HasanuddinLawReview Volume 6 Issue 1, April 2020 P-ISSN: 2442-9880, E-ISSN: 2442-9899 Nationally Accredited Journal, Decree No. 32a/E/KPT/2017. This work is licensed under a Creative Commons Attribution 4.0 International License. 25 Much in Little: The Umbrella Clause that Changes the International Investment Protection Standard Kartika Paramita International Business Law Program, Universitas Prasetiya Mulya, Indonesia. E-mail: kartika.paramita@pmbs.ac.id ARTICLE INFO ABSTRACT Keywords: Bilateral Investment Treaty; ICSID; Investment; Umbrella Clause How to cite: Paramita, K. (2020). Much in Little: The Umbrella Clause that Changes the International Investment Protection Standard. Hasanuddin Law Review, 6 (1): 25-45 DOI: 10.20956/halrev.v6i1.1570 The umbrella clause of a Bilateral Investment Treaty (BIT) establishes an obligation for the State parties to respect all commitments entered into by an investment contract between an investor and the host country. It extends the jurisdiction of a BIT forum to the breach-of-contracts matters and changes the nature of a private issue to an international affair. The polemic over the clause's interpretation has become a controversial issue over the years. It comes as a backlash for the Contracting States as a foreign investor could quickly bring an investment problem to an international forum. After more than a decade since its first discussion in the case of SGS v Pakistan, the clause grows to be one of the reasons for many countries to leave or reform their BIT model and changes the trend of international investment protection standard. This article addresses the different episodes of the umbrella clause alongside over the past decade. It projects the debate over the clause’s scope, its development, the governments' action, and their perception over it, and finally, how it changes the standard of investment protection in international treaties. Copyright © 2020 HALREV. All rights reserved. 1. Introduction In 2003, Société Générale de Surveillance S.A (SGS) a company headquartered in Geneva filed a claim against the Islamic Republic of Pakistan before the arbitration tribunal of International Centre for Settlement of Investment Disputes (ICSID). The claim was based on a violation of an agreement made between both of the parties, which SGS claimed had elevated to a breach of bilateral investment protection