Countries › Paraguay › Guide › 14. Disputes › Enforcing arbitral awards in Paraguay: annulment, execution of domestic awards and recognition of foreign awards

Enforcing arbitral awards in Paraguay: annulment, execution of domestic awards and recognition of foreign awards

Argentina. For full detail on Argentina, go to The Argentine Thread.

Last verified: 2026-10-28 · Status: Changing

An award is final and binding on notification; if it sets no deadline the debtor has 20 days to pay, after which a Paraguayan award goes straight to execution before a first instance civil judge with only three defences allowed. Annulment is the only challenge, decided in a single instance by the Asunción Court of Appeal on documents, within 15 or 25 business days of notification, and it does not stop enforcement without a bank guarantee. Foreign awards are recognized by the same Court of Appeal under the most favourable treaty, chiefly the New York Convention, with no appeal from its decision.

USD figures use PYG 5,868.31 per US dollar, the Banco Central del Paraguay reference quotation published for Wednesday 28 October 2026. Conversions are for orientation only.

Key facts

Days to comply with an award that sets no deadline	20 daysLey 7561/2025 art. 48, as of 2026-10-28 · in force
Deadline to seek annulment of an international award (domestic: 15)	25 business daysLey 7561/2025 art. 54, as of 2026-10-28 · in force
Deadline to seek annulment of a domestic award	15 business daysLey 7561/2025 art. 54, as of 2026-10-28 · in force
Time for the Court of Appeal to decide annulment	10 business daysLey 7561/2025 art. 55, as of 2026-10-28 · in force
Appeal against annulment decision	No Ley 7561/2025 art. 55, as of 2026-10-28 · in force
Annulment suspends enforcement automatically	No; stay only with bank guarantee ordered by the court Ley 7561/2025 art. 54, as of 2026-10-28 · in force
Defences against execution of an award	Forgery, ten year prescription, payment Ley 7561/2025 art. 58; CPC art. 526 a, b, d, as of 2026-10-28 · in force
Court recognizing foreign arbitral awards	Tribunal de Apelación en lo Civil y Comercial de la Capital (no appeal) Ley 7561/2025 art. 10, 63, as of 2026-10-28 · in force
Debtor's time to object to recognition of a foreign award	15 business daysLey 7561/2025 art. 63, as of 2026-10-28 · in force
New York Convention reservations	None Ley 948/1996, as of 2026-10-28 · in force
BCP reference rate used for conversions	5868.31 PYG per USDBCP planilla 28 October 2026, as of 2026-10-28 · in force

The rule

1. Compliance window and post award requests. The award is final, unappealable and binding from notification, with res judicata effect. If the debtor does not comply in the form and time set by the award, or within 20 days of notification where none is set, the creditor may seek court execution. Within 10 days of receiving the award (20 in international cases) a party may ask for correction of errors, clarification, rectification of excess or interpretation, or for an additional award on claims omitted; the other side gets the same period to answer and the tribunal decides within 15 days, extendable by 15. Such a request suspends the compliance period, and the annulment deadline then runs from notification of the decision or from expiry of the time to decide.
Cost to do it: The tribunal may not charge additional fees for corrections, interpretation or additional awards (art. 66).
Example: An award ordering payment of PYG 1,173,662,000 notified on 2 November 2026 with no payment date must be paid within 20 days, unless a correction request suspends the period. / On a US$200,000 award, asking for correction of a calculation error within 10 days keeps the annulment deadline from running until the tribunal rules.Ley Nº 7561/2025, De Arbitraje, Art. 48, 50 and 51, 2025-12-23 official text · verified 2026-10-28

2. Annulment: single instance, short, documents only. The only remedy is an action for annulment before the Tribunal de Apelación en lo Civil y Comercial of the Capital, on the closed list of grounds read restrictively: incapacity or invalid agreement; no proper notice of appointment or proceedings or inability to present a case; composition or procedure contrary to the agreement or the law; decisions beyond the submission; non arbitrable matters; breach of Paraguayan public policy (international public policy in international cases); and lateness only if expressly agreed. The court may not review the merits, reasoning or interpretation, on pain of misconduct. Grounds a) to d) are available only if the party objected before the tribunal in time and was overruled, and no ground can be raised that could have been cured by a correction or additional award request. Deadline: 15 business days (domestic) or 25 business days (international) from notification. The other side answers in the same period, evidence is documentary save exceptional cases (10 business days, never witnesses or party confession, a single court expert), the court decides within 10 business days, and no appeal lies except on lapse of the action, which occurs after 30 days of inactivity. On request, the court may suspend the annulment action for up to 6 months to let the tribunal cure the defect.
Cost to do it: Counsel fees for a written, documents only action; no court fee stated in the law.
Example: A domestic award notified on Monday 2 November 2026 must be challenged within 15 business days, excluding non working days. / An international award for US$1,000,000 (PYG 5,868,310,000) has 25 business days for annulment; witness evidence is never allowed.Ley Nº 7561/2025, De Arbitraje, Art. 52, 54, 55 and 56, 2025-12-23 official text · verified 2026-10-28

3. Stay of enforcement and consequences of annulment. Filing for annulment does not suspend compliance or enforcement. The Court of Appeal may exceptionally stay the award if the applicant provides the counter security agreed by the parties or in the rules, or one the court fixes in relation to the amount of the award; a personal undertaking is never accepted and a guarantee must be a joint and several bank guarantee or equivalent. The court rules on the stay within 5 business days and that decision cannot be challenged. If the award is annulled the consequences depend on the ground: court litigation if the agreement was invalid; restart before the same tribunal from the defect for due process breaches; new tribunal or restart for irregular composition; new arbitration or court for matters outside the clause; court only for non arbitrable matters; a new award for public policy; and a new tribunal, or for domestic cases the Court of Appeal itself if the parties so agree within 15 business days, where the award was late. Evidence taken remains usable. Where no party is Paraguayan or based in Paraguay, the parties may waive annulment or limit it to certain grounds expressly and in writing.
Cost to do it: A stay requires a joint and several bank guarantee related to the amount awarded; bank commissions are a real cost.
Example: To stay a PYG 5,868,310,000 award while annulment is pending, the debtor posts a bank guarantee sized by the Court of Appeal in relation to that amount. / For a US$1,000,000 award, a guarantee commission charged by a local bank is the price of stopping execution; without it the creditor can attach assets.Ley Nº 7561/2025, De Arbitraje, Art. 53, 54 and 57, 2025-12-23 official text · verified 2026-10-28

4. Executing a domestic award. An award rendered in Paraguay needs no recognition. The creditor files the original or an authenticated copy (with any correction or additional award) before the Juez de Primera Instancia en lo Civil y Comercial on duty where the award was rendered, of the Capital, or where the debtor has assets, at the creditor's choice. The judge opens execution on those documents under the judgment execution procedure of the Código Procesal Civil: attachment, then a citation to the debtor, who has 3 days to raise defences. Only three defences are admissible against an award: forgery of the award, ten year prescription, and payment; they must rest on facts after the award and be proved by documents. Execution is suspended only if the Court of Appeal has ordered a stay.
Cost to do it: Counsel fees for execution under Ley 1376/1988 and auction costs if assets must be sold.
Example: An Asunción award for PYG 1,173,662,000 against a Ciudad del Este company can be executed before the civil judge of Alto Paraná, where its trucks are registered. / For a US$200,000 award, a debtor claiming it already paid must prove it with documents dated after the award.Ley Nº 7561/2025, De Arbitraje; Ley Nº 1337/1988, Código Procesal Civil, Ley 7561 art. 10 and 58; CPC art. 519, 522, 525, 526 and 527, 2025-12-23 official text · verified 2026-10-28

5. Recognizing foreign awards. An award rendered outside Paraguay is recognized under ratified treaties, applying the one most favourable to the applicant where several apply; failing a treaty, or if the applicant prefers, under the law itself. The applicant files the original or a copy, with a translation by a registered public translator if not in Spanish, before the Tribunal de Apelación en lo Civil y Comercial of the Capital. Recognition may be refused only at the debtor's request and proof, on grounds mirroring the New York Convention, plus non arbitrability under Paraguayan law and breach of international public policy. The debtor objects within 15 business days with documents only, the court decides within 10 business days, and there is no appeal. Once recognized, the award is executed before the first instance judge of the Capital, the debtor's domicile or where assets lie, with the same three defences as a domestic award. Paraguay applies the New York Convention since 6 January 1998 with no reservations, so it covers awards from any state.
Cost to do it: Sworn translation by a registered translator and apostille of foreign documents; under the Convention fees may not be appreciably higher than for domestic awards (art. III).
Example: A London seated award against an Encarnación exporter: filed with the Asunción Court of Appeal with a Spanish translation, answered in 15 business days, decided in 10 business days, then executed in Itapúa. / On a US$1,000,000 (PYG 5,868,310,000) foreign award, the statutory recognition timetable is about 25 business days after the debtor is served, without appeal.Ley Nº 7561/2025, De Arbitraje; Ley Nº 948/1996 (New York Convention), Ley 7561 art. 10, 59, 60, 61, 62 and 63; Convention art. III to VI, 2025-12-23 official text · verified 2026-10-28

6. Regional instruments. For awards from Mercosur states, Bolivia and Chile, the cooperation agreement approved by Ley 3036/2006 gives extraterritorial effect to awards and judgments that are authentic, translated, issued by a body with international jurisdiction under the rules of the requested state, rendered after proper citation and defence, final, and not manifestly contrary to public policy; recognition may be requested through letters rogatory via central authorities or directly by the party, with legalization unless replaced by another formality. The Mercosur Agreement on International Commercial Arbitration (Ley 3303/2007) governs arbitrations with contacts in more than one Mercosur state. Under Ley 7561 art. 59 the creditor may rely on whichever treaty is most favourable.
Cost to do it: Translation and, for direct filings, legalization or apostille; transmission through central authorities avoids legalization (art. 10 and 26).
Example: An award rendered in Montevideo in favour of a Uruguayan grain trader can be presented under the Mercosur, Bolivia and Chile agreement or the New York Convention, whichever is easier. / For a US$500,000 (PYG 2,934,155,000) award from Buenos Aires, the Argentine side of the dispute is outside this guide; see The Argentine Thread for the Argentine rules.Ley Nº 3036/2006, approves the Mercosur, Bolivia and Chile jurisdictional cooperation agreement, Agreement art. 18 to 24, 2006-10-26 official text · verified 2026-10-28

Feature	Award seated in Paraguay	Foreign award
Recognition needed	No (art. 58)	Yes, Court of Appeal of the Capital (art. 63)
Challenge	Annulment, 15 or 25 business days (art. 54)	Objection to recognition, 15 business days (art. 63)
Grounds	Art. 52 closed list	Art. 61, New York Convention style
Appeal	None (art. 55)	None (art. 63)
Execution court	First instance civil judge: seat, Capital or assets (art. 10)	First instance civil judge: Capital, debtor domicile or assets (art. 10)
Execution defences	Forgery, ten year prescription, payment	Same

Domestic versus foreign awards in Paraguay

Worked example

Annulment and stay: a Paraguayan cooperative loses a domestic arbitration and is ordered to pay PYG 1,173,662,000 (US$200,000). It files for annulment on day 14 of its 15 business days, alleging it could not present its case. The creditor nonetheless starts execution; the cooperative asks for a stay and the Court of Appeal, within 5 business days, conditions it on a joint and several bank guarantee. Without the guarantee, attachment of the cooperative's accounts proceeds.
Foreign award: a Dutch trading house holds a US$1,000,000 (PYG 5,868,310,000) award rendered in Rotterdam. It files a translated copy with the Asunción Court of Appeal; the debtor alleges a public policy breach but offers witness evidence, which the court cannot use because objections are documentary; recognition is granted within the statutory timetable and execution follows before the judge where the debtor's silos are located.

Step by step

On receiving the award, diary 10 or 20 days for correction requests and 15 or 25 business days for annulment (art. 50 and 54).
If you are the creditor and the award sets no date, wait 20 days from notification, then file for execution with an authenticated copy (art. 48 and 58).
If you are the debtor and want to stop execution, prepare a joint and several bank guarantee before asking for a stay (art. 54).
For a foreign award, obtain the original or a certified copy, apostille it and have it translated by a registered public translator before filing (art. 60).
Map debtor assets by jurisdiction to pick the execution court (art. 10).

Common traps

The 20 day compliance period and the 10 or 20 day correction periods are calendar days (art. 7); only the annulment and recognition deadlines are expressly business days.
Procedural objections not raised before the tribunal in time cannot ground annulment (art. 52).
Defects that a correction or additional award request could have fixed are lost if no request was made (art. 52).
The annulment action lapses after 30 days without activity (art. 55).
Art. 58 refers to a suspension under art. 56, but the power to stay enforcement is in art. 54; art. 56 deals with remitting the case to the tribunal.
The BACN text of the Código Procesal Civil still prints art. 536 on foreign awards, which Ley 1879/2002 art. 69 repealed; rely on Ley 7561/2025 and the treaties.

Sources

← Commercial arbitration in Paraguay: drafting the clause, constituting the tribunal and running the case under Ley 7561/2025Foreign court judgments in Paraguay: exequatur, treaty routes, foreign forum clauses and cross border interim measures →

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