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EUROBRIDGE

Legal framework

PPP and investment protection law

National PPP and concession laws, investment guarantees and international treaties for the countries we have checked against official sources.

Checked on October 23, 2026Information, not legal advice

Why investment protection matters

A PPP or concession contract usually runs for decades. Governments, laws and exchange rates change over that time, and an investor needs to know in advance what protects the project if a dispute arises.

Protection works on two levels. National law sets the rules for the contract and guarantees property and investment. International treaties let a foreign investor take a dispute outside the local courts and enforce an arbitral award in another country.

This section brings both levels together for the jurisdictions we have checked against official sources. Every page links to the original text and shows the date of our check.

Countries covered

Open a country to see its PPP and concession laws, investment guarantees, dispute settlement and the legal terms used for each party.

JurisdictionMain PPP / concession lawICSIDNew York ConventionEnergy CharterTreaty with Ukraine
Ukraine№ 4510-IX (2025)YesYesPartyn/a
European Union2014/23/EU, 2014/24/EUn/an/aWithdrawnn/a
PolandUstawa o partnerstwie publiczno-prywatnym (2008)NoYesWithdrawnIn force (1993)
GermanyGWB Teil 4, KonzVgVYesYesWithdrawnIn force (1993)
FranceCode de la commande publiqueYesYesWithdrawnIn force (1994)
SpainLey 9/2017 (LCSP)YesYesWithdrawnIn force (1998)
United KingdomProcurement Act 2023YesYesWithdrawnIn force (1993)
United StatesState P3 enabling laws; TIFIA (23 U.S.C. ch. 6)YesYesNoIn force (1994)
MexicoLey de Asociaciones Público Privadas (2012)YesYes—No
ColombiaLey 1508 de 2012YesYes—No
BrazilLei 11.079/2004NoYes—No
PeruLey N° 32441 (2025)YesYes—No
ChileLey de Concesiones de Obras Públicas (Decreto 900 MOP)YesYes—In force (1995)
ArgentinaLey N° 27.328 (2016)YesYes—In force (1995)
United Arab EmiratesAbu Dhabi Law No. (2) of 2019; Dubai Law No. (22) of 2015YesYes—In force (2003)
Saudi ArabiaPrivate Sector Participation Law (2021)YesYes—In force (2008)
AustraliaNational PPP Policy and Guidelines (2008)———No

n/a: does not apply to this jurisdiction. —: not covered by our check yet.

International mechanisms

These instruments matter to a foreign investor whatever the host country: where a dispute can be heard, and whether an award can be enforced.

ICSID Convention

The World Bank centre for investor-state disputes. Its database lists 166 signatory and contracting states. Poland and Brazil are not on that list, so investors there rely on bilateral treaties and commercial arbitration.

Source (opens in a new tab)

New York Convention (1958)

The convention makes foreign arbitral awards enforceable through national courts. UNCITRAL lists 172 parties.

Source (opens in a new tab)

Ukraine's bilateral investment treaties

UNCTAD lists 78 bilateral investment treaties of Ukraine: 65 in force, 7 signed but not in force and 6 terminated, including those with Russia, Italy, and India.

In force with key markets (year as listed by UNCTAD):

  • United States (1994)
  • United Kingdom (1993)
  • Germany (1993)
  • France (1994)
  • Spain (1998)
  • Poland (1993)
  • Austria (1996)
  • Netherlands (1994)
  • Switzerland (1995)
  • Canada (1994)
  • Argentina (1995)
  • Chile (1995)
  • Panama (2003)
  • United Arab Emirates (2003)
  • Saudi Arabia (2008)
  • Qatar (2018)
  • Kuwait (2002)
  • Oman (2002)
  • Japan (2015)
  • Israel (2010)

No treaty with Mexico, Brazil, Colombia, and Peru.

Türkiye: a 2017 treaty has been signed but is not in force; the 1996 treaty remains in force.

Source (opens in a new tab)

Energy Charter Treaty

A multilateral treaty for the energy sector, signed on December 17, 1994 and in force since April 16, 1998. Ukraine remains a party, while many European states and the EU have withdrawn.

Withdrawals and their effective dates

  • ItalyJanuary 1, 2016
  • FranceDecember 8, 2023
  • GermanyDecember 20, 2023
  • PolandDecember 29, 2023
  • LuxembourgJune 17, 2024
  • SloveniaOctober 14, 2024
  • PortugalFebruary 2, 2025
  • SpainApril 17, 2025
  • United KingdomApril 27, 2025
  • EU and EuratomJune 28, 2025
  • NetherlandsJune 28, 2025
  • DenmarkSeptember 4, 2025
  • LithuaniaAugust 8, 2026
  • Icelandtakes effect March 17, 2027
  • Irelandtakes effect April 28, 2027
  • Romaniatakes effect May 23, 2027

Source (opens in a new tab)

Sources

  1. ICSID – Database of Member States (opens in a new tab)
  2. UNCITRAL – Status: New York Convention 1958 (opens in a new tab)
  3. UNCTAD – The Energy Charter Treaty (1994) (opens in a new tab)
  4. MIGA – Member countries (opens in a new tab)
  5. MIGA – Ukraine response (opens in a new tab)
  6. UNCTAD IIA Navigator – Ukraine (opens in a new tab)

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PPP and investment protection law by country | EUROBRIDGE