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Online and on-chain dispute resolution

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Decentralised dispute-resolution protocols such as Kleros and Aragon Court resolve disputes by juries of token holders who stake tokens and vote, with the smart contract executing the outcome. Their decisions are not arbitral awards. They lack a seat, a tribunal in the legal sense, an arbitration agreement that identifies the parties and the procedural guarantees that Art. V of the New York Convention and Art. 34 of the Model Law presuppose. A party who loses before such a protocol can relitigate in court, while a party who wins has only what the smart contract already executed. Singapore courts have not ruled on the question. The IAA's definition of arbitration would, in my view, exclude such protocols because there is no agreement to submit to a tribunal that decides according to law or agreed rules.

The practical use of on-chain mechanisms is therefore as a first tier within a conventional clause. The parties agree to submit disputes below a threshold to an on-chain procedure and to treat its outcome as binding contractually, with SIAC arbitration for larger disputes and for challenges to the on-chain result. Several protocol foundations have adopted this structure. It gives the on-chain outcome the force of a contractual expert determination, which Singapore and Swiss courts enforce as a matter of contract unless the determination is tainted by fraud or manifest error. The enforceability of the New York Convention is preserved for what matters.

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For Hong Kong, our parallel site HongkongIQ.com offers the same practical guidance. For crypto and digital assets, dltreg.com covers legal, tax and fiduciary services. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.