Ten years after the landmark South China Sea arbitration ruling, the landmark decision was finally commemorated outside the Philippines – and in a capital Beijing would rather have avoided. On 13–14 July, a Track 1.5 conference in Jakarta, co-hosted by Philippine and Indonesian institutions, marked the anniversary of the July 12, 2016 award.

More than a conference, the event was a commemoration of the ruling – unprecedented outside the Philippines – that initially was scheduled to include Indonesian government speakers. Hosting the event in Jakarta, ASEAN’s primus inter pares, sent a signal of regional solidarity against China’s assertive actions in the South China Sea and underscored the willingness of two key maritime Southeast Asian states to shape norms governing behavior at sea.

The arbitral award had global implications. It clarified the legal status of maritime features, rejected China’s claim to historic rights within its “nine-dash line,” and confirmed that none of the Spratly Island features can generate a 200-nautical-mile exclusive economic zone under Article 121(3) of the U.N. Convention on the Law of the Sea (UNCLOS). It also found China in breach of environmental obligations for island-building and destructive harvesting. More broadly, it demonstrated that smaller states can shape international rules — even in the face of great power resistance.

The significance of the event in Jakarta was not lost on Beijing. The Chinese government initially attempted to pressure the organizers to cancel the conference, according to several sources with knowledge of the event. When this failed, it shifted tactics and attempted to undermine the event’s legitimacy. The effort was partly successful: Indonesian officials initially slated to attend the conference withdrew days before the conference, and government backing quietly disappeared from the event’s program. The commemoration went ahead, albeit in reduced form.

The episode distilled a decade of contestation into a single week. At the conference, Chinese and Southeast Asian participants  both spoke the language of “peace and stability,” but mean different things. Chinese participants consistently framed order in terms of stability, while Philippine and Indonesian speakers emphasized equality under a regime of rules. The gap between those premises, more than any particular reef or shoal, is the region’s primary fault line when it comes to maritime order.

Contending with each other are two competing visions of order.

The first is legalist. In this view, entitlements flow from law, rules bind large and small states alike, and adjudication allows weaker states to constrain stronger ones. The second is relational. In this view, order rests on stability, hierarchy, and negotiated consensus; law is only one bargaining tool among many, and managing relations with the region’s dominant power – i.e. China – takes precedence over law.

The Philippines anchors the legalist camp. In Jakarta, its representatives, which included a senior official from the Department of Foreign Affairs, presented the award as a blueprint for regional order. The ruling and UNCLOS together form the foundation of Manila’s maritime policy. More deeply embedded in this is the claim that international law is an equalizer, indifferent to the size of a state’s navy or economy.

This strategy consists of four parts: fidelity to international law, sustained dialogue with Beijing, strengthened partnerships with like-minded states, and domestic capacity-building. As this year’s chair of ASEAN, Manila is also trying to embed elements of this approach regionally, from maritime cooperation initiatives to proposals for institutionalizing coast guard coordination.

Yet even here, there are clear limits. ASEAN consensus still stops short of Beijing’s red lines. Regional statements invoke UNCLOS repeatedly but avoid mentioning either China or the award itself – a silence that reflects a mixture of political caution and strategic calculation.

At home, Manila’s commitment to a legalist order is contested, and the award has been repeatedly downplayed; this position is not exclusive to any one administration, but was most marked during the presidency of Rodrigo Duterte (2016–2022). That same ambivalence was evident in Jakarta during the July 13-14 conference. Indonesia’s Foreign Ministry has long acted as a guardian of UNCLOS and has consistently rejected the legal basis of China’s “nine-dash line.” Jakarta reaffirmed this position in a 2020 note verbale to the United Nations, which explicitly invoked the tribunal’s findings. But Indonesia rarely names the award in political settings. The Jakarta conference revealed why.

Within the Indonesian state, legalist instincts compete with a preference for managing relations with great powers, including China, quietly. Government agencies and academic institutions have shown a  willingness to endorse the ruling, but higher-level political considerations have generally prevailed. The result is a hybrid posture: one that is legalist in principle, but relational in practice.

Elsewhere in Southeast Asia, a form of hedging prevails. Malaysia has taken note of the award without endorsing it. Vietnam has aligned its practice with its legal reasoning but avoids citing it directly.

Officials from both countries acknowledge that much of the award reflects authoritative interpretations of UNCLOS. A decade on, it remains the reference point for regional debates about maritime issues. As one participant in Jakarta noted, it is difficult to imagine cooperation on fisheries or energy “without the ruling.” Fence-sitting, in this sense, is  a strategy that allows Southeast Asian claimants to adhere to the substance of the ruling, while preserving their relationship with China.

The clarity of the award, and its “final and binding” character, has also conditioned China’s response. Beijing has avoided engaging the ruling’s substance and instead targets those referencing it. Unable to cancel the Jakarta conference, it worked to erode its legitimacy. Under apparent Chinese pressure, Indonesian academic institutions and think tanks removed their logos from the conference’s promotional materials. Indonesian government participation was scaled back: a vice-minister was replaced by a director-general, who then withdrew – after which all scheduled Indonesian officials dropped out entirely. The pressure was exercised through personal and institutional ties rather than public demands. This was China’s relational order operating as it was intended.

Two caveats are important. First, Southeast Asia’s tilt toward a relational order should not be interpreted simply as capitulation. States in the region continue to balance, hedge, and pursue their interests across multiple relationships, including with the United States. The pull of relationalism reflects preference and habit as much as outside pressure.

Second, Southeast Asia’s legalists are not proxies for Washington. The 14-nation joint statement reaffirming the 2016 award as final and binding — rejected the same day by China’s Foreign Ministry— included three Baltic states among its signatories, but no ASEAN member beyond the Philippines. The United States has never ratified UNCLOS, and its freedom-of-navigation operations challenge Southeast Asian claims too. The region’s legalism is inclusive by design: it seeks to keep China inside a rules-based order, rather than isolating it by joining a U.S.-led anti-China coalition

The tension between legalistic and relational approaches, which was on display in Jakarta, plays out not only between states but also within them. It is reflected in competing camps across Southeast Asia: one favoring pragmatic engagement with China, and the other seeking to expose Beijing’s coercive behavior and aggression. While these two camps are likely to continue to coexist, they are inherently in competition. At present, political considerations appear to favor a relational approach and a reinforcement of that order, as ties with Beijing are seen as too important and far-reaching to risk by strictly enforcing the South China Sea arbitral award or asserting sovereign rights in disputed EEZs.

Regardless of this trajectory, resistance from scholars and legalists continues to embed the award into accepted regional practice. The important fact was that despite Chinese opposition, the Jakarta commemoration still happened, even in diminished form. This was important. Maritime orders are not built in a single ruling or undone by a single act of pressure, but take shape through repetition, habit, and participation.

Which order prevails will depend on how many states keep up their resistance and refuse to acquiesce.