LIECHTENSTEIN Trends and Developments Contributed by: Michael Nueber and Philipp Konzett, Nueber Konzett
International Arbitration in Liechtenstein in 2026: Private Wealth, Court Support and Cross-Border Enforcement A stable framework with growing practical relevance The legal framework for arbitration proceedings is implemented in Sections 594 to 635 of the Liechten - stein Civil Procedure Code (ZPO). It is largely based on the UNCITRAL Model Law and the correspond - ing Austrian provisions. This gives parties a modern and recognisable arbitration framework while allowing Liechtenstein courts and practitioners to draw on the more extensive Austrian case law and academic com - mentary where no Liechtenstein authority is available. The framework makes no distinction between domes - tic and international arbitration and leaves consider - able procedural autonomy to the parties. Recent Liechtenstein case law reinforces an arbitra - tion-friendly but carefully controlled approach to judi - cial review. The courts respect the parties’ decision to arbitrate and do not treat setting-aside proceedings as an opportunity to reconsider the merits of the dispute. An award will not be annulled merely because the tri - bunal’s findings of fact are alleged to be incomplete or because its interpretation of the law may be open to criticism. Court intervention remains confined to the limited statutory grounds set out in § 628 ZPO, includ - ing serious procedural defects, lack of arbitrability and violations of fundamental principles of Liechtenstein law. At the same time, the courts examine carefully whether an award is final and enforceable and which parties, claims and legal issues are covered by its binding effect. An application to set aside must gen - erally be filed within the relatively short period of four weeks of receipt of the award, and the Liechtenstein Court of Appeal acts as the sole ordinary instance. The result is a framework that combines considerable finality with focused quick judicial control, rather than a full appeal on the facts or the law. In addition to the procedural framework, the Liechten - stein Chamber of Commerce and Industry published the so-called “Liechtenstein Rules”, which aim at providing a concise framework aiming at the specific needs of the Liechtenstein financial centre. They are designed to combine the flexibility of ad hoc arbitration with certain institutional safeguards, while maintaining
a comparatively limited administrative structure. Con - fidentiality is a particularly important feature: the Rules impose confidentiality obligations on the participants and allow measures to protect sensitive documents and information during the taking of evidence. Against this background, arbitration proceedings seated in Liechtenstein appear to be gaining in prac - tical relevance, with parties increasingly relying on the Liechtenstein Rules for both domestic and cross- border disputes. This combination of procedural flexibility, limited judi - cial review and confidentiality is particularly attractive in disputes involving family wealth, fiduciary structures or closely held businesses, where the commercial or reputational consequences of public proceedings may be significant. This also tends to the needs of one Liechtenstein’s economic cornerstones, the fiduciary industry. For parties considering Liechtenstein in practice, accessibility, cost and finality are especially relevant. Vaduz is around 75 minutes by car from Zurich and is readily accessible through nearby railway hubs. The choice of Liechtenstein as the seat is a legal rather than merely geographical decision: it subjects the arbitration to Liechtenstein procedural law and court supervision, while hearings may still be held elsewhere or conducted remotely. Costs under the Liechtenstein Rules should be assessed on a case-by-case basis and will depend on factors including the amount in dispute, the complexity of the proceedings, the num - ber of arbitrators and the parties’ legal expenses. Cross-border enforcement remains a central advantage Arbitration is becoming increasingly important in Liechtenstein, particularly in disputes involving foun - dations, trusts and other private wealth structures. Its advantages are especially significant in cross-border cases. Liechtenstein court judgments currently only benefit from bilateral enforcement treaties with Swit - zerland and Austria, which limits their effectiveness internationally. By contrast, arbitral awards are recog - nised and enforceable under the New York Conven - tion almost anywhere in the world.
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