Most foreign companies that end up in Israeli arbitration have handled litigation at home before. They know the basic rhythm: written submissions, document exchange, then a hearing where witnesses give evidence and lawyers argue the case. Israeli arbitration follows a similar pattern, but the rules governing what happens at the hearing — whether one is held at all, how witnesses are called, how examination is structured — sit almost entirely within the arbitrator's discretion.
That discretion is not unlimited. The Arbitration Law 5728-1968, the ICCA Rules, the ICC Rules, and, for international proceedings, Israel's International Commercial Arbitration Law 5784-2024 (the Model Law), all set guardrails. But the specific procedure at an oral hearing is far less standardised than a court trial, and far less predictable to a foreign party who has never appeared in one. What reduces that unpredictability, almost always, is preparation that begins well before the hearing is ever scheduled.
1. Is an Oral Hearing Mandatory in Israeli Arbitration?
No. Unlike a state court proceeding, an oral hearing in Israeli arbitration is not a right that attaches automatically. Whether one is held depends on the terms of the parties' agreement and the tribunal's procedural orders.
Under Section 9 of the First Schedule to the Arbitration Law 5728-1968, the default rules for ad hoc arbitrations, an arbitrator may conduct proceedings by written submissions unless a party requests an oral hearing or the arbitrator decides one is necessary. A documents-only arbitration — both sides submit written statements and the arbitrator decides on the papers — is entirely lawful and relatively common for smaller or lower-complexity disputes.
For institutional arbitrations the position shifts:
- ICCA Rules: a hearing will generally be held unless all parties agree to a documents-only process
- ICC Rules: Article 25 provides that the tribunal must hold a hearing if either party so requests; a documents-only award without a hearing requires the agreement of all parties
- International Commercial Arbitration Law 5784-2024 (Model Law): Article 24 requires the tribunal to hold a hearing if either party requests one at an appropriate stage of the proceedings
In practice, any dispute involving contested facts — disputed delivery dates, alleged defects in goods or services, misrepresentation claims, financial disputes where the numbers are in genuine disagreement — will almost certainly include a hearing once either side asks for one. The real question is whether you request the hearing at the right time and have prepared your witnesses properly.
2. Pre-Hearing Preparation: Witness Statements and Expert Reports
The single most important step before any oral hearing is the exchange of written witness statements. Israeli arbitration has adopted international practice: each party submits witness statements in advance, which stand as the witnesses' evidence-in-chief. The witnesses then appear at the hearing primarily to be cross-examined by the other side.
Tribunal procedure orders — issued at the first case management conference — typically set the following timetable:
- Simultaneous exchange of witness statements: 8–12 weeks after the close of pleadings
- Simultaneous exchange of expert reports: 4–8 weeks after witness statements
- Reply witness statements (if permitted): 4 weeks after initial exchange
A witness statement in Israeli arbitration is a sworn document. The witness declares that its contents are true and correct under their personal responsibility. For a foreign national giving a statement, this declaration carries the same legal weight as a sworn affidavit before a notary in most common-law systems.
Witnesses who are not fluent in the language of the arbitration must have their statements translated. The declaring witness signs the statement in their own language; a certified translation is filed alongside it. Exhibits attached to the statement — contracts, emails, invoices — must be accompanied by certified translations into the language of the arbitration if they are in a different language.
3. The Hearing Day: Format and Sequence
An oral hearing in Israeli commercial arbitration has no fixed format. Unlike court proceedings — where the judge controls a scripted sequence that all lawyers know in advance — the arbitrator shapes the procedure as the case develops. For a foreign party this can be disorienting the first time. Here is what a typical ICCA hearing actually looks like:
- Venue: ICCA's hearing rooms at Ha-Arba'a Street 28, Tel Aviv, or a hired venue such as a law firm's conference room
- Language: Hebrew (domestic proceedings) or English/Hebrew (international proceedings), with interpreters if agreed
- Participants: arbitrator or tribunal panel, parties' counsel, witnesses (waiting outside until called), and an ICCA administrative clerk for institutional proceedings
- Transcript: not produced automatically; either party can engage a stenographer at their own cost
The typical sequence of proceedings:
- Opening submissions: each party's counsel summarises their case (10–30 minutes, or longer for complex disputes by prior agreement with the tribunal)
- Claimant's witnesses: each witness is called in turn, confirms their written statement, and is cross-examined by respondent's counsel
- Respondent's witnesses: same procedure
- Expert witnesses: usually heard after all lay witnesses, by prior agreement between the parties and the tribunal
- Closing submissions: oral, written (post-hearing briefs), or both — the tribunal decides at the close of evidence
Tribunals in ICCA proceedings frequently ask parties to agree on time limits for cross-examination to keep proceedings on schedule. A "chess clock" approach — where each party has a fixed total number of hearing hours — is increasingly common in multi-day hearings and is more likely to be ordered when one party's witness list is considerably longer than the other's.
4. Examination-in-Chief and Cross-Examination
Because witness statements stand as evidence-in-chief, examination-in-chief at the hearing is usually brief. Counsel typically does no more than confirm the witness's name and statement, then ask a few additional questions on points that emerged after the statement was filed — a new document produced in discovery, a factual concession made by the other side. The real substance of witness evidence happens in cross-examination.
Cross-examination in Israeli arbitration follows a hybrid of civil-law and common-law practice. The cross-examining party may:
- Put specific factual propositions directly to the witness ("You approved this invoice in September 2024, correct?")
- Challenge the witness's credibility or the basis for their stated knowledge
- Highlight inconsistencies between the witness statement and documentary evidence
- Ask about events or documents not addressed in the statement, provided they are within the scope of the dispute
Leading questions are permitted in cross-examination. Israeli arbitrators — most of whom are retired judges of the Israeli District or Supreme Court, or senior advocates with decades of litigation experience — understand that cross-examination is adversarial by design. They will intervene to prevent harassing, repetitive, or irrelevant questioning, but they will not restrict a cross-examiner who is being vigorous and effective.
One feature that regularly surprises foreign parties: Israeli arbitrators question witnesses directly, and they do so without waiting for counsel to raise a point in re-examination. An arbitrator who cannot follow an accounting entry will simply stop and ask. Common-law practitioners used to a judge who stays mostly silent tend to find this jarring. Brief your witnesses before the hearing that it will happen.
5. Expert Witnesses at the Hearing
Expert witnesses are handled differently from lay witnesses in Israeli arbitration, both in the pre-hearing process and at the hearing itself.
After the exchange of written expert reports, tribunals frequently order an "expert conferencing" or "hot-tubbing" session — a format in which opposing experts appear simultaneously, answer questions together, and are examined by the tribunal and then by counsel. This format, borrowed from Australian and international commercial arbitration practice and increasingly common in ICCA proceedings, allows the tribunal to probe the specific areas of expert disagreement directly. Both experts hear the same question and give their differing answers side by side, which makes it harder for either to evade or talk around the point of conflict.
If hot-tubbing is not ordered, experts are examined consecutively: each expert confirms their written report, is cross-examined by opposing counsel, and may be re-examined. Expert cross-examination in Israeli arbitration tends to be technical; opposing counsel typically focuses on the methodology, the assumptions behind the numbers, and any internal inconsistencies in the report.
Expert reports in Israeli arbitration typically address:
- Accounting, lost profits, or damages quantification
- Construction defect causation and remediation costs
- Technical standards in IP, software, or engineering disputes
- Real estate valuation for damages calculations
- Foreign law — where a party's rights depend on the law of another jurisdiction, a legal expert report from a qualified foreign lawyer is admissible and treated as expert evidence
6. Documents and Exhibits at the Hearing
Before the hearing, the parties agree on a set of hearing bundles — physical or electronic folders containing all documents that may be referred to during evidence. The standard structure in Israeli commercial arbitration is:
- Core Bundle: key contractual documents, the parties' main correspondence, and agreed facts
- Witness Bundles: one bundle per witness, containing only the documents that witness will be asked about in cross-examination
- Expert Bundle: the documents and data underlying the expert reports
- Authorities Bundle: legal authorities cited in submissions, if the parties have prepared legal briefs
Hebrew-language documents must be accompanied by certified English translations where the hearing language is English, and vice versa. The translating party bears this cost. Disputes about translation quality arise in a significant proportion of Israeli international arbitrations; using a single agreed translator for key documents reduces those disputes.
7. Language and Interpretation at the Hearing
The language of the arbitration is whatever the parties agreed in their contract's arbitration clause. Most international commercial contracts with Israeli parties provide for English-language arbitration, or at minimum permit either party to request proceedings in English. Where no language is specified:
- ICCA Rules: the tribunal determines the language, having regard to the parties' nationalities and the language of the contract
- ICC Rules: same approach
- International Commercial Arbitration Law 5784-2024: Article 22 allows the tribunal to determine the language of the proceedings
In practice, Israeli parties and most Israeli arbitrators are fluent in English. Significant arbitrations with a foreign party are routinely conducted in English. When proceedings are in English but a witness speaks only Hebrew, Russian, or Arabic, the parties arrange interpretation for that witness's testimony. The interpreter translates each answer consecutively — after each question and answer — which extends the time needed for cross-examination substantially.
8. Remote and Hybrid Hearings
Israeli arbitration practice has normalised virtual and hybrid hearings since 2020. ICCA's procedural guidelines accommodate remote proceedings, and the International Commercial Arbitration Law 5784-2024 expressly supports virtual hearings as a valid format for all types of proceedings.
A fully remote hearing — all participants appearing by video — is standard for procedural conferences, interim measure applications, and single-witness testimony. A substantive merits hearing lasting multiple days is more commonly run as a hybrid: the arbitrator, lead counsel, and key witnesses in a shared venue in Tel Aviv, with remote participants joining via video for specific testimony or closing arguments.
For foreign parties, remote hearings change the economics of the case:
- No international travel costs for company witnesses appearing for a single day of testimony
- No need for Israeli entry visas for non-national witnesses
- Less operational disruption for senior executives whose testimony is limited in scope
- Ability to have the party's international counsel participate alongside Israeli local counsel without travel
9. Post-Hearing Briefs and the Road to the Award
After the oral hearing, tribunals typically invite written post-hearing submissions — also called closing briefs or post-hearing memorials. These allow each party to:
- Summarise the evidence given at the hearing, including key witness answers
- Reference the transcript by page and line if one was made
- Address specific documents put to witnesses that require further argument
- Make final legal submissions on the applicable law and the relief sought
Timelines for post-hearing briefs in ICCA proceedings are typically four to eight weeks after the hearing, with simultaneous exchange. Reply briefs responding to the other side's submission are sometimes permitted, adding another two to four weeks. Read the tribunal's procedural order on this point before drafting — some arbitrators prohibit new evidence or new arguments in post-hearing submissions, limiting them to commentary on what came out at the hearing. Filing something the other side can object to as new material wastes a round of correspondence nobody wants.
After post-hearing briefs, the arbitrator deliberates and issues the final award. Under the Arbitration Law 5728-1968, the award must be delivered within the time agreed by the parties or, in the absence of agreement, within a reasonable time. ICCA's standard terms encourage delivery within three to four months of the last submission. The Israeli District Court has authority under Section 28 of the Arbitration Law to set a deadline if an arbitrator is unreasonably delayed, but this power is rarely used in practice — Israeli arbitrators in commercial disputes typically issue awards within the expected window.
10. The Cost of an Oral Hearing in Israeli Arbitration
Hearing costs vary substantially by case complexity and the institutional framework chosen, but foreign parties should budget for the following major components:
- Hearing room fees (ICCA): currently NIS 2,500–6,000 per day depending on room size
- Arbitrator's daily fees: senior Israeli arbitrators charge NIS 15,000–35,000 per hearing day; a three-person panel multiplies this figure accordingly
- Interpretation: NIS 800–1,500 per hour for a certified interpreter; NIS 6,000–12,000 for a full hearing day
- Transcript: NIS 3,000–7,000 per hearing day for Hebrew-English stenography
- Travel and accommodation: for foreign parties, flights and hotel costs for counsel and witnesses attending in person
For a two-party, three-day arbitration hearing with two witnesses per side, total direct costs excluding counsel fees typically run NIS 80,000–150,000. Counsel fees — Israeli and foreign — will usually be the largest single component. The arbitrator allocates costs in the final award, and in Israeli arbitration the losing party generally bears a significant share of the prevailing party's reasonable costs, though the allocation is discretionary rather than automatic.
Frequently Asked Questions
Yes. Under Article 24 of the International Commercial Arbitration Law 5784-2024 and Section 9 of the First Schedule to the Arbitration Law 5728-1968, either party can request a hearing. Make the request early — at the first procedural conference or in your initial response to the notice of arbitration. Waiting until the documentary phase is nearly finished risks a refusal on grounds of procedural efficiency, and a tribunal that has already planned a documents-only process is unlikely to reverse course unless good cause is shown.
Not in the formal sense used in Israeli court proceedings. Witnesses sign their written statements with a declaration that the contents are true and correct to the best of their knowledge, but there is no swearing-in ceremony at the hearing itself. A witness who knowingly gives false testimony in arbitration can face civil liability and potential criminal exposure under Section 237 of the Penal Law 5737-1977 (false statement not under oath, used in proceedings). Treat the duty to testify truthfully as legally equivalent to court evidence.
An arbitrator has no direct power to compel a witness to attend. However, under Section 14 of the Arbitration Law 5728-1968, either party can apply to the Israeli District Court for a witness summons compelling attendance at the arbitration hearing. The court will issue this only if the witness is within Israeli jurisdiction and their testimony is genuinely necessary. A foreign witness resident outside Israel cannot be compelled through Israeli process. If a witness fails to appear without explanation, the tribunal can draw adverse inferences against the party who called them, which can significantly affect the outcome on contested factual points.
Yes, and in English-language arbitrations no Hebrew is required at any point. In a Hebrew-language arbitration, a foreign witness testifying in English needs a party-appointed interpreter. Counsel cross-examines in Hebrew (rendered into English for the witness), and the witness answers in English (rendered into Hebrew for the record). Consecutive interpretation roughly doubles the time needed for cross-examination. Prepare witnesses to speak in short sentences and to pause after each clause, and budget the hearing calendar accordingly.
Hearing room fees at ICCA (Ha-Arba'a Street 28, Tel Aviv) currently run NIS 2,500 to NIS 6,000 per day depending on room size. Arbitrator fees for hearing days are typically NIS 15,000 to NIS 35,000 per day for a senior Israeli arbitrator. A party-appointed interpreter for a full hearing day costs NIS 6,000 to NIS 12,000. For a two-party, three-day hearing with two witnesses per side, total direct costs excluding counsel fees typically run NIS 80,000 to NIS 150,000. The arbitrator allocates these costs in the final award, and the losing party usually bears a significant share.