The enforcement of international commercial arbitral awards against states faces a significant challenge: many states invoke sovereign immunity to resist execution, potentially rendering the arbitration process ineffective. This research conducts a comparative study between the legal systems of England and Iran, focusing on how each jurisdiction addresses the tension between state immunity and the enforcement of arbitral awards. The study utilizes a library-based methodology, supported by fieldwork involving the collection and analysis of relevant court judgments. The central question explored is how each legal system, within its legislative and institutional framework, responds to state immunity claims at the enforcement stage and whether a proper balance is struck between the principle of state sovereignty and the functional requirements of international arbitration. The findings suggest that the English legal system, through the State Immunity Act 1978, has developed a coherent and arbitration-friendly structure. It clearly distinguishes between jurisdictional immunity and enforcement immunity, a distinction consistently applied in judicial practice. Conversely, the Iranian legal system lacks a dedicated legal framework for state immunity and instead relies on general principles and scattered precedents, leading to ambiguity and legal uncertainty. This undermines the predictability of outcomes in enforcement proceedings involving states. The article concludes by recommending that Iran undertake substantive legal reforms to clarify and restrict the scope of state immunity, especially in relation to the enforcement of arbitral awards. Such reforms are essential for enhancing Iran’s reliability and attractiveness as a jurisdiction in the field of international commercial arbitration.