Countries › Uruguay › Guide › 14. Disputes › Commercial arbitration in Uruguay

Commercial arbitration in Uruguay

Last verified: 2026-10-27 · Status: Stable

Arbitration seated in Uruguay runs on two tracks: international cases under Ley 19.636, a near copy of the UNCITRAL Model Law, and domestic cases under the Código General del Proceso as rewritten by Ley 20.257 in 2024. Court support for international cases (appointments, challenges, jurisdiction rulings, annulment) sits with the Tribunales de Apelaciones en lo Civil, and annulment must be sought within three months. Domestic awards must be issued within 120 business days unless agreed, the tribunal must attempt conciliation, and annulment has to be filed within five days.

USD figures use UYU 40.214 per US dollar, the BCU quotation for DLS. USA BILLETE on 26 October 2026, retrieved from the BCU quotations service on 27 October 2026. Amounts set in UR use UYU 1,940.77, the latest published UR value (September 2026, Decreto 229/026, IMPO values table); amounts in UI use UYU 6.6792 per UI (BCU, 27 October 2026). Conversions are rounded and for orientation only.

Key facts

International arbitration law based on the UNCITRAL Model Law	Yes (2018, Ley 19.636) Ley 19.636, as of 2026-10-27 · in force
Default number of arbitrators, international	3 Ley 19.636 art. 10, as of 2026-10-27 · in force
Deadline to seek annulment of an international award seated in Uruguay	3 monthsLey 19.636 art. 39, as of 2026-10-27 · in force
Deadline to file annulment of a domestic award	5 daysCGP art. 501 (Ley 20.257), as of 2026-10-27 · in force
Default term to issue a domestic award	120 business daysCGP art. 496 (Ley 20.257), as of 2026-10-27 · in force
Court supporting international arbitration	Tribunales de Apelaciones en lo Civil Ley 19.636 art. 6, as of 2026-10-27 · in force
Term to request correction or interpretation of an international award	30 daysLey 19.636 art. 33, as of 2026-10-27 · in force

The rule

1. Ley 19.636 applies to international commercial arbitration seated in Uruguay, subject to treaties. An arbitration is international if the parties have places of business in different states when they agree, or a substantial part of the obligations or the subject matter is most closely connected with a place outside the parties' state; parties cannot make an arbitration international merely by saying so. No court may intervene except where the law provides. The arbitration agreement may be a clause or a separate agreement and must be in writing, which includes exchanges of letters and electronic communications.
Cost to do it: Drafting cost only; a clause naming seat, rules, number of arbitrators and language avoids later court applications.
Example: A Uruguayan grain exporter and a Chinese buyer agree in their contract to ICC arbitration seated in Montevideo; Ley 19.636 governs because their places of business are in different states. / A US investor and Uruguayan sellers in a US$15,000,000 (about UYU 603,210,000) share deal can choose Montevideo as seat with English as language under art. 22.Ley Nº 19.636 (International Commercial Arbitration), art. 1, 5 and 7, 2018-07-13 official text · verified 2026-10-27

2. A court seized of a dispute covered by an arbitration agreement must refer the parties to arbitration if a party asks no later than its first submission on the merits, unless the agreement is void, inoperative or incapable of performance; the arbitration may proceed meanwhile. Asking a court for interim measures is compatible with the agreement. The arbitral tribunal may itself order interim measures, and these are binding and enforced by the Tribunal de Apelaciones en lo Civil on request.
Cost to do it: The tribunal may require the applicant to give adequate security for an interim measure (art. 17.1).
Example: A Montevideo court must send a dispute to arbitration if the defendant invokes the clause in its first brief on the merits. / A foreign party that answers a Uruguayan lawsuit on the merits without invoking the clause risks losing the right to arbitrate a US$2,000,000 claim.Ley Nº 19.636, art. 6, 8, 9 and 17, 2018-07-13 official text · verified 2026-10-27

3. Absent agreement there are three arbitrators, and nationality is no bar. Each side appoints one and the two appoint the chair; if a party fails to appoint within 30 days of a request, the court appoints. A challenge goes first to the tribunal within 15 days of learning of the grounds; if rejected, the challenging party may apply to the court within 30 days, the court decides within 60 days with no appeal, and the arbitration is suspended meanwhile. The tribunal rules on its own jurisdiction; objections must be raised no later than the defence. If it upholds jurisdiction as a preliminary question, a party may ask the court within 30 days to decide.
Cost to do it: Court applications on appointment, challenge or jurisdiction are made to the Tribunales de Apelaciones en lo Civil (art. 6); counsel fees apply.
Example: In a three member tribunal, if the Uruguayan respondent does not name its arbitrator within 30 days, the claimant asks the Tribunal de Apelaciones en lo Civil to appoint one. / A party challenging an arbitrator in a US$4,000,000 case faces a court decision within 60 days, with the arbitration stayed while it is pending.Ley Nº 19.636, art. 10, 11, 13 and 16, 2018-07-13 official text · verified 2026-10-27

4. The parties choose the seat and the language, and otherwise the tribunal decides. The tribunal applies the law chosen by the parties, meaning its substantive law and not its conflict rules; failing a choice, it picks the law it deems appropriate. It decides in equity only if the parties expressly authorize it. The award must be in writing, signed and reasoned unless agreed otherwise, and state its date and seat. Corrections and interpretations may be requested within 30 days of receipt.
Cost to do it: No extra fee may be charged for correcting, interpreting or completing the award (art. 35.3).
Example: A Montevideo seated tribunal applies New York law chosen in a supply contract, without applying New York's conflict rules. / Parties to a US$1,000,000 dispute can agree on hearings anywhere while keeping Montevideo as the legal seat (art. 20.2).Ley Nº 19.636, art. 20, 22, 28, 31 and 33, 2018-07-13 official text · verified 2026-10-27

5. Unless the parties adopt institutional rules, the tribunal fixes its costs in the award. Fees must be reasonable considering the amount in dispute, complexity and time spent, may take into account international scales such as the ICC scale, and are stated separately for each arbitrator. Costs are in principle borne by the losing party, though the tribunal may apportion them; the tribunal may require deposits in equal shares and suspend or end the proceedings if they are not paid.
Cost to do it: Arbitrators' fees on the reasonableness criteria of art. 36, or the chosen institution's schedule; plus counsel and expert costs.
Example: A tribunal deciding a UYU 10,000,000 dispute states each arbitrator's fee separately in the award. / In a US$4,000,000 (about UYU 160,856,000) case the tribunal may benchmark its fees against the ICC scale (art. 36.2).Ley Nº 19.636, art. 34, 35, 36, 37 and 38, 2018-07-13 official text · verified 2026-10-27

6. The only recourse against an international award is an action for annulment before the Tribunal de Apelaciones en lo Civil, on the Model Law grounds: incapacity of a party or invalid agreement, lack of proper notice or inability to present one's case, matters beyond the submission, irregular composition or procedure, non arbitrable subject matter, or conflict with Uruguay's international public policy. It must be filed within three months of receipt of the award.
Cost to do it: Counsel fees for the annulment action; the merits are not reviewed.
Example: A Uruguayan respondent that lost an ICC award seated in Montevideo has three months to seek annulment. / A foreign award creditor holding a Montevideo seated award for US$4,000,000 can enforce once the three month annulment window passes without a challenge.Ley Nº 19.636, art. 6 and 39, 2018-07-13 official text · verified 2026-10-27

7. Domestic arbitration is governed by CGP art. 472 to 506 as reworded in 2024. Any dispute may be arbitrated unless the law says otherwise, except matters where settlement is prohibited; investment arbitration started by foreign investors is always international. The agreement must be in writing, the old separate compromiso requirement is abolished and earlier clauses are directly enforceable. Unless a sole arbitrator is agreed, there are three or five arbitrators; arbitrators must be over 25 and sitting judges, prosecutors and court staff cannot serve. Absent an agreed procedure the CGP ordinary process applies and the tribunal must attempt conciliation at a hearing. A dormant arbitration lapses after one year without procedural activity.
Cost to do it: Arbitrators may ask the enforcing court to fix their fees, which absent other rules are based on the Colegio de Abogados del Uruguay fee scale (art. 498.2).
Example: Two Montevideo companies with an arbitration clause in a 2012 contract that required a later notarial compromiso can start arbitration directly (art. 473.5). / A foreign owned Uruguayan subsidiary arbitrating against a local customer is in domestic arbitration unless the art. 1 tests of Ley 19.636 are met.Código General del Proceso, Title VIII as reworded by Ley Nº 20.257, art. 472, 473, 476, 479, 480 and 490, 2024-04-25 official text · verified 2026-10-27 · changed: Ley Nº 20.257 (promulgated 25 April 2024) replaced CGP art. 472 to 506: separate compromiso abolished, concurrent interim powers, new annulment grounds and procedure.

8. Court support in domestic arbitration (preliminary steps, forced appointment, challenges, interim measures, early evidence) belongs to the appellate court that would have heard the case on appeal, and forced enforcement of the award to the first instance court that would have had the case. A pre arbitration interim measure lapses if the arbitration is not started within 30 days. The award must be issued within 120 business days from the tribunal's first act unless agreed. Annulment, on seven listed grounds including late award and failure to attempt conciliation, must be filed within five days of notification and suspends enforcement.
Cost to do it: Costs of incidents and of the annulment action are borne by the losing party in them; absent agreement the costs of the arbitration go to the losing party claim by claim (art. 497).
Example: A domestic tribunal appointed in March must render its award within 120 business days from its first act unless the parties agreed a different term. / A party losing a domestic award on a US$250,000 claim has only five days from notification to file annulment.Código General del Proceso, as reworded by Ley Nº 20.257, art. 488, 494, 496, 499 and 501, 2024-04-25 official text · verified 2026-10-27

Point	International (Ley 19.636)	Domestic (CGP, Ley 20.257)
Default tribunal	3 arbitrators	3 or 5 unless sole arbitrator agreed
Court support	Tribunales de Apelaciones en lo Civil	Appellate court that would have heard the case
Award term	As agreed or set by rules	120 business days unless agreed
Annulment deadline	3 months	5 days
Conciliation attempt	Not required	Mandatory hearing
Arbitrator eligibility	Nationality no bar	Over 25; judges and court staff excluded

International versus domestic arbitration seated in Uruguay

Worked example

A US technology company and a Uruguayan distributor sign a US$2,000,000 (about UYU 80,428,000) distribution agreement with ICC arbitration seated in Montevideo, English language and New York law. Because their places of business are in different states, Ley 19.636 applies. When the distributor sues in Montevideo instead, the US company invokes the clause in its first brief and the court refers the parties to arbitration (art. 8). The tribunal upholds its jurisdiction as a preliminary question; the distributor asks the Tribunal de Apelaciones en lo Civil within 30 days and loses (art. 16.3). After the award, the distributor has three months to seek annulment on Model Law grounds only (art. 39).

Step by step

Decide whether the deal is international under Ley 19.636 art. 1; if not, the CGP domestic rules apply.
Draft a written clause naming seat, rules, number of arbitrators, language and governing law (Ley 19.636 art. 7, 10, 20, 22 and 28).
If sued in court, invoke the clause no later than the first brief on the merits (art. 8).
For urgent relief, use court interim measures or tribunal measures (art. 9 and 17); in domestic cases start the arbitration within 30 days of a pre arbitration measure (CGP art. 488).
Calendar challenge and annulment deadlines immediately: 15 and 30 days for challenges, 3 months (international) or 5 days (domestic) for annulment.

Common traps

Calling an arbitration international in the contract does not make it so (Ley 19.636 art. 1).
The five day domestic annulment window is very short (CGP art. 501).
Domestic tribunals must attempt conciliation; skipping it is an annulment ground (CGP art. 490 and 499).
Sitting judges cannot be appointed in domestic arbitration (CGP art. 480.3).
A dormant domestic arbitration lapses after one year without procedural acts (CGP art. 479.2).

Sources

← Debt collection and executive proceedings in UruguayEnforcing arbitral awards in Uruguay →