Years of Progress: The Development of the Singapore Convention on Mediation

This year, the United Nations Convention on International Settlement Agreements Resulting from Mediation, commonly referred to as the Singapore Convention on Mediation, has celebrated its 6th year anniversary since it opened for signature on 7 August 2019. In just six years, the Convention’s benefits have been increasingly recognised by nations, acknowledging mediation’s value in the international dispute resolution ecosystem. This article aims to reflect on the Convention’s history, its current standing, and its ongoing role in promoting the growth and acceptance of mediation worldwide.

I. History of the Singapore Convention on Mediation

During the past decade, the United Nations Commission on International Trade Law (UNCITRAL) began working on a treaty to address the enforcement gap of international settlement agreements resulting from conciliation proceedings. In July 2014, the Working Group II (Dispute Settlement) agreed to consider the matter and report back to the Commission at its forty-eighth session on the feasibility of carrying out further progress in the field. In July 2015, the Commission took note of the considerations and tasked the Working Group II to continue identifying relevant issues and exploring prospective solutions. 

A rapid progress was made in the coming years, culminating in the finalization of the draft Convention at the fifty-first UNCITRAL Commission session in 2018. In December 2018, the United Nations General Assembly adopted the resolution by consensus, and opened the Convention for signature with a signing ceremony held on 7 August 2019 in Singapore. Endorsing the Convention’s uniform enforcement framework for mediated settlements, 46 countries already signed the Convention during the ceremony, including large economies such as the US, China, India, and South Korea. The first ratifications were deposited by Singapore and Fiji in the coming year on 25 February 2020, followed by Qatar on 12 March 2020.

In accordance with Art. 14(1) of the Convention, which requires that the Convention shall enter into force six months after the deposit of the third instrument of ratification, acceptance, approval or accession, the entry into force officially occurred on 12 September 2020. 

II. Status of the Singapore Convention on Mediation and its Significance for the Global Mediation Community in 2025

1. Signatories and Contracting Parties to the Convention

The Convention is the third complementary piece to existing influential multi-national treaties in the field of international dispute resolution, namely the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (“New York Convention”) and the Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters (“The Hague Convention”). 

An increasing number of countries recognise the Convention as a transformative step in global dispute resolution. By encouraging the use of mediation for both commercial and investor-state disputes, the Convention reduces reliance on courts and arbitration and empowers businesses to confidently settle cross-border disputes, as their agreement will become legally enforceable abroad. As of 13 October 2025, the Convention has 58 signatories and 19 parties that have formally recognised its benefits and agreed to adhere to its terms.

The Convention has been signed by the following 58 States: Afghanistan, Armenia, Australia, Belarus, Benin, Brazil, Brunei Darussalam, Chad, Chile, China, Colombia, Congo, Democratic Republic of Congo, Ecuador, Eswatini, Fiji, Gabon, Georgia, Ghana, Grenada, Guinea-Bissau, Haiti, Honduras, India, Iran (Islamic Republic of), Iraq, Israel, Jamaica, Jordan, Kazakhstan, Lao People’s Democratic Republic, Malaysia, Maldives, Mauritius, Montenegro, Nigeria, North Macedonia, Pakistan, Palau, Paraguay, Philippines, Qatar, Republic of Korea, Rwanda, Samoa, Saudi Arabia, Serbia, Sierra Leone, Singapore, Sri Lanka, Timor-Leste, Turkey, Uganda, Ukraine, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, and Venezuela (Bolivarian Republic of).

Additionally, the following States have ratified, accepted, approved, or acceded to the Convention: Bahrain, Belarus, Brazil, Costa Rica, Ecuador, Fiji, Georgia, Honduras, Israel, Japan, Kazakhstan, Nigeria, Paraguay, Qatar, Saudi Arabia, Singapore, Sri Lanka, Turkey, and Uruguay. On this list, Brazil is the most recent Contracting Party to ratify the Convention, representing its commitment to advancing international trade and promoting the use of alternative dispute resolution.

2. Growing Interest in the UK, US, and the EU

The Ministry of Justice of the United Kingdom (UK) launched a public consultation that ran between February and April 2022 to seek views from stakeholders in the mediation sector on whether the UK should sign and ratify the Convention. The 2022 public consultation helped inform the public of the Convention’s purpose and key provisions, as well as outline feedback gathered from prior informal consultations. As a direct result, the UK signed the Convention on 3 May 2023, indicating a step towards deepened endorsement of mediation’s important role in resolving international disputes and promoting access to justice. 

In 2025, the Government is again consulting its UK stakeholders and experts in the field of mediation to gather proposals on how the Convention could be implemented into domestic law. Within the 2025 public consultation, it is noted that as part of the process, it is likely that Regulations will be laid in the UK Parliament under the Private International Law (Implementation of Agreements) Act 2020. The intention is to have uniform implementing provisions extending UK-wide. The questions specifically relate to the registration of internationally mediated settlement agreements, definitions within the Convention, grounds for refusal, enforceability, and implementation of the Convention. The public consultation closes on 29 October 2025.

In the United States (US), another significant jurisdiction, robust discussions on the advantages and modalities of ratification of the Convention have been taking place over the past years as well. The American Bar Association (ABA) passed a resolution by the ABA’s House of Delegates in early 2020, and through this resolution urged the US to become party to Convention. Last year on March 22, 2024, the US Uniform Law Commission (ULC) Executive Committee unanimously approved its Study Committee’s report on the UN Convention on International Settlement Agreements Resulting from Mediation. Recognising the benefits of the Convention, the Study Committee encourages the increased use of mediation when resolving commercial disputes. The Committee’s proposal that the ULC expresses support for the US ratification of the Convention represents another major milestone. 

Significantly, the Committee made further recommendations to the ULC, suggesting that certain articles should be formally addressed upon the possible US ratification of the Convention. These recommendations include that settlement agreements in the meaning of Art. 5(1)(b)(i) should be seen as encompassing agreements that are voidable at the option of the party resisting relief. They also address that a reference to rules of procedure in the meaning of Art. 3 refers to privileges and other evidentiary rules, and that under Article 13(3)(a), federal courts would apply state law on protection of mediation confidentiality as rules of procedure in cases arising under the Convention. Finally, the Committee highlighted that when considering the method of implementation, the Convention should be ratified as a self-executing treaty rather than being implemented via legislation at the state or federal levels.

IMI is proud to have been able to participate in the detailed work of the ULC Study Committee as an international observer, represented by Honorary Director Debbie Massucci, Executive Director Ivana Ninčić Österle, and Board Member David Weiss. IMI strongly supports the conclusions of the above-mentioned report, especially understanding that ratification will increase efficiency, predictability, and leadership in promoting of appropriate dispute resolution, by a major jurisdiction and economy. Notably, ratification of the Convention is a means to advance mediation and to influence interpretation and best practice.

With regards to developments in the European Union (EU), European Law Institute (ELI) Slovenian Hub and the Forum for International Conciliation and Arbitration (FICA) organised a Roundtable on the Position of the European Union on the Singapore Convention on Mediation on 18 June 2021. The roundtable culminated in a report outlining the discussion around questions such as whether the EU has exclusive or shared competence to accede to the Convention. The stakeholders attending from several EU bodies and organisations also explored the Convention’s impact and its relationship with existing EU laws like the Mediation Directive 2008/52/EC.

In the same year, European Commission (Directorate General for Justice and Consumers, Civil Justice Unit) organised an online workshop, gathering experts from the fields of mediation, law, business, and academia. Reporting on this occasion, Irish Judge Paul Gilligan wrote a detailed elaboration of the proceedings of the workshop. Judge Gilligan highlighted that some arguments were presented in favour of the EU considering accession, with representatives also debating individual member states signing the Convention if unanimity is not achievable. 

Additionally, the European Union Intellectual Property Office (EUIPO) published a Position Paper on the Singapore Convention on Mediation in 2022, showcasing a strong institutional support within the EU. Prepared by the ADR-SAB Working Group 3, the position paper serves as a key document in providing stakeholders with essential information on the Convention’s features and impact, while asserting that accession would be an advantage to EU businesses, maintaining the EU’s competitive position globally.

III. IMI’s Ongoing Support for the Singapore Convention on Mediation

IMI has long supported and had the privilege to contribute to all phases of the development of the idea of the Convention. Besides observing the work of the USA Uniform Law Commission (ULC) Study Committee as outlined above, IMI was involved in a number of projects supporting the adoption of the Convention at its early stages.

Focus on enforceability as a policy action for international mediated settlements was a direct result of consultations conducted between 2016 and 2017 through the Global Pound Conference (‘GPC’) Series, an initiative launched and conducted by IMI. In 2017, IMI collaborated with the Institute for Dispute Resolution (IDR) at New Jersey City University to conduct a Research Survey on the Enforceability of Mediated Settlement Agreements. The survey aimed at exploring the views of businesses on whether cross-border mediated settlements are enforceable on a global scale, to present it to the UNCITRAL Working Group II and assist their deliberation in adopting the Convention.

In 2021, the IMI/CCA/Strauss Institute Mixed Mode Taskforce published a series of articles in the New York Dispute Resolution Lawyer, including The Impact of Enforcement on Dispute Resolution Methodology article, co-authored by Kathleen Paisley and Jane Player. Additionally, IMI regularly updates the mediation community on important developments and the most recent ratifications of the Convention. 

This year, IMI established its Mediation Public Policy Committee with the goal of promoting the integration of mediation into public policy, legislative and regulatory frameworks, and governmental practices on a global scale. Among its initial projects, the Committee is tasked with providing more structured support to the further understanding and adoption of the Singapore Convention on Mediation. The Committee’s mission and primary objectives are outlined in detail in the full announcement and the Committee’s Terms of Reference.

IV. Future Outlook

An overall trend can be seen that the Convention is receiving greater acceptance, leading to mediation becoming a trusted mode of alternative dispute resolution worldwide. States that have already signed and ratified the Convention need to continuously promote the Convention, triggering more conversation and action from relevant stakeholders. Institutional and organisational support further elevates the visibility and recognition of the benefits of enforceable mediated settlements. IMI intends to continue providing structured support to increase awareness of the Convention, with the hope that the regime will result in harmonised outcomes for the betterment of the field of international mediation.

V. Bibliography and Useful Resources

• UN. (2019). United Nations Convention on International Settlement Agreements Resulting from Mediation. Access link.
• Singapore Convention on Mediation website, managed by Singapore International Dispute Resolution Academy (SIDRA), with the support of Ministry of Law, Singapore. Background to the Convention. Access link.
• Singapore Convention on Mediation website, managed by Singapore International Dispute Resolution Academy (SIDRA), with the support of the Ministry of Law, Singapore. Jurisdictions. Access link.
• SMU, SIDRA. A Handbook on the Singapore Convention on Mediation. Access link.
• UNIS Press Release. Brazil Ratifies the Singapore Convention on Mediation. 11 August 2025. Access link.
• UK Ministry of Justice. (2022). Consultation on the United Nations Convention on International Settlement Agreements Resulting from Mediation (New York, 2018) (the “Singapore Convention on Mediation”). Access link.
• UK Ministry of Justice. (2025). Consultation on implementing the Singapore Convention on Mediation. Access link.
• The Better Conflicts Audio Experience by CEDR. Podcast from 27 April 2022 “Should the UK Sign the Singapore Convention”. Access link.
• American Bar Association Adopted by the House of Delegates. (2020). Resolution. 104A. Acces link.
• Dr. Herman Verbist. (2022). Report on “Roundtable on the Position of the European Union on the Singapore Convention on Mediation” organized on 18 June 2021 by the European Law Institute (ELI) Slovenian hub and the Forum for International Concilation and Arbitration (FICA). Access link.
• Directive 2008/52/EC of the European Parliament and of the Council of 21 May 2008 on certain aspects of mediation in civil and commercial matters. Access link.
• Paul Gilligan. (2021). Report of the Workshop on EU’s position with regard to the Singapore Convention. Access link.
• EUIPO. (2022). ADR- SAB Working Group 3: position paper on the Singapore Convention on Mediation. Access link.
• Harold Abramson. (2019). Singapore Mediation Convention Reference Book Singapore Mediation Convention Reference Book. Access link.
• International Mediation Institute. (2014). IMI and the United Nations. Access link.
• International Mediation Institute. GPC Series Data and Reports. Access link.
• International Mediation Institute. Survey on the Enforceability of Mediated Settlement. Access link.
• Kathleen Paisley and Jane Player. (2021). The Impact of Enforcement on Dispute Resolution Methodology. Access link.
• International Mediation Institute. (2018). IMI Briefing Paper on the Singapore Convention. Access link.
• International Mediation Institute. (2025). Brazil Ratifies the Singapore Convention on Mediation. Access link.