Energy contracts, due to their long-term nature, heavy investments, and geopolitical sensitivity, are always at risk of complex disputes. In the meantime, the "arbitration agreement" as the "gateway" to the arbitration process and with its specific functions that go beyond a ritual and formal document, plays a vital role by creating the necessary flexibility not only in determining jurisdiction, governing law, and procedural rules, but also provides the basis for solving expert and technical views on unpredictable and specialized issues with respect to the type of energy contracts. The present study, which has been compiled using a library and descriptive-analytical method, while explaining the concept, function, and necessity of drafting an arbitration agreement in energy contracts and examining the approach of the legal systems of the three countries of Iran, Japan, and France to this issue, relies on comparative studies to seek the fundamental question of what is the appropriate model for the Iranian legal system regarding drafting an arbitration agreement in energy contracts, especially in the current circumstances and the existence of various sanctions in the country. The studies conducted indicate that Iranian law is influenced by Islamic jurisprudence and civil procedure laws.
Japan, by adopting a broad and flexible approach to international commercial arbitration, and France, with its dynamic judicial practice and maximum support for the independence of the parties' will, which is reflected in the arbitration agreement, are pioneers in this regard. Meanwhile, the conditions of our country are such that in order to attract investment in the energy sector and resolve contractual challenges, while requiring the amendment of laws, it is appropriate to consider a model in the preparation of the agreement that is more consistent with the French legal system.

Keywords: Arbitration agreement, appropriate model, legal gaps, Japanese legal system, French legal system.