Eight years after its founding, the China International Commercial Court (CICC) does not (at least not yet) loom large in the competitive landscape of international commercial courts. Older courts in London, Singapore, and Dubai handle much larger caseloads each year. But the CICC is a work in progress, and tracking its development can yield insights about the ambitions of China’s judiciary.

Case in point: the latest Supreme People’s Court (SPC) policy document about the CICC and local counterparts. Its focus is on sixteen local “international commercial tribunals” (国际商事法庭, or IC tribunals) (details here) that have quietly been created over the past five years to supplement the CICC. Issued in September 2025, the Opinions On Promoting the High-Quality Development of International Commercial Courts and Serving and Safeguarding High-Level Opening Up” (关于推进国际商事法庭高质量发展服务保障高水平对外开放的意见) or ICC Opinions, signals that the SPC is focusing substantial efforts on improving the quality of the IC tribunals, which operate under the SPC’s firm guiding hand.

The tribunals deserve our attention because they are doing the bulk of the work of what perhaps should be called the China’s ICC network. The CICC itself, staffed by SPC judges, accepted just forty-two cases in its first eight years, as parties must either opt for its jurisdiction in very high-value cases or qualify as cases that it considers are ground-breaking. But the local tribunals – for the most part, created within ordinary intermediate-level courts in sixteen major cities – exercise compulsory jurisdiction over certain kinds of cross-border commercial cases. Those cases previously would have been heard by regular commercial tribunals in those same intermediate courts, but now are channeled to judges with specialized knowledge of transnational commercial law. Cross-border arbitral awards also go to these tribunals for confirmation.

The tribunals deserve our attention because they are doing the bulk of the work of what perhaps should be called the China’s ICC network.

Despite the growing number and activity of the IC tribunals, only a few scholarly articles have focused on them. (See here, here, and here.) The rest of this essay will provide more background about the tribunals and unpack the ICC Opinions. I draw on published materials and informal discussions with some of the tribunals’ judges and lawyers who have practiced before them. (Full disclosure: I am a member of the CICC’s expert committee and have been invited to join the expert committee of a local ICC. However, this essay reflects only my own views and not those of the courts.)

The first IC tribunal opened in late 2020. Like the CICC, the tribunals’ mission is to become “a preferred place for international commercial dispute resolution,” in the words of a 2025 Communist Party Central Committee document on “Strengthening Judicial Work in the New Era.” Most of the tribunals are located in the more developed East Coast areas, with approximately one third in the Yangtze River Delta region, reflecting uneven distribution of foreign-related commercial cases in the Chinese courts. Some IC tribunals appear to have been selected to promote particular economic development strategies such as the Western Land-Sea New Corridor (connecting Chongqing in western China with ports in southern China) and the revitalization of China’s rustbelt in the Northeast.

Within the geographic jurisdiction of the courts where they sit, virtually all of the IC tribunals have subject-matter jurisdiction over certain categories of cases with foreign elements. Those categories include judicial review of arbitration, cross-border judicial assistance, recognition and enforcement of foreign judgments, and international commercial contractual disputes. Some tribunals also hear cross-border civil cases and cases involving foreign-invested enterprises in China.

I spoke with Chinese lawyers who have handled foreign-related litigation in the IC tribunals, and they were complimentary about the tribunals that heard their cases. One commented that the judges have more experience with foreign-related cases and are more willing to apply foreign law, while another lawyer noted that the court itself reviewed the rules of a foreign arbitral institution and related provisions of foreign law.

The ICC Opinions signals that the SPC has big plans for these tribunals.

The ICC Opinions call for a number of measures to improve the quality of the ICC network so that it will become a credible counterpart to other international commercial courts. For example, the document creates an appropriate performance evaluation system for the tribunals and provides better training opportunities for their personnel, including study and internships abroad. It encourages local IC tribunals to publish improved model choice of court clauses to make it easier for foreign litigants to agree to have their cases heard by local IC tribunals and encourages the tribunals to direct appropriate cases to the CICC. The SPC strengthens its monitoring of the local tribunals by requiring them to register (备案) cases in which they apply international treaties or practices.

As in earlier SPC documents, the ICC Opinions instruct the tribunals to adopt a “one-stop” model, linking litigation with mediation and arbitration. For the first time in the CICC context, the SPC uses the politically favored language of the “Fengqiao Experience,” referring to a flexible dispute-resolution model with its roots in Mao-era practices that the Communist Party is promoting for resolving domestic cases.

The ICC Opinions also promotes the use of mediation through international institutions sponsored by the Chinese government, such as the International Organization for Mediation (see here) and the International Commercial Dispute Prevention and Settlement Organization (see here). Local IC tribunal judges whom I contacted said that most mediations are done either by judges themselves or with the involvement of specialized local mediation organizations.

The ICC Opinions preview the SPC’s plans for upcoming foreign-related measures, including updating its judicial interpretations of the Civil Procedure Law and Arbitration Law to reflect recent amendments to those laws, crafting a framework to facilitate judicial confirmation of international mediation agreements, and creating a mechanism to allow the CICC’s expert committee members to participate more in discussions on judicial policies, provide legal advisory opinions, and collaborate in training. The latter mechanism presumably will apply to experts from outside China, as domestic experts already do these things. However, when the IC tribunals need to appoint people’s assessors for trials, the ICC Opinions encourages them to appoint domestic, Hong Kong, or Macau experts rather than foreigners – illustrating the limits to the China ICC network’s internationalization.

In short, the document enables the SPC to take action on a number of measures that required its leadership’s approval. The benefits for the SPC are clear: the IC tribunals will do a better job of hearing cross-border cases, and in so doing make progress towards China being a preferred destination for international dispute resolution.

For a local court, hosting an “international commercial tribunal” may mean greater prestige and special consideration when the SPC is collecting typical cases, cases for the People’s Court Case Database, or cases for submission to Case Law on UNCITRAL Texts. This may, in turn, translate into bigger headcount and budget.

Development of the ICC network is inevitably slowed by obstacles inherent in China’s complicated bureaucracy. For example, creating the IC tribunals within existing intermediate courts rather than as standalone courts probably reflects reluctance of the National People’s Congress Standing Committee to establish another set of specialized courts. But the ICC Opinions signals that the SPC has big plans for these tribunals.

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Susan Finder is a distinguished scholar in residence at the Peking University School of Transnational Law, member of the international commercial expert committee of the China International Commercial Court of the Supreme People’s Court, and author of the Supreme People’s Court Monitor. Her views should not be attributed to the SPC.

Suggested Citation:
Susan Finder, “China’s International Commercial Court Network: A Work in Progress,” USALI Perspectives, 6, No. 6, Jan. 28, 2026, https://usali.org/usali-perspectives-blog/chinas-international-commercial-court-network-a-work-in-progress.

The views expressed in USALI Perspectives are those of the authors, and do not represent those of USALI or NYU.

This work is licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License.