An aerial view of Natuna Besar, the largest island in Indonesia’s Natuna archipelago, serves as a stark reminder of the region’s complex maritime landscape. Ten years after the landmark South China Sea arbitration ruling, a significant commemoration took place outside the Philippines—in a capital Beijing would have preferred to avoid. On July 13–14, a Track 1.5 conference in Jakarta, co-hosted by Philippine and Indonesian institutions, marked the anniversary of the July 12, 2016 award. This event, which initially was scheduled to include Indonesian government speakers, served as more than a conference; it was a commemoration of the ruling, an act unprecedented outside the Philippines. Hosting the event in Jakarta, ASEAN’s primus inter pares, signaled 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 event, and government backing quietly disappeared from the program. The commemoration went ahead, albeit in reduced form. As the event noted, you have reached the limit of 2 free articles this month, but the core debate remained clear.
The episode distilled a decade of contestation into a single week. Contending with each other are two competing visions of order. The first is legalist, where entitlements flow from law, rules bind large and small states alike, and adjudication allows weaker states to constrain stronger ones. The second is relational, where 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—China—takes precedence over law. At the conference, Chinese and Southeast Asian participants both spoke the language of “peace and stability,” but meant 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.
The Philippines anchors the legalist camp. In Jakarta, its representatives, including a senior official from the Department of Foreign Affairs, presented the award as a blueprint for regional order. The ruling and UNCLOS form the foundation of Manila’s maritime policy. 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, ASEAN consensus still stops short of Beijing’s red lines, as regional statements invoke UNCLOS but avoid mentioning China or the award itself.
At home, Manila’s commitment to a legalist order is contested, a position most marked during the presidency of Rodrigo Duterte (2016–2022). That same ambivalence was evident in Jakarta. Indonesia’s Foreign Ministry has long acted as a guardian of UNCLOS and rejected the legal basis of China’s “nine-dash line,” reaffirming this in a 2020 note verbale to the United Nations. However, Indonesia rarely names the award in political settings. Within the Indonesian state, legalist instincts compete with a preference for managing relations with great powers quietly. The result is a hybrid posture: legalist in principle, but relational in practice.
Elsewhere in Southeast Asia, hedging prevails. Malaysia has taken note of the award without endorsing it, and 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. As one participant in Jakarta noted, it is difficult to imagine cooperation on fisheries or energy “without the ruling.”
China’s response has been conditioned by the “final and binding” character of the award. Beijing has avoided engaging the ruling’s substance and instead targets those referencing it. Under apparent Chinese pressure, Indonesian academic institutions and think tanks removed their logos from the conference 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. This was China’s relational order operating as 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. Second, Southeast Asia’s legalists are not proxies for Washington. The 14-nation joint statement reaffirming the 2016 award included three Baltic states but no ASEAN member beyond the Philippines. The region’s legalism is inclusive by design: it seeks to keep China inside a rules-based order, rather than isolating it. Regardless of this trajectory, resistance from scholars and legalists continues to embed the award into accepted regional practice. The fact that the Jakarta commemoration happened, even in diminished form, 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.
