With the wave of Energy Charter Treaty (ECT) renewable energy arbitrations coming to an end, investors are seeking to enforce their awards in three continents. This article examines the first decisions issued by domestic courts in relation to the recognition and enforcement of intra- European Union (EU) ECT awards against Spain. The findings of the courts in the United States, the United Kingdom and Australia in these first enforcement cases will have an impact on the enforcement of the many awards that are pending enforcement and future awards that will be rendered in the pending cases against Spain.
Journal of International Arbitration