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| ICC Rules 2021 | SIAC Rules 2025 | HKIAC Rules 2024 | VIAC Rules 2021 | ICDR Rules 2021 | SCC Rules 2017 | DIS Rules 2018 | LCIA Rules 2020 | Swiss Rules 2021 | DIAC Rules 2022 | CPR Intn'l Administered Rules 2019 | ISTAC Rules 2017 | AIAC Rules 2021 | JAMS Rules 2021 | KCAB Rules 2016 | SCCA Rules 2023 | CAM-CCBC Rules 2022 | |
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| Deemed Start of arbitration | Article 4.2 Day request is received by ICC Secretariat | Rule 6.2 Date of receipt of complete Notice of Arbitration by Registrar | Article 4.2 Day Notice of Arbitration is received by HKIAC | Article 7.1 Day the Statement of Claim is received by Secretariat or by an Austrian Regional Economic Chamber | Article 2.2 Day Notice of Arbitration is received by Administrator | Article 8 Day Request is received by SCC | Article 6.1 Day Request is filed with DIS | Articles 1.4, 4.4 Date of receipt by the Registrar, which is the date delivered (if hard copy) or transmitted (if soft copy) | Article 3.2 Day Notice of Arbitration is received by SCAI Secretariat | Article 4.6 Day, complete Request is received by DIAC | Rule 3.4 Date on which CPR receives notice of arbitration | Article 7.6 Date on which Request for Arbitration and registration fee are received | Rule 7.5 Date on which Notice of Arbitration is delivered to respondent | Article 2.4 (a) Issuance of Commencement Letter | Article 8.2 Day Request for Arbitration is received by the KCAB Secretariat | Article 5.4, the date on which the SCCA determines at its discretion that the filing requirements provided by Article 5 have been satisfied and the SCCA registration fee has been paid. | No express rule; initiation of the proceedings according to Articles 7.1 and 7.2 |
| Default deadline for response | Article 5.1 30 days from receiving request from ICC Secretariat by respondent | Rule 7.1 14 days from receipt of notice of arbitration by respondent | Article 5.1 30 days from receipt of Notice of Arbitration by respondent | Article 8.1 30 days from receipt of the Statement of Claim | Article 3.1 30 days after Administrator confirms receipt of Notice of Arbitration | Article 9(1) Set by Secretariat | Article 7.2 45 days from transmission of the Request | Article 2.1 28 days from the start of arbitration | Article 4.1 30 days from receipt of the Notice of Arbitration | Article 5.1 30 days after the Request has been notified to the Respondent | Rule 3.5 30 days after Commencement Date | Article 8.1 30 days after the notification of the Request for Arbitration | Rule 6.1 30 days after receipt of notice of arbitration | Article 4.1 Within 30 days after commencement | Article 9.1 30 days from receipt of Request for Arbitration by the respondent | Article 6.1, 30 days from commencement of Arbitration. Answer shall inter alia include any plea that the Arbitral Tribunal to be constituted under these Rules lacks jurisdiction. | Article 8.1 15 days from receipt of Notice of Arbitration |
| Default number of arbitrators | Article 12.2 Sole arbitrator (in deemed complex cases the default number of arbitrators is three) | Rule 19.1 Sole arbitrator | Article 6.1 HKIAC decides | Article 17.2 The Board decides | Article 12 Sole arbitrator, unless Administrator decides three are appropriate | Article 16(2) The Board decides | Article 10.2 Three arbitrators, unless a party requests a sole arbitrator and DIS Arbitration Council grants the requests | Article 5.8 Sole arbitrator | Articles 9.1, 9.2 The SCAI Court decides and will consider all relevant circumstances; as a rule, a sole arbitrator shall decide | Article 10.2 Sole arbitrator, unless the Arbitration Court finds that three arbitrators are appropriate | Rule 5.1.a Generally three arbitrators; one arbitrator only if amount in dispute does not exceed US$ 3 million and CPR does not decide otherwise based on the complexity of the case | Article 13.2 Decision by the Board, taking into account all relevant circumstances and facts | Rule 9.3 Three arbitrators in international arbitration unless Director determines number of arbitrators | Article 7.1 One arbitrator, unless JAMS determines otherwise because of size, complexity or other circumstances of the case | Article 11 Sole arbitrator | Article 15, one arbitrator unless the SCCA Court determines at its discretion that three arbitrators are appropriate because of the size, complexity, or other circumstances of the case. | No default; Article 10.1 states that, if the number of arbitrators was not defined, the CAM-CCBC Presidency shall decide if one or three arbitrators shall be appointed |
| Default appointment of a sole arbitrator | Article 12.3 By ICC Court if parties fail to agree on arbitrator within 30 days from the day respondent received the Request for Arbitration | Rule 21 Joint appointment within 21 days from receipt of request by Registrar, otherwise by President of SIAC | Articles 7.1, 7.2 Joint appointment within 30 days from service of the Notice of Arbitration or 15 days from HKIAC’s decision, otherwise by HKIAC | Article 17.3 By Board if parties fail to agree on arbitrator within 30 days after receiving the Secretary General’s request | Article 13.3 At the written request of any party by Administrator if parties fail to agree on arbitrator within 45 days after Administrator received Notice of Arbitration; Administrator may use ICDR list method in Art. 13.6 | Article 17(3) Joint appointment within 10 days, otherwise by SCC Board | Articles 11, 13.2 Joint appointment within time limit fixed by DIS, otherwise by DIS Appointing Committee | Article 5.6 By LCIA after receipt of Response or, if no Response, 28 days from the start of arbitration | Article 10 Joint appointment within 30 days after • Respondent received Notice of Arbitration if parties have agreed on a sole arbitrator • parties receive SCAI Court’s decision to refer dispute to a sole arbitrator if parties have not agreed upon number of arbitrators, otherwise by SCAI Court | Articles 12.3 By the Arbitration Court if parties fail to jointly nominate an arbitrator; alternative appointment procedure available in Art. 13 | Rule 5.3 By CPR through CPR List Procedure if parties fail to agree on arbitrator within 30 days after deadline for notice of defence | Article 14 By Board if parties fail to agree on arbitrator within 30 days from the notification of claimant's Request for Arbitration | Rule 9.4 By Director upon request of any party if parties fail to agree on arbitrator within 30 days of the respondent's receipt of the notice of arbitration; "list procedure" available in Art. 9.8 | Articles 7.3 and 7.5 By joint appointment of the parties; otherwise by JAMS through method including a list of candidates and considering the parties' responses | Article 12.1 Joint appointment within 30 days of the receipt of the Request of Arbitration by the respondent | Article 16.5 SCCA Court if the parties fail to make a joint nomination within 30 days of the commencement of the arbitration. | Article 13.1 by agreement of the parties; after 15 days appointed by the CAM-CCBC Presidency if the parties could not agree |
| Default appointment of three member tribunal | Articles 12.4, 12.5 Each party nominates an arbitrator; chair appointed by ICC Court | Rule 22 Each party nominates an arbitrator; if within 14 days of first nomination a party fails to nominate its arbitrator, President of SIAC will appoint on its behalf; chair appointed by President of SIAC | Article 8.1 Claimant nominates its arbitrator in the Notice of Arbitration or within 15 days from HKIAC’s decision, and respondent nominates in the Answer to the Notice of Arbitration or within 15 days after Claimant's nomination pursuant to HKIAC's decision, otherwise by HKIAC | Article 17.4 Each party nominates an arbitrator; if a party fails to do so within 30 days after receiving the Secretary General’s request, Board appoints arbitrator | Art. 13.3 [see default appointment of sole arbitrator] | Article 17(4) Parties appoint equal number of arbitrators, chair appointed by SCC Board; if party fails to appoint arbitrator(s) within stipulated time, SCC Board appoints arbitrator(s) | Articles 12, 13.2 Each party nominates an arbitrator; chair jointly nominated by co-arbitrators, otherwise selected and appointed by DIS Appointing Committee | Article 5.6, 5.8 By LCIA after receipt of Response or, if no Response, 28 days from the start of arbitration | Articles 11.1, 11.2 Each party designates an arbitrator within the time limit set by the SCAI Court; chair jointly designated by the arbitrators within 30 days from the confirmation of the second arbitrator, otherwise arbitrators appointed by SCAI Court | Article 12.4 Each party nominates one arbitrator; chair jointly nominated by co-arbitrators within 10 days after appointment of second arbitrator, otherwise appointed by Arbitration Court; alternative appointment procedure available in Art. 13 | Rules 5.1.c, 5.4, 6.1 Screened Selection Procedure: both parties each designate one arbitrator without arbitrators knowing which party nominated them; chair is appointed by CPR; if parties or arbitrators have failed to designate arbitrator, CPR designates arbitrator | Article 14.2, 14.3 Each party nominates one arbitrator and co-arbitrators appoint chair; if parties or arbitrators fail to do so, the Board appoints the arbitrator | Rule 9.5 Each party appoints one arbitrator; party-appointed arbitrators choose chair; if parties/arbitrators fail to appoint arbitrator, the Director appoints arbitrator; "list procedure" available in Art. 9.8 | Articles 7.4 and 7.5 Each party nominates one arbitrator and co-arbitrators appoint chair; if parties or arbitrators fail to do so, JAMS appoints co-arbitrator and uses method with list of candidates for chair (Art. 7(5)) | Article 12.2 The claimant nominates one arbitrator in the Request for Arbitration or within such additional period of time fixed by the Secretariat; the respondent nominates one arbitrator in the Answer to the Request for Arbitration or within such additional period of time fixed by the Secretariat | Article 16.6, 16.10, each party nominates an arbitrator within 30 days after the commencement of the arbitration, and the presiding arbitrator shall be appointed by the SCCA Court. SCCA Court may use list procedure. | Article 11.1 Both parties each nominate one arbitrator within 15 days after receipt of rules; Article 11.5 Co-arbitrators subsequently appoint chair; Article 11.8 If parties/ co-arbitrators fail to appoint arbitrator, the appointment shall be made by the CAM-CCBC Presidency |
| Default restrictions on arbitrators where parties with different nationalities | Article 13.5, 13.6 Sole arbitrator/chair not of nationality of any party; if investment arbitration based on treaty, no arbitrator of nationality of any party | Rule 19.7 Unless parties agreed otherwise, if parties are of different nationalities, President appoints a sole arbitrator of different nationality to the parties | Articles 11.2, 11.3 Sole arbitrator/chair not of nationality of any party unless otherwise agreed by all parties or in appropriate circumstances with no objections within a time limit set by HKIAC | None | Article 13.4 At the request of any party or on its own initiative, Administrator may appoint nationals of a country other than that of any of the parties | Article 17(6) Sole arbitrator/chair not of nationality of any party | Articles 11, 12.3 Sole arbitrator /chair not of nationality of any party if appointed by DIS Appointing Committee, unless all parties are of the same nationality or otherwise agreed by the parties | Article 6.1 Sole arbitrator/chair not of nationality of any party | None | Article 11.1 Sole arbitrator/chair not of nationality of any party, unless parties who are not of the same nationality as proposed arbitrator agree, or Arbitration Court decides | Rule 6.2.b Upon request of any party, arbitrators shall be of nationality other than that of the parties | None | Rule 10.5 Sole arbitrator/chair not of nationality of any party, unless otherwise agreed by parties or determined by Director | None | Article 12.4 Upon either party’s request, the Secretariat appoints a sole arbitrator/chair whose nationality is different from the nationalities of the parties. | None | Article 11.9 Upon either party's request, the CAM-CCBC Presidency shall decide about "the need and convenience" to appoint a president of the arbitral tribunal with a nationality different than that of both parties' case by case |
| Time limit for challenging arbitrator | Article 14.2 30 days from appointment/confirmation or 30 days from becoming aware of relevant circumstances | Rule 27.1 Within 15 days of notice of appointment or within 15 days of becoming aware of circumstances for challenge | Article 11.7 15 days from appointment or 15 days from becoming aware of relevant circumstances | Article 20.2 15 days from becoming aware of relevant circumstances | Article 15.1 15 days from notification of appointment or 15 days from becoming aware of relevant circumstances | Article 19(3) 15 days from becoming aware of relevant circumstances | Article 15.2 14 days from becoming aware of relevant circumstances | Article 10.3 14 days from appointment or, if later, 14 days from becoming aware of relevant circumstances | Article 13.2 15 days from becoming aware of relevant circumstances | Article 15.2 15 days from receipt of notification of appointment or 15 days from becoming aware of relevant circumstances | Rule 7.6 15 days after receipt of notification of the appointment or becoming aware of relevant circumstances | Article 16.2 30 days after notification of choice or appointment of the arbitrator or after relevant circumstances became known | Rule 11.2 15 days after becoming aware of relevant circumstances | Article 9.1 Within 15 days from notification of appointment or within 15 days of becoming aware of relevant circumstances | Article 14.3 Within 15 days from (1) the date of receipt of the confirmation of the nomination/appointment of the arbitrator or (2) the date on which the party making the challenge becomes aware of the facts and circumstances giving rise to such challenge | Article 18.3, 14 days after the appointment of the challenged arbitrator or after the circumstances giving grounds for the challenge became known to the party. | Article 14.1 Challenge is possible within 10 days after becoming aware of a relevant fact with regards to independence, impartiality or another justifiable cause |
| Joinder | Articles 7.1, 7.5 On request by a party prior to confirmation/appointment of any arbitrator, unless otherwise agreed; requests after confirmation/appointment are subject to additional party's acceptance of the tribunal and Terms of Reference and are decided by the tribunal | Rule 18 On application by a party or third-party either before or after formation of tribunal if third party is prima facie party to arbitration agreement or all parties consent. Note also Rule 17 on co-ordinated proceedings. | Article 27.1 On request by a party or third-party before or after constitution of tribunal if joining party is prima facie bound by an arbitration agreement under the Rules or all parties, including joining party, consent to joinder | Article 14 On request by a party or third-party before or after constitution of tribunal | Article 8 On request by a party prior to appointment of an arbitrator, unless • otherwise agreed, or • the arbitral tribunal once constituted determines that joinder is appropriate, and the additional party consents to such joinder | Articles 13(1), 13(2) On request by a party and only permitted prior to the submission of the Answer, unless the SCC Board decides otherwise | Article 19.1 On request by a party and only permitted prior to appointment of any arbitrator | Article 22.1(x) Only on application by a party and consent of applicant and new party required | Article 6 On request by a party or non-party before or after constitution of tribunal; application before constitution requires preliminary decision of the Court, Art. 6.2, 5 | Article 9 Request by a party or non-party; requires consent of all parties or that joining party is party to arbitration agreement referred to in Request | Rule 3.12 Prior to appointment of any arbitrator upon the request of any party unless CPR finds otherwise | No rules available | Rule 21.1 On request of any party to the arbitration or any third party (after the filing of the statement of defence only in exceptional circumstances) if either all parties agree or third party is prima facie bound by arbitration agreement or it is necessary for efficient resolution of the dispute and directly affects outcome of the proceedings | Article 6.3 On application by any party (including potential third party); Tribunal will decide on such request, after consulting with all parties, taking into account all circumstances it deems relevant and applicable | Article 21.1 On application by a party and (1) an agreement in writing to the joinder between the applicant and the joining third-party or (2) the joining third-party being a part of the same arbitration agreement and agreeing to join the arbitration proceedings | Article 12, on request by a party prior to the appointment of any arbitrator; requests after appointment are subject to all parties’ agreement and additional party's acceptance of the tribunal, or agreement of the additional party, additional party's acceptance of the tribunal and subject to the tribunal’s decision. The tribunal shall take into account all relevant circumstances, including whether the tribunal has prima facie jurisdiction over the additional party, the timing of the request for joinder, possible conflicts of interests, and the impact of the joinder on the arbitration. | Article 18 By request of the party who wishes to include an additional party (18.1); decided by the CAM-CCBC Presidency before constitution of the arbitral tribunal (18.2); after the constitution of the arbitral tribunal by the arbitral tribunal itself (18.4); by submission to the CAM-CCBC Presidency by a party that voluntarily whishes to be included (18.5) |
| Consolidation | Article 10 On request by party, ICC Court can consolidate pending ICC arbitrations under ICC Rules where • the parties agree; or • all claims made under same arbitration agreement(s); or • same parties, in connection with same legal relationship, and ICC finds arbitration agreements compatible | Rule 16 On request by party SIAC Court or tribunal can consolidate where • parties agree; • claims under same arbitration agreement; or • arbitration agreements are compatible and disputes arise out of same legal relationship, principal and ancillary contract or same transaction or series of transactions. Note also Rule 17 on co-ordinated proceedings. | Article 28.1 On request by party, HKIAC can consolidate where (a) parties agree, or (b) claims are made under the same arbitration agreement; or (c) claims are made under more than one arbitration agreement, common question of law/fact in all arbitrations, right to relief is in respect of or arise out of same transaction or a series of related transactions, and the arbitration agreements are compatible | Article 15 On request by party, Board can consolidate proceedings where • all parties agree; or • same arbitrator(s) was/were appointed and the place of arbitration in all of the arbitration agreements is the same. Board shall consider compatibility of the arbitration agreements and the respective stage of the arbitral proceedings | Article 9 On request by party or on its own initiative, Administrator may appoint a consolidation arbitrator. Consolidation arbitrator may consolidate proceedings where applicable rules are administered by AAA or ICDR and • all parties expressly agreed to appoint consolidation arbitrator; or • all claims made under same arbitration agreement; or • same or related parties, disputes in connection with same legal relationship and arbitration agreements may be compatible | Article 15(1) On request by party, SCC Board can consolidate newly commended SCC arbitration with pending arbitration where • parties agree; or • all claims are made under same arbitration agreement; or • relief sought arises out of the same transaction/series of transactions and SCC Board finds arbitration agreements compatible | Article 8.1 On request by party and only if all parties agree | Article 22A (22.7, 22.8) 22.7 By order of the tribunal upon application by any party and subject to approval by LCIA where: • all parties consent; or • LCIA arbitrations commenced under same/compatible arbitration agreement between same parties; and no tribunal appointed or composed of same arbitrators 22.8 LCIA Court can consolidate where • all parties consent; or • LCIA arbitrations commenced under same/compatible arbitration agreement between same parties; and no tribunal appointed | Article 7 The SCAI Court can consolidate pending arbitrations under Swiss Rules and will take into account all relevant circumstances, including links between the cases and the progress made in the proceedings | Article 8.2 Upon request by any party prior to appointment of an arbitrator if • all claims made under same arbitration agreement; or • same parties, compatibility of arbitration agreements, and disputes arise out of same legal relationship or underlying contracts consist of principal and ancillary contracts or claims arise out of related transactions | Rule 3.13 Upon request of any party and after consultation with the parties where • parties have agreed to consolidation; or • all claims are made under same arbitration agreement; or • claims are made under different arbitration agreements but between the same parties, the disputes arise in connection with same legal relationship and CPR finds arbitration agreements compatible | Article 11.1 Upon request of any party where two or more arbitrations are pending under the ISTAC Rules and where • parties to the arbitrations are different and have agreed to consolidation; or • parties to the arbitrations are the same and: 1) have agree to consolidation, or 2) all claims in the arbitrations are based on same arbitration agreement, or 3) the claims in the arbitrations are based on more than one arbitration agreement but arise in connection with same legal relationship and are compatible | Rule 22.1 Upon request of any party where • parties have agreed to consolidation; or • all claims in the arbitrations are made under same arbitration agreement; or • claims are made under more than one arbitration agreement but dispute arises in connection with same legal relationships and arbitration agreements are compatible | Article 6.1 Upon request by the parties and at discretion of JAMS after consulting with parties to all proceedings and the Tribunal; parties do not need to be identical | Article 23.1 On a request by a party, the Arbitral Tribunal may consolidate claims made in separate but pending arbitration | Article 13, at the request of a party, SCCA Court may consolidate where the parties agree; or the claims are made under the same arbitration agreement; or the disputes arise in connection with the same relationship and the SCCA Court finds the arbitration agreements compatible. No application can be made after the tribunal is fully constituted unless the parties agree to consolidation; or all members of the tribunal are identical and each tribunal requests that there be consolidation. SCCA Court is to take into account all relevant circumstances, including the applicable law, if the same arbitrators are appointed, the progress of the arbitrations, common issues of law and/or facts, whether the consolidation is in the interests of justice and efficiency. | Article 19.1 At the request of a party, before the constitution of the arbitral tribunal for the to-be-consolidated proceeding, the CAM-CCBC Presidency may consolidate the two if (a) the parties have agreed to consolidate, (b) all claims are made based on the same arbitration agreement(s) or (c) the arbitration agreements are not the same, but the (i) parties are the same, (ii) the disputes are related to the same legal relationship and (iii) the CAM-CCBC Presidency deems the arbitration agreements compatible. |
| Tribunal's discretion to order Interim Measures | Article 28.1 On request by any party the tribunal has power to order any interim or conservatory measure tribunal deems appropriate | Rule 45.1 On request by any party the tribunal has power to order or award any injunction or any other interim relief it deems appropriate; tribunal may ask for security from requesting party | Article 23.2 On request by any party the tribunal has power to order any interim measures tribunal deems necessary or appropriate | Article 33.1 On request by any party the tribunal has power to order any interim or conservatory measure or amend, suspend or revoke any such measure | Article 27.1 On request by any party the tribunal has power to order any interim or conservatory measure tribunal deems necessary | Article 37(1) On request by any party the tribunal has power to order any interim measure tribunal deems appropriate | Article 25.1 On request by any party the tribunal has power to order any interim or conservatory measure, amend, suspend or revoke any such measure, unless the parties have agreed otherwise | Article 25.1 On request by any party the tribunal has power to order: • respondent to provide security for all or part of the amount in dispute • preservation, storage, sale or disposal of property or thing under control of any party and relating to arbitration • provisional relief subject to final award | Article 29.1 On request by any party the tribunal has power to order any interim measure tribunal deems appropriate or - in exceptional circumstances even on its own initiative - modify, suspend or terminate any interim measure granted | Appendix II, Art. 1.1 On request by any party the tribunal has power to issue provisional orders or order interim measures the tribunal considers appropriate | Rule 13 On request by any party, tribunal has power to order interim measures it deems necessary | Article 31.2 On request by any party, tribunal has power to grant interim measures it deems appropriate | Rule 16.1 At request of any party, tribunal has power to grant interim measures | Article 31.1 At request of any party, tribunal may order whatever interim measures it deems necessary | Article 32.1 At the request of a party, the Arbitral Tribunal may order interim measures as it deems appropriate | Article 28, upon application by any party the tribunal may grant interim measures which may include an order to (1) Maintain or restore the status quo pending determination of the dispute, (2) Take action that would prevent, or refrain from taking action that is likely to cause (a) current or imminent harm, or (b) prejudice to the arbitral process, (3) Provide a means of preserving assets out of which a subsequent award may be satisfied, (4) Preserve evidence that may be relevant and material to the resolution of the dispute. | Article 22.1 The arbitral tribunal may issue provisional, coercive and interlocutory measures at its own discretion, at any parties request, unless otherwise agreed between the parties. |
| Confidentiality | Article 22.3 No confidentiality provision binding parties or arbitrators, but any party can apply for confidentiality of proceedings, or to protect trade secrets or confidential information; ICC publishes all awards unless one party objects | Rule 59 All matters relating to proceedings and award, disclosure permitted in limited circumstances | Article 45 Covers any information about the arbitration, an award or emergency decision, with disclosure permitted in limited circumstances. Confidentiality extends to all parties, party representatives, tribunal and HKIAC as well as any emergency arbitrator, expert, witness and tribunal secretary | Article 16.2 Arbitrators have the duty to keep all information acquired in the course of their duties confidential [Art. 2.4 confidentiality of the Board] [Art. 4.4. confidentiality of the Secretariat] | Article 40.1 Confidential information shall not be divulged by arbitrators or Administrator | Article 3 SCC, tribunal and any administrative secretary maintain confidentiality of arbitration and award, unless otherwise agreed by parties | Article 44 All matters concerning the arbitration, including its existence, disclosure permitted in limited circumstances | Article 30 Awards and any materials in proceedings are confidential; disclosure permitted in limited circumstances | Article 44 Awards, orders and any materials in proceedings are confidential, unless otherwise agreed; disclosure permitted in limited circumstances | Article 38 Awards, orders and any materials in proceedings are confidential, unless otherwise agreed; disclosure permitted in limited circumstances | Rule 20 Unless parties agree otherwise, proceedings are confidential except in case of judicial proceedings ancillary to arbitration, statutory provision to the contrary, or protection of legal rights of a party | Article 21.1 Proceedings are confidential; at request of a party, tribunal can take necessary measures to protect confidential information | Rule 44.1 All matters relating to proceedings, except where disclosure is necessary for implementation and enforcement of the award or disclosure is required of a party by a legal duty | Article 16 Unless otherwise required by law, or unless the parties agree otherwise, Tribunal, parties and JAMS maintain the confidentiality of the arbitration | Article 57 Arbitration proceedings, and records thereof, are confidential; disclosure permitted only when it is agreed by the parties, required by law, or required in court proceedings | Article 44, all Confidential information disclosed by parties or witnesses during the arbitration shall not be divulged by arbitrators and SCCA; Unless the parties agree otherwise, the tribunal may issue orders concerning the confidentiality of the arbitration or any matters in connection with the arbitration and may take measures to protect trade secrets and confidential information. Article 36.3, unless the parties agree, or applicable law requires, otherwise, the parties and their representatives shall keep any award order, decision, or other ruling confidential at all times. | Article 39.1 The arbitration shall be confidential, except in cases provided for by law, other applicable legal rules, or by express agreement between the parties. |
| Time limit for issuing award | Article 31.1 Within 6 months from date of last signature of Terms of Reference | Rule 53.2, 53.3 Tribunal to give draft award to Registrar within 90 days from close of proceedings; award to be delivered as soon as practicable afterwards following Registrar comments | Article 31.2 No later than three months from the date when the tribunal declares the entire proceedings or the relevant phase of the proceedings closed, as applicable. Extendable by party agreement or by HKIAC in appropriate circumstances | Art. 32.2 No later than three months after the last hearing or filing of the last authorized submission concerning matters to be decided in an award, whatever is the later | Article 33.1 60 days from the closing of the hearing, unless otherwise agreed, specified by law or determined by Administrator | Article 43 Within 6 months from date of referral to tribunal | Article 37 Tribunal shall send award to DIS for review within three months after the last hearing or last authorized submission, whichever is later | No time limit; but tribunal should endeavour to issue final award no later than three months following the last submission from the parties (15.10) | No time limit | Article 35 6 months from transmission of file to the tribunal, unless extended by written agreement of parties or by Arbitration Court | Rule 15.8.a Awards should generally be rendered within two months after close of proceedings | Article 33.1 6 months after the completion of signature on the Terms of Reference or after the notification of the approval of the Terms of Reference to the Tribunal | Rule 34.1 Arbitral tribunal has to submit draft of final award to Director for technical review within 90 days after closing of proceedings | Article 33.1 Within three months of dispute being heard and submitted to tribunal for a decision | Article 38.1 Within 45 days from the date on which (1) final submissions are made or (2) the hearings are closed whichever is later | Article 33.3, 75 days from the date of the closing of the proceedings. | Article 29 Sixty (60) days after receiving the closing statements (or after expiration of the time limit for presenting closing statements), unless another time limit is established in the Terms of Reference or agreed with the parties. |
| Expedited / summary procedure | Articles 30.2, 30.3 Unless parties opt out or ICC Court finds application inappropriate, expedited procedure rules apply if amount in dispute does not exceed 3,000,000 US$ or parties agree | Rule 13 and Schedule 2 - Prior to constitution of Tribunal, parties can agree to application of streamlined procedure if amount in dispute does not exceed S$1,000,000. Rule 14 and Schedule 3 - Expedited procedure available if applied for at the time of filing Notice or Response or prior to constitution of tribunal and where (i) amount in dispute below S$ 10,00,000 but above S$ 1,000,000; (ii) amount in dispute below S$ 1,000,000 and President has determined that Streamlined Procedure shall not apply; or (iii) circumstances warrant expedited procedure. | Articles 42, 43 Expedited procedure available prior to formation of tribunal in limited circumstances. Early determination procedure available to summarily decide on one or more points of law/fact | Article 45 Available if the parties agree on expedited procedures no later than the submission of the Answer to the Statement of Claim | Article 1.4 Unless parties opt out or Administrator finds application inappropriate, expedited procedure rules apply if no disclosed claim or counterclaim exceeds 500,000 US$ or parties agree | Rules for Expedited Arbitrations applicable if parties expressly agree | Article 1.4, Annex 4 Available if the parties agree on application of Annex 4 | Article 9A Expedited tribunal available in exceptional urgency | Article 42.1 Available if parties agree on expedited procedures or if amount in dispute does not exceed CHF 1,000,000, unless the SCAI Court decides otherwise | Article 32.1 Applies: unless otherwise agreed, if amount in dispute does not exceed AED1,000,000; or if parties agree; or in cases of exceptional urgency as determined by Arbitration Court upon application by a party. | Accelerated Rule 1.1 Global Rules for Accelerated Commercial Arbitration (International) apply where the parties have incorporated the Rules in the arbitration agreement (parties can agree on further conditions) | Article 1 of the ISTAC Fast Track Arbitration Rules Fast Track Rules apply where: • amount in dispute does not exceed 300,000.00 ₺, or • the parties so agree | Rule 8.2 Upon request by any party where parties have agreed or the amount in dispute is less than USD 500,000 (for international arbitrations) or there is exceptional urgency | Article 22 On application to JAMS prior to full constitution of Tribunal, provided Amount in dispute does not exceed USD 5 million, or if parties so agree, or in cases of exceptional urgency | Articles 43-49 Expedited Procedures available (1) where the claim amount does not exceed KRW 500,000,000; or (2) where the parties agree to be subject to the Expedited Procedures | Appendix 2, the Expedited Procedure Rules shall apply if the parties so agree, or where the amount in dispute does not exceed SAR 4,000,000 (US$ 1,066,409) or an equivalent amount, exclusive of the costs of arbitration, representing the aggregate amount in claims. | Article 36.1 Applicable to proceedings where the amount in dispute does not exceed BRL 3.000.000 (ca. USD 600.000; August 2023). Parties may opt out of the procedure (36.2). Article 37 Time limits may be reduced to speed up proceedings (37.3); the proceedings shall commence electronically (paperless, via videoconference if possible) (37.4, 37.10); the procedure shall be conducted by a sole arbitrator, unless agreed upon otherwise (37.5) - the CAM-CCBC secretariat shall invite the parties to agree to a sole arbitrator if the arbitration agreement proposes a three arbitrator tribunal (37.6); if parties cannot agree, the tribunal shall be constituted as agreed upon in the arbitration agreement (37.6). |
| Availability of emergency arbitrator | Article 29 and Appendix V Prior to arbitration file being transmitted to tribunal; not available in investment arbitration | Rule 12.1 and Schedule 1– Applicant may request appointment of Emergency Arbitrator prior to submitting Notice of Arbitration. Notice to be filed within 7 days. | Article 23, Schedule 4 Prior to the commencement of arbitration until the constitution of tribunal | Not available | Article 7 Prior to constitution of tribunal | Appendix II, Article 1(1) Prior to arbitration file being transmitted to tribunal | Not available | Article 9B Emergency, unless arbitration agreed before 1 Oct 2014 and parties did not 'opt-in'; or parties agreed to 'opt-out' (Article 9.16) | Article 43.1 Prior to the constitution of tribunal | Appendix II, Art.2 Prior to constitution of tribunal | Rule 14 Prior to constitution of tribunal | Article 1.1 of the ISTAC Emergency Arbitrator Rules Prior to transmission of the file to the tribunal | Rule 17.1 Prior to constitution of tribunal | Article 3 Prior to constitution of tribunal | Appendix 3, Article 1.1 Concurrent with or following the submission of the Request of Arbitration but before constitution of the Arbitral Tribunal | Article 7 and Appendix III, before the constitution of the Arbitral Tribunal; the SCCA shall appoint an emergency arbitrator one business day after receipt of application. | Article 21 and Appendix I A party that needs provisional measures may file for appointment before the constitution of the arbitral tribunal (21.1) |
| Cost allocation | Articles 38.4, 38.5 Tribunal has discretion and will consider relevant factors including conduct of parties | Rules 57 and 58 – Registrar shall determine costs of arbitration at conclusion of arbitration in accordance with Schedule of Fees and Practice Notes for time being in force. Tribunal has authority to order that all or part of legal or other costs of party be paid by another party. | Articles 34.3, 34.4 Tribunal has discretion and will consider relevant factors, including any third party funding arrangement, outcome related fee structure agreement, or adverse environmental impact arising out of the parties’ conduct in the arbitration | Article 38.2 Tribunal has discretion, unless otherwise agreed by parties, and will consider relevant factors, including conduct of parties | Article 37 Tribunal has discretion and will consider the circumstances of the case | Article 49(6), 50 Unless otherwise agreed by the parties , tribunal has discretion and will consider the outcome and other relevant circumstances | Article 33.2. 33.3 Tribunal has discretion and shall take into account all circumstances it considers to be relevant, including the outcome of the arbitration and conduct of parties | Article 28.4 Tribunal has discretion, with general principle that costs reflect parties' relative success and failures in the award | Articles 40.1, 40.2 Costs of arbitration shall be borne by unsuccessful party, unless tribunal finds apportionment reasonable; tribunal has full discretion regarding parties’ legal costs | Article 36 No specific rules on the allocation of costs | Rule 19 Discretion of the tribunal unless otherwise agreed by the parties | Article 41.1 Discretion of the tribunal | Rule 13.5 (l) In principle borne by unsuccessful party but at discretion of the tribunal having regard to the circumstances of the case | Article 36.4 Discretion of the tribunal, taking into account the circumstances of the case | Article 53 The Arbitral Tribunal has the discretion over how to allocate legal costs and necessary expenses incurred by the parties in connection with the proceedings, including legal fees and costs for experts, interpreters, and witnesses. Unless otherwise agreed by the parties, the Arbitral Tribunal also has the power to allocate the necessary expenses in any manner it deems appropriate | Article 40, Arbitral Tribunal shall allocate the costs of arbitration among the parties at its discretion, taking into account the circumstances of the case, including the extent to which each party has conducted the arbitration in an expeditious and cost-effective manner. | Schedule of Costs I. 9., Article 30.4 The arbitral tribunal shall establish liability and apportionment of the costs (30.4); the default allocation is 50% Claimant(s), 50% Respondent(s) |
| Mediation | ICC Mediation Rules available; recommended mediation clauses available | Rules 32.4 and 50.2 - Cues to Tribunals to prompt parties to consider mediation - SIAC-SIMC Arb-Med-Arb Protocol available; recommended Arb-Med-Arb clause available | HKIAC Mediation Rules available. Recommended mediation clause available. | Vienna Mediation Rules available. Recommended mediation clause available. | International Mediation rules available. Recommended mediation clause available. | SCC Mediation Rules available. Recommended mediation clause available. | DIS Mediation Rules available. Recommended mediation clause available. | LCIA Mediation Rules available. Recommended mediation clauses available | Swiss Rules of Mediation (2021) available. Recommended mediation clause available. | Not available | Rule 21 Mediation available at any stage of the proceedings; recommended multi-step clauses available | ISTAC Mediation Rules available | AIAC Mediation Rules 2018 available; Med-Arb Procedure available; recommended model clauses available | JAMS International Mediation Rules available; recommended mediation clauses available | Mediation Rules are available in Korean; International Mediation Rules are currently being drafted | SCCA Mediation available. | CAM-CCBC Mediation Rules 2016 available; recommended multi-tier clauses availableCAM-CCBC Mediation Rules 2016 available; recommended multi-tier clauses available |
| Languages spoken at the Secretariat other than English | "all major languages" including Arabic, Chinese, German, Italian, Portuguese, Russian and Spanish | Bahasa Indonesia, Chinese, French, Hindi, Korean, Lithuanian, Malay, Russian and Tagalog | Mandarin, Cantonese, French, Russian, Filipino, Korean, Spanish, Japanese, Arabic, and Swedish | Italian, French, Polish, Spanish, Russian, Czech and Slovak (case administration in German and English) | "world's business languages" | Swedish and Russian | German (no further information available) | No information available | French, German, Italian (no further information available) | Arabic, Hindi, Spanish, Portugese | No information available | Turkish | Bahasa Indonesian, Bahasa Malay, Cantonese, French, German, Hindi, Mandarin, Odia, Russian, Spanish, Tamil | "JAMS employees can assist clients in more than 30 languages" | Korean | Arabic | Portuguese, Spanish, French Portuguese, Spanish, French |
| Number of cases submitted to in certain years (if numbers available) | 842 (2018) | 663 (2018) | 291 (2023) (excluding domain name disputes submitted to the HKIAC) | 64 (2018) | 993 (2018) | 152 (2018) | 162 (2018) | 317 (2018) | 100 (in 2015) | 168 (2018) 231 (2020), 276 (2021), 340 (2022) | No information available | No information available | 90 (2018) (arbitration only) | 6500 arbitration cases filed in 2019, 190 of which were international | 443 (2019) | By April 2023 – 220 cases with parties from over 20 different countries since it became operational in 2016. | 115 OR 116 (2022) |
| Average costs (administrative + tribunal's fees) at 1 million US$ amount in dispute | 141,472.00 (max.: 215,725.00) US$ | ~176,674.50 US$ (at 1 US$ = 1,35 SGD) | Maximum fees (acc. to schedule 3): ~60,800 US$ (sole arbitrator), ~162,000 US$ (three arbitrators) (at 1 US$ = 7,85 HK$) | Min.-max. fees: ~92,000.00-122.000,00 US$ (at 1 US$ = 0.9075 EUR) | 18,975.00 + X US$ [standard administrative fee schedule + arbitrators' fees (Case Administrator designates appropriate hourly rate of tribunal's fees, Art. 38)] | ~124,000.00 US$ (at 1 US$ = 0.89 EUR) | ~99,000.00 US$ (at 1 US$ = 0,89 EUR) | Fees at hourly rates (arbitrators' fees at hourly rate up to 500 £); average fees acc. to LCIA costs statistics (2017) if amount in dispute < 1 million US$: ~32,000.00 US$ | Average fees: 132,346.00 US$ (at 1 US$ = 0.91 CHF) | Fees with one arbitrator estimated at AED 147,020 (approx. US$ 40,000). Three arbitrators estimated at AED 361,061 (approx. US$ 98,312). | No fixed arbitrator fees | ~54,000.00 USD (at 1US$=5,74 ₺) | 119,300.00 USD [+ SST (6%)] | Arbitrator fees at hourly rate set by the arbitrator(s); Case Management Fee of 13% against all Professional Fees | See Annexes 1 and 2 of the KCAB International Arbitration Rules for the Cost Schedules | Fees with one arbitrator estimated at US$ 53,455. Fees with Expedited Arbitration estimated at US$ 42,764. Three arbitrators estimated at US$ 127,370. | 3 arbitrator tribunal: 114.805,65 Sole arbitrator: 62.380,51 (Calculated with CAM-CCBC Arbitration Cost Simulation and Schedule of Costs as effective of November 2022; USD 1 = BRL 4,90, August 2023) |
| Average costs (administrative + tribunal's fees) at 10 million US$ amount in dispute | 397,367.00 (max.: 619,715.00) US$ | ~419,088.00 US$ (at 1 US$ = 1,35 SGD) | Maximum fees (acc. to schedule 3): ~147,000 US$ (sole arbitrator), ~394,000 US$ (three arbitrators) (at 1 US$ = 7,85 HK$) | Min.-max. fees: ~251,000.00-338,000.00 US$ (at 1 US$ = 0.9075 EUR) | 28,750.00 + X US$ [standard administrative fee schedule + arbitrators' fees (Case Administrator designates appropriate hourly rate of tribunal's fees, Art. 38)] | ~334,000.00 US$ (at 1 US$ = 0.89 EUR) | ~323,000.00 US$ (at 1 US$ = 0,89 EUR) | Fees at hourly rates (arbitrators' fees at hourly rate up to 500 £); average fees acc. to LCIA costs statistics (2017) if amount in dispute between 1 and 10 million US$: ~79,000 US$ | Average fees: 361,030.00 US$ (at 1 US$ = 0.91 CHF) | Fees with one arbitrator estimated at AED 392,246 (approx. US$ 106,803). Three arbitrators estimated at AED 976,739 (approx. US$ 265,953). | No fixed arbitrator fees | ~155,000.00 USD (at 1US$=5,74 ₺) | 300,100.00 USD [+ SST (6%)] | Arbitrator fees at hourly rate set by the arbitrator(s); Case Management Fee of 13% against all Professional Fees | See Annexes 1 and 2 of the KCAB International Arbitration Rules for the Cost Schedules | Fees with one arbitrator estimated at US$ 155,146. Three arbitrators estimated at US$ 372,399. | 3 arbitrator tribunal: 216.358,81 Sole arbitrator: 114.994,70 (Calculated with CAM-CCBC Arbitration Cost Simulation and Schedule of Costs as effective of November 2022; USD 1 = BRL 4,90, August 2023) |
| Average costs (administrative + tribunal's fees) at 100 million US$ amount in dispute | 744,727.00 (max.: 1,154,875.00) US$ | ~897,668.25 US$ (at 1 US$ = 1,35 SGD) | Maximum fees (acc. to schedule 3): ~314,000 US$ (sole arbitrator), ~840,000 US$ (three arbitrators) (at 1 US$ = 7,85 HK$) | Min.-max. fees: ~542,000.00-726.000,00 US$ (at 1 US$ = 0.9075 EUR) | 42,250.00 + X US$ [standard administrative fee schedule + arbitrators' fees (Case Administrator designates appropriate hourly rate of tribunal's fees, Art. 38)] | ~618.000,00 US$ (at 1 US$ = 0.89 EUR) | ~644,000.00 US$ (at 1 US$ = 0,89 EUR) | Fees at hourly rates (arbitrators' fees at hourly rate up to 500 £); average fees acc. to LCIA costs statistics (2017) if amount in dispute between 10 and 100 million US$: ~185,000.00 US$ | Average fees: 640,830.00 US$ (at 1 US$ = 0.91 CHF) | Fees with one arbitrator estimated at AED 821,564 (approx. US$ 223,701). Three arbitrators estimated at AED 1,924,694 (approx. US$ 524,068). | No fixed arbitrator fees | ~252,000.00 USD (at 1US$=5,74 ₺) | 634,100.00 USD [+ SST (6%)] | Arbitrator fees at hourly rate set by the arbitrator(s); Case Management Fee of 13% against all Professional Fees | See Annexes 1 and 2 of the KCAB International Arbitration Rules for the Cost Schedules | Fees with one arbitrator estimated at US$ 283,074. Three arbitrators estimated at US$ 689,223. | 3 arbitrator tribunal: 411.725,24 Sole arbitrator: 216.765,09 (Calculated with CAM-CCBC Arbitration Cost Simulation and Schedule of Costs as effective of November 2022; USD 1 = BRL 4,90, August 2023) |
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