An overview: How do the key changes to the SIAC Rules compare with some of the other major arbitral institutions?


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.

About Eric Lai

Associate, CMS Holborn Asia
This entry was posted in Arbitration, Asean, Dispute Resolution, Hong Kong, ICC, London, SIAC, Singapore. Bookmark the permalink.

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