The Third Winter Lecture took place on 9th February 2026 at Sciences Po and was delivered by Prof. Christophe Seraglini on the topic “The future role of seats in international arbitration”.
This lecture addresses the long-standing debate around the role of the seat in international arbitration, exploring whether it should be seen as a technical choice or as a point of major legal consequence, impacting procedural rules, control over the arbitration and award, and tribunal powers. Theories have evolved between two extremes: a state-centered conception, where the seat is the legal center of gravity, and a fully delocalized vision, seen especially in French doctrine, where awards (and arbitrators) are considered divorced from any single legal system. Besides, England has recently reformed its arbitration law to reinforce the local significance of the seat. All these competing models invite questions about the appropriate balance between procedural certainty and transnational flexibility. Ultimately, the lecture considers whether the seat should serve not as an instrument of state dominance nor fade into irrelevance, but rather as a voluntary and meaningful point of legal connection, chosen by or attributed to the parties, and serving to anchor the arbitration both legally and in practice. The question remains open: what precise role could, or should, the seat play in the future of international arbitration?