| SIAC (2016 rules) | ICC | LCIA | HKIAC | |
| Consolidation of multi-contract disputes | ✔ | ✔ | ✔ | ✔ |
| Joinder of parties and non-parties |
✔ |
✔ | ✔ |
✘ (Non-parties disallowed) |
| Early dismissal of claims/ defences |
✔ |
✘ | ✘ |
✘ |
| Delocalising the Seat of Arbitration |
✔ |
✔ | ✘
(Default seat is London if parties have not agreed; Parties can subsequently request another seat) |
✘ (Default seat is Hong Kong if parties have not agreed) |
| Remedy against non-paying party for unpaid deposits | ✔ | ✘ | ✔ |
✔
|
| Expedited procedure may be heard solely on documentary evidence |
✔ |
✘
(Expedited procedure unavailable) |
✘
(Appears to be silent) |
✔ |
| Emergency arbitration proceedings (appointment of arbitrator in 1 day) |
✔ |
✘
(Appointment within 2 days) |
✘
(Appointment within 3 days) |
✘ (Appointment within 2 days) |
| Arbitrator’s appointment can be challenged; A reasoned decision to any challenge will be given and a fee is payable |
✔ |
✘ | ✔
(The former arbitrator’s fees are not fixed) |
✘ |
With thanks to Lakshanthi Fernando.
Singapore International Arbitration Blog 