Case Details

Sauna UK BidCo Limited v. Republic of Finland (ICSID Case No. ARB/24/38)

Subject of Dispute:

Electric power distribution services
Economic Sector:

Electric Power & Other Energy
Instrument(s) Invoked:

ECT (Energy Charter Treaty)
Applicable Rules:

ICSID Convention - Arbitration Rules

(a) Original Proceeding

Claimant(s)/Nationality(ies):

Sauna UK BidCo Limited (British)
Respondent(s):

Republic of Finland (Finnish)
Date Registered:

August 23, 2024
Date of Constitution of Tribunal:

March 6, 2025

Composition of Tribunal

President:

Audley SHEPPARD (Irish, New Zealand) - Appointed by Co-Arbitrators
Arbitrators:

D. Brian KING (U.S.) - Appointed by the Claimant(s)
Eduardo SILVA ROMERO (Colombian, French) - Appointed by the Respondent(s)

Party Representatives

Claimant(s):

Debevoise & Plimpton, London, U.K.
Respondent(s):

Three Crowns, London, U.K. and Madrid, Spain
Language(s) of Proceeding:

English
Status of Proceeding:

Pending
Latest Development:

December 22, 2025 -
The Respondent files a Reply on a Preliminary Objection.

(a) Original Proceeding

Published Decisions

Procedural Order No. 1

Procedural Order No. 2

Available on the ICSID Website

Procedural Order No. 1 (May 14, 2025) English (Original)

Procedural Order No. 2 (May 14, 2025) English (Original)

(a) Original Proceeding

Date	Development
August 23, 2024	The Acting Secretary-General registers a request for the institution of arbitration proceedings.
November 6, 2024	Following appointment by the Claimant, D. Brian King (U.S.) accepts his appointment as arbitrator.
December 2, 2024	Following appointment by the Respondent, Eduardo Silva Romero (Colombian/French) accepts his appointment as arbitrator.
March 6, 2025	Following appointment by his co-arbitrators pursuant to the parties’ agreement, Audley Sheppard (Irish/New Zealand) accepts his appointment as presiding arbitrator.
March 6, 2025	The Tribunal is constituted in accordance with Article 37(2)(a) of the ICSID Convention. Its members are: Audley Sheppard (Irish/New Zealand), President, appointed by his co-arbitrators pursuant to the parties’ agreement; D. Brian King (U.S.), appointed by the Claimant; and Eduardo Silva Romero (Colombian/ French), appointed by the Respondent.
April 29, 2025	The Tribunal holds a first session by video conference.
May 14, 2025	The Tribunal issues Procedural Order No. 1 concerning procedural matters.
May 14, 2025	The Tribunal issues Procedural Order No. 2 concerning transparency and confidentiality.
June 19, 2025	The Claimant files a memorial on the merits.
July 7, 2025	The Respondent files a request to address the objections to jurisdiction as a preliminary question pursuant to ICSID Convention Article 41(2) and ICSID Arbitration Rule 44.
July 25, 2025	The Claimant files observations on the request to address the objections to jurisdiction as a preliminary question.
August 8, 2025	The Respondent files a response to the Claimant’s observations of July 25, 2025.
August 22, 2025	The Claimant files further observations on the Respondent’s response of August 8, 2025.
September 3, 2025	The Respondent files a Memorial on a Preliminary Objection.
September 10, 2025	The Tribunal issues a decision on the Respondent’s request to address the objections to jurisdiction as a preliminary question; as a result, the proceeding on the merits is suspended.
October 6, 2025	The Respondent files a Memorial on a Preliminary Objection.
October 29, 2025	The Claimant files a Counter-Memorial on a Preliminary Objection.
November 10, 2025	The Tribunal issues Procedural Order No. 3 concerning the Respondent’s request to address the objections to jurisdiction as a preliminary question.
November 20, 2025	Following exchanges between the parties, the Respondent files a request for the Tribunal to decide on production of documents.
November 26, 2025	The Tribunal issues Procedural Order No. 4 concerning production of documents.
December 19, 2025	The Tribunal issues Procedural Order No. 5 concerning confidentiality.
December 22, 2025	The Respondent files a Reply on a Preliminary Objection.