thomas Kolster are partners and Laura Tuure is an associate at Krogerus Attorneys Ltd. The authors would like to convey their thanks and appreciation to associate elect Julius Jauhiainen for his extensive background research and substantial contributions to the chapter.

2 The FAA is not officially translated into English. An unofficial translation by Finland's Ministry of Justice is available at Finlex, an online database of up-to-date legislation and other judicial information of Finland operated by the Ministry of Justice:

3 See the FAI, 'History of the Finland Arbitration Institute'. No date. Available at: Last accessed 10 March 2021.

4 The FAI statistics for the year 2020 and four preceding years are available at:

5 See Gustaf Möller, 'National Report for Finland' in Jan Paulsson, ed., International Handbook on Commercial Arbitration (Wolters Kluwer 2018) pp. 28–29.

6 Section 3.1 of the FAA.

7 Government Bill HE 202/1991 vp, p. 3.

8 See, e.g., pursuant to Section 22 of the FAA, '[t]he arbitrators shall give the parties sufficient opportunity to present their case'. Failure to do so constitutes a basis for setting the arbitral award aside upon request, as dictated in Section 41.1,4 of the FAA.

9 As long as the Finnish public policy is not violated.

10 These procedural irregularities are listed in Sections 40.1 and 41.1 of the FAA. Section 40.1 of the FAA contains a list of grounds for declaring the award invalid. Section 41.1 of the FAA contains a list of grounds for setting aside the award. Both lists are exhaustive.

11 See, e.g., 'Finnish ordinary courts' on the European e-Justice Portal. Available at:

12 Ad hoc tribunals are not permitted under the laws of Finland. Section 98.4 of the Finnish Constitution (731/1999, as amended) explicitly prohibits provisional courts.

13 Sections 14 to 17 of the FAA. Cases where courts would intervene in the selection of arbitrators are rare.

14 Section 29 of the FAA.

15 See the Supreme Court's (in Finnish korkein oikeus, abbreviated as KKO) Decision No. KKO 2008:77, where paragraph 10 of the judgment of the Supreme Court stated that the usability of arbitration as a method of solving commercial disputes depends largely on the binding nature and enforceability of an arbitral award and that only clear formal errors and relatively grave procedural errors may result in the invalidity or setting aside of an arbitral award.

17 See the FAI, 'Record number of 101 new cases filed with the Finland Arbitration Institute (FAI) in 2020'. 13 January 2021. Available at:

18 See the FAI, 'Statistics'. Available at:

19 The proposal titled 'Ehdotus välimiesmenettelylain uudistamiseksi' (in Finnish) is available at:

20 UNCITRAL, 'Comments of the Secretariat of the United Nations Commission on International Trade Law (UNCITRAL) on the basis of the unofficial translation from Finnish provided by the Finland Arbitration Institute'. 10 October 2016. Available at:

21 The Ministry of Justice's information about the ongoing reform process (in Finnish) is available at:

22 All FAI Rules are available at:

23 The following summary of the changes is based on the article 'Revised Arbitration Rules of the Finland Chamber of Commerce to enter into force on 1 January 2020' as published by the FAI on 17 December 2019. The article is available at: of-the-finland-chamber-of-commerce-to-enter-into-force-on-1-january-2020/.

24 See Article 50 of the 2020 FAI Arbitration Rules.

25 See Article 48 of the 2013 FAI Arbitration Rules.

26 See Appendix II of the 2020 FAI Arbitration Rules.

27 See Article 4.1 of the 2020 FAI Arbitration Rules.

28 See Article 4.5 of the 2020 FAI Arbitration Rules.

29 See Article 6.3(i) and 8.2(g) of the 2020 FAI Arbitration Rules.

30 See Article 10.1 of the 2020 FAI Arbitration Rules.

31 See Article 18.2 and 19.1(d) of the 2020 FAI Arbitration Rules.

32 See Article 19.2(b) of the 2020 FAI Arbitration Rules.

33 See Article 18.2(b) of the 2013 FAI Arbitration Rules.

34 See Article 30.1 of the 2020 FAI Arbitration Rules.

35 See Article 29.1 of the 2020 FAI Expedited Arbitration Rules.

36 See Article 49.1 of the 2013 FAI Arbitration Rules.

37 See Article 51.3 of the 2020 FAI Arbitration Rules.

38 See Article 25.3 of the 2013 FAI Arbitration Rules.

39 See Article 49.4 of the 2020 FAI Arbitration Rules.

40 See G Möller, 'National Report for Finland', footnote 5, pp. 28–29.

41 As an important exception, information on arbitrations relating to the redemption of minority shares is, in general, public. However, in the event of a dispute relating to the redemption of minority shares, arbitration is expressly required on a statutory basis (i.e., the Finnish Limited Liability Companies Act (624/2006, as amended)).

42 Some of these summaries and excerpts are still available on FAI's website. See

43 See Article 43.1 of the 2020 FAI Arbitration Rules. On the contrary, the opposite holds true in expedited proceedings. Pursuant to Article 41.1 of the 2020 FAI Rules for Expedited Arbitration, an award shall not contain reasons, unless a party has requested a reasoned award within the time limit set by the sole arbitrator.

44 Decision No. KKO 2018:48, Case No. S2017/54 (26 June 2018).

45 Pursuant to Section 41.1,4 of the FAA, '[a]n award may be set aside by the court upon request of a party if the arbitrators had not given a party sufficient opportunity to present his or her case'.

46 Section 25.2 of the FAA.

47 Decision No. KKO 2020:89, Case No. S2019/146 (1 December 2020).

48 See paragraph 36 of Decision No. KKO 2020:89.

49 See the UNCITRAL, 'International Investment Agreements: Finland'. No date. Available at:

50 See footnote 19 and Mika Savola, 'Miksi ja miten välimiesmenettelylakia tulisi muuttaa?'. Defensor Legis 4/2017, pp. 501–513. See also Christopher R Seppälä, 'Why Finland Should Adopt the UNCITRAL Model Law On International Commercial Arbitration'. Liikejuridiikka 3/2016, pp. 188–210.

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