During the discussions in the resumed 38th session of UNCITRAL Working Group III—held in Vienna from 20 to 24 January 2020—a principal issue under consideration by delegates was the enforceability of ‘awards’ rendered by an appellate mechanism or an investment court. The centrality of the issue of enforcement in the discussions rests upon the requirement that in order for a new dispute resolution system to be effective and to create confidence among its users, its outcomes will need to be predictably enforceable.