This guest post is contributed by Raghd Al-Hosni—GRC Officer at OQAE.
The Sultanate of Oman is now a party to two of the most important international treaties governing cross border dispute resolution: The New York Convention, which deals with arbitration awards, and the Singapore Convention, which deals with settlement agreements resulting from mediation.
While both serve the same broad goal of making it easier to enforce the outcomes of alternative dispute resolution across borders, they differ in scope, mechanism, and history. This post examines what each convention does and how Oman has adopted them.
What Each Convention Does
New York Convention: Formally the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards. This convention creates a uniform mechanism for enforcing arbitral awards issued in one contracting state within the territory of another, eliminating the need to relitigate the dispute from scratch.
Singapore Convention: Formally the United Nations Convention on International Settlement Agreements Resulting from Mediation. It does for mediation what the New York Convention did for arbitration, enabling direct enforcement of international mediation settlement agreements across member states.
Given the key difference between arbitration and mediation, the New York Convention is used to enforce the arbitral award decided by the arbitration tribunal, while the Singapore Convention is used to enforce the settlement agreement signed between the parties to a mediation process.
Oman’s Accession: A Timeline
Oman acceded to the New York Convention, which was entered into force in 1959, through Royal Decree 36/98, making it part of Omani law with effect from 10 June 1998.
Nearly three decades later, Oman joined the Singapore Convention, which entered into force in 2020, through Royal Decree 6/2026, issued on 11 January 2026. Oman is considered one of the early adopters of the Singapore Convention.
What This Means for Businesses
For international companies and investors in Oman, the practical significance is straightforward. An arbitral award issued in any of the 170+ New York Convention member states can be enforced in Oman without relitigating the merits.
Now, a settlement agreement resulting from mediation conducted in any Singapore Convention member state enjoys a similarly streamlined pathway. Mediation settlements are no longer “weaker” instruments; they are legally binding and enforceable.
Interaction with Omani Law
Given the maturity of the arbitration framework in Oman, the New York Convention operates directly and clearly within the legal framework of the Law of Arbitration in Civil and Commercial Disputes and the Civil and Commercial Procedures Law. Article 1 of the Arbitration Law expressly preserves the primacy of international agreements, while article 9 grants the Court of Appeal in Muscat jurisdiction over international commercial arbitrations. Article 58 stipulates that enforcement requires that the award does not violate Oman’s public order and that the award is final in its country of origin.
Oman does not currently have a proper legal framework for governing mediation as a form of alternative dispute resolution, nor does it have any legal provisions that govern settlement agreements arising out of mediation proceedings outside the general provisions of the Civil and Commercial Procedures Law that are triggered when the parties decide to settle a dispute that has already been presented before the court, not those that have independently been reached by the parties without starting litigation first. The Law of Public Notaries can be used to give settlement agreements the power of enforcement documents, but this requires both parties to notarise the agreement before the Public Notary, which is not usually possible if one of the parties is not in Oman.
It is worth noting that the mediation concept found in the Singapore Convention is not the same as the mediation concept found in the Omani Law of Mediation and Conciliation, which relates to mediation through official government tribunals, and not through an independent mediator.
This means that even though Oman is legally bound to provide a mechanism for recognising settlement agreements resulting from mediation, a domestic legal framework still does not exist for the courts to enforce such agreements.
Conclusion
This blog post highlighted the key differences between the New York Convention and the Singapore Convention and how each operates within the Omani legal framework.
For the Singapore Convention to achieve its objectives, Oman must consider issuing a standalone mediation law as well as specific provisions for the courts to enforce settlement agreements that meet the requirements of the Singapore Convention.
You can read the full text of the Singapore Convention on the link below: