A Haute-Savoie engineering company obtains in November 2026 a SIAC award declaring it creditor of 4,100,000 Singapore dollars against an Asian group. The award is in English, signed electronically, and the sole arbitrator sat in Singapore. The debtor does not pay, but it holds a French subsidiary and receivables from two customers established in France. The question then becomes the only one that matters: what is that document worth before a French judge, and how quickly can it become an enforceable title.
This page deals with recognition and enforcement in France of an award made in Singapore: the treaty framework, why French law is more generous than the New York Convention, the application to the judicial court of Paris, the debtor’s appeal and its lack of suspensive effect, review for international public policy, and what the decree of 6 August 2026 changes on 1 January 2027.
1. What a Singapore award is worth in France
Singapore acceded on 21 August 1986 to the Convention on the Recognition and Enforcement of Foreign Arbitral Awards, done at New York on 10 June 1958, and France ratified it on 26 June 1959. One hundred and seventy two States are parties today. Both countries are therefore bound by the same instrument, which removes at the outset the reciprocity questions that complicate enforcement of foreign judgments.
The principle laid down by French law fits in one sentence: arbitral awards are recognised or enforced in France if the party relying on them establishes their existence and if such recognition or enforcement is not manifestly contrary to international public policy (code of civil procedure, article 1514). Two conditions only, one evidential, one substantive, and an adverb that confines review to what is manifest.
The contrast with the regime for court judgments is worth measuring. A judgment of a Singapore court falls, absent an applicable bilateral treaty, under the general law of enforcement, with review of indirect jurisdiction, procedural regularity and conformity with international public policy. From the enforcement standpoint alone, an arbitration clause is worth more than a jurisdiction clause.
2. Why French law is more favourable than the Convention
The New York Convention allows the requested State to refuse enforcement in several cases, including where the award has been set aside in its country of origin. French law does not adopt that ground: the Court of Appeal may refuse recognition or enforcement only in the five exhaustively listed cases, which concern the tribunal’s jurisdiction, the regularity of its constitution, compliance with its mission, due process and international public policy (articles 1520 and 1525).
The bridge between the two texts is article VII of the Convention, which preserves the right of an interested party to rely on the more favourable law of the country where enforcement is sought. On that basis the Court of Cassation held that an award made in Switzerland and then set aside there remained enforceable in France, its existence subsisting despite the annulment (Cass. 1re civ., 23 March 1994, no. 92-15.137).
The formula was then taken to its conclusion: an international award, which is not attached to any national legal order, is an international judicial decision whose regularity is examined under the rules applicable in the country where recognition and enforcement are sought (Cass. 1re civ., 29 June 2007, no. 05-18.053). The consequence is decisive for a French creditor: even if the debtor obtains annulment in Singapore, the award may still take effect in France.
That advantage is lost by waiting. A debtor anticipating enforcement in France has every interest in organising its insolvency while the creditor wonders whether it should first resist the challenge in Singapore. The answer is that it does not have to choose: the French enforcement procedure can be started without waiting for the outcome of the foreign challenge.
3. The application to the judicial court of Paris
Jurisdiction is centralised and that is a convenience. Where the award was made abroad, forced execution requires an enforcement order of the judicial court of Paris, to the exclusion of any other court (article 1516). It does not matter where the assets to be attached are: there is a single door.
The procedure is not adversarial. The application is filed at the registry by the more diligent party, together with the original of the award and a copy of the arbitration agreement, or copies satisfying the conditions required for their authenticity (article 1516). The debtor is therefore neither summoned nor heard at that stage, which explains the speed of the order and the brevity of the review.
Two requirements deserve attention. If the documents are not in French, the applicant produces a translation, and may be required to have it made by a translator on a list of judicial experts or authorised in a Member State of the European Union (article 1515). Enforcement is then endorsed on the award and, where applicable, on the translation (article 1517). A SIAC award in English therefore requires a translation, whose cost and lead time are prepared in advance.
An order refusing enforcement must give reasons (article 1517). One granting it need not, and it is open to no separate challenge, the debate moving to the appeal provided for by article 1525. For the creditor the advantage is plain: it obtains a title before the other side has been able to say anything at all.
4. The debtor’s appeal, and why it suspends nothing
A decision ruling on an application for recognition or enforcement of an award made abroad may be appealed, within one month of service of the decision (article 1525). The parties may agree another method of notification where the appeal targets the award bearing the enforcement order. Before a court sitting in metropolitan France, that period is extended by two months for persons resident abroad (article 643), which gives an Asian debtor three months.
The appeal has no suspensive effect (article 1526). The creditor may therefore take enforcement measures as soon as the order is obtained, without waiting for the outcome. The First President sitting in summary proceedings, or the pre trial judge once seised, may stay or adjust enforcement where it is liable seriously to prejudice the rights of one of the parties. The test is demanding, and an assertion of cash flow difficulty does not meet it.
That absence of suspensive effect is the creditor’s principal asset, and it governs the chronology of the case. Obtain the order, serve it, then attach, before the opponent has organised its defence on the merits: the sequence is prepared even before the award is made, by identifying assets and preparing the translation.
5. The real battleground: international public policy
Reading the texts makes enforcement look like a formality, and it is one. The litigation begins on appeal, when the debtor chooses, among the five cases of article 1520, the one offering the best prospects. The most formidable complaint is not irregular constitution of the tribunal, but conflict with international public policy, the only case where the French judge agrees to reopen the facts.
The prohibition of money laundering belongs to international public policy, and it falls to the judge to determine whether recognition or enforcement of the award would obstruct the objective of combating money laundering by allowing a party to benefit from the proceeds of such activities, that inquiry being neither confined to the evidence produced before the arbitrators nor bound by their findings, assessments and characterisations (Cass. 1re civ., 23 March 2022, no. 17-17.981).
Compliance with substantive international public policy cannot be made conditional on a party’s conduct before the arbitrator either, and no limit is placed on the Court of Appeal’s power to investigate in law and in fact all the elements concerning the defects listed in the code (Cass. 1re civ., 7 September 2022, no. 20-22.118). For a French company that case law has two faces: it protects against enforcement of an award born of a corrupt arrangement, but it also exposes a favourable award obtained in a sensitive sector to review far more intrusive than Singapore’s.
6. What the decree of 6 August 2026 changes
Decree no. 2026-741 of 6 August 2026 containing various measures to clarify and modernise arbitral procedure, published in the Journal officiel of 7 August 2026, takes effect on 1 January 2027. It amends Book IV of the code of civil procedure and brings, for international arbitration, five changes of direct interest to the creditor under a Singapore award.
Proof of the existence of the award is made lighter: producing a copy of the award and of the arbitration agreement will suffice, the requirement of the original disappearing (articles 1515 and 1516 as amended). A free standing recognition procedure is created, available before the judicial court of Paris for awards made abroad, including incidentally (new article 1516-1). Refusal of enforcement or recognition must still be reasoned (new article 1517).
Before the Court of Appeal, two innovations matter for an Asian case. Parties will be able to put documents in a foreign language into the record without translation, the pre trial judge being able to order one at the expense of a party it designates (new article 1527-3), and parties, witnesses, experts and counsel may be authorised to speak in a foreign language (new article 1527-4). The court will finally be able to adapt the reasoning of its decision and the manner of its publicity to the needs of confidentiality (new article 1527-5).
One point runs the other way for the debtor. The First President will no longer be able to adjust enforcement, but only to suspend it, by an order open to no challenge (article 1526 as amended). The negotiating room that existed around an adjustment, partial enforcement or enforcement against security, therefore disappears in favour of a blunter alternative.
7. Transitional law, or why the date of the award governs everything
The decree does not apply uniformly from 1 January 2027, and that nuance is worth reading before settling a timetable strategy. Three distinct transitional tests are used (decree no. 2026-741, article 22). The new definition of international arbitration applies where the arbitration agreement was concluded after that date. Certain provisions on the constitution of the tribunal apply where it was constituted afterwards.
The third test is the one that concerns the creditor: articles 1515, 1516, 1516-1, 1517, 1521, 1523, 1524, 1525 and 1526 to 1527-5, that is the whole block on recognition, enforcement and remedies, apply in their form derived from the decree to awards made after 1 January 2027. It is therefore the date of the award, not the date of the application, that determines the regime.
The consequence is concrete. A SIAC award made on 20 December 2026 and presented for enforcement in 2028 will still fall under the texts derived from the 2011 decree: original award required, no free standing recognition procedure, no foreign language documents without translation before the Court of Appeal. An award made a few weeks later will benefit from the lighter regime. In an arbitration whose outcome is expected around the turn of the year, that detail deserves to be brought to the tribunal’s attention while the timetable is still being discussed.
Two articles escape that division and do not change: article 1514, which lays down the conditions of recognition, and article 1520, which lists the five grounds of challenge. The core of the French regime therefore remains identical, only the procedural machinery is modernised.
8. After enforcement: a title, and ten years to use it
No text fixes a period within which enforcement of a foreign award must be sought. Neither the code of civil procedure nor the New York Convention confines the application within a time bar, and it is better said that way than by inventing a deadline. The calendar constraint lies elsewhere, and it is twofold.
The first concerns the claim itself, which is time barred under the law governing it. The second concerns the title: arbitral awards declared enforceable by a decision not open to a challenge with suspensive effect constitute enforceable titles (code of civil enforcement procedures, article L. 111-3, 2), and enforcement of such titles may be pursued only for ten years, unless actions to recover the claims recorded are subject to a longer period (article L. 111-4).
The real risk is therefore not the time bar on the application, but dissipation of assets while one hesitates. A debtor that has lost the arbitration has the time of the translation, the filing and the service to empty its French subsidiary. That is why conservatory measures are prepared alongside the application, not after it.
Frequently asked questions
Must the original award be produced
Yes for awards made up to 31 December 2026: the application is accompanied by the original of the award and a copy of the arbitration agreement, or by copies satisfying the conditions of authenticity (article 1516). For awards made after 1 January 2027, a copy of each of the two documents will suffice, the requirement of an original being removed (decree no. 2026-741, articles 16 and 22). For an award at the end of 2026 it is therefore prudent to ask the SIAC secretariat for an authenticated copy as soon as it is made.
How long is there to apply for enforcement
No text fixes a period, neither the code of civil procedure nor the New York Convention. The constraint lies elsewhere: the claim is time barred under the law governing it, and once the award has been declared enforceable, enforcement of the title may be pursued only for ten years, unless the claim recorded is subject to a longer period (code of civil enforcement procedures, articles L. 111-3, 2 and L. 111-4). In practice the real risk is the disappearance of assets, not the time bar.
Can the debtor block enforcement during its appeal
Not as of right. An appeal against the enforcement order has no suspensive effect (article 1526). The First President sitting in summary proceedings, or the pre trial judge, may stay or adjust enforcement where it is liable seriously to prejudice a party’s rights, which requires more than a cash flow difficulty. From 1 January 2027, for awards made after that date, that judge will no longer be able to adjust but only to suspend, by an order open to no challenge.
How does this differ from enforcing a Singapore judgment
The regime is markedly more favourable for an award. It is recognised or enforced as soon as its existence is established and enforcement is not manifestly contrary to international public policy (article 1514), the Court of Appeal being able to refuse only in the five cases of article 1520. A Singapore judgment falls under the general law of enforcement, with broader review. That is a drafting argument: in a contract with a Singapore counterparty, an arbitration clause protects a French creditor better than a jurisdiction clause.
Can an award set aside in Singapore still be enforced
In France, yes. Setting aside in the country of origin is not among the five cases in which the Court of Appeal may refuse recognition or enforcement (articles 1520 and 1525). The Court of Cassation holds that an award set aside at the seat remains enforceable in France (Cass. 1re civ., 23 March 1994, no. 92-15.137) and that an international award is not attached to any national legal order (Cass. 1re civ., 29 June 2007, no. 05-18.053). That solution is peculiar to French law and does not transpose to every State party to the Convention.