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Arbitration

Does an Israeli arbitration award need an apostille to be enforced abroad?

The Convention never uses the word apostille, but most enforcing courts want one. Article IV of the 1958 New York Convention requires the applicant to produce a duly authenticated original award or a duly certified copy, together with the arbitration agreement, and an apostille is the cleanest way to satisfy that requirement for a document leaving Israel. Israel is party both to the New York Convention and to the 1961 Hague Apostille Convention, so an Israeli award or the court order confirming it can be apostilled and relied on in another contracting state. A certified translation is also needed wherever the enforcing court does not work in the language of the award. Requirements differ by destination, so confirm the local practice before assembling the bundle.

Authentication in Israel depends on what kind of document you are holding. An award signed by the arbitrator is a private document, so the usual route is to have a notary authenticate the arbitrator's signature and then obtain an apostille on the notarial certificate. Where the award has been confirmed by the District Court under the Arbitration Law 5728-1968, the court registry issues a certified copy of the confirming judgment and the Ministry of Foreign Affairs apostilles it, as it does for other Israeli court judgments. Apostilles on notarial documents come from the Magistrates' Court secretariat. The fee is about NIS 41 per apostille at the time of writing. The arbitration agreement itself needs the same treatment, since Article IV requires it alongside the award.

Sequencing repays attention. Confirming the award in Israel first is not always helpful, because some jurisdictions view an Israeli confirmation order as a second exequatur that the New York Convention was designed to abolish, and will ask for the raw award instead. Decide with local counsel in the enforcement jurisdiction which document they want, then authenticate that one rather than everything. Translations must meet the destination court's own standard, which may mean a sworn translator there rather than a certified translation obtained in Israel, and our guide to enforcing an Israeli arbitral award abroad works through the routes country by country.

⚖ In Practice
  • Governing law: Article IV, 1958 New York Convention; Hague Apostille Convention 1961; Arbitration Law 5728-1968 for confirmation in Israel
  • Competent authority: the District Court (Beit Mishpat Mechozi) for confirmation; the Ministry of Foreign Affairs for apostilles on court judgments, including a judgment confirming the award, and other public documents; the Magistrates' Court secretariat (Beit Mishpat HaShalom) for apostilles on notarial documents
  • Documents required: an authenticated award, the arbitration agreement, and a certified translation into the enforcing court's language
  • Fees: an apostille costs about NIS 41 per document (2026; updated each January); notarial authentication of a signature runs roughly NIS 200 to NIS 400
  • Timeline: allow 2 to 4 weeks to assemble a certified, apostilled and translated bundle, and longer where the award must first be confirmed in Israel
  • Watch out: some courts treat an Israeli confirmation order as an unnecessary second exequatur, so ask local counsel which document they want before authenticating anything

From the full guide: Enforcing an Israeli Arbitral Award Abroad

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Get a Free Consultation with Adv. Eli ShimonyPrepared under the direction of Adv. Eli Shimony, Eli Shimony Law Office · Editorial policy

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