SIAC
The Singapore International Arbitration Centre ("SIAC") was established in 1991 and is one of the leading arbitral institutions in Asia. New SIAC arbitration rules (the “SIAC Rules”) came into effect as of 1 January 2025 and, unless otherwise agreed, apply to any arbitration commenced on or after that date. The SIAC Rules establish a Court of Arbitration (“Court”) which comprises a number of leading arbitration figures from around the world. The responsibilities of the Court include rendering decisions on challenges to arbitrators and certain jurisdictional challenges.
The SIAC Rules contain various procedures for accelerated proceedings. There is an expedited procedure which a party can request the application of in cases where the parties have agreed, the amount in dispute does not exceed S$10,000,000, or where the circumstances of the case warrant the application of the procedure. A “streamlined procedure” was introduced in 2025 for disputes valued at S$1,000,000 or less, albeit with leeway for the SIAC President to decide that it should not apply in any particular case, and parties can also choose to apply it by consent to any dispute.There is a 6-month and 3-month timeline from Tribunal constitution to award under the expedited and streamlined procedures respectively. (Parties can also, should they so wish, entirely exclude the operation of either, or both, of the expedited and streamlined procedures).
The SIAC Rules also include an emergency arbitrator procedure. An emergency arbitrator can generally be appointed within 1-3 days following the application for emergency arbitration (and payment of applicable fees). The President of the Court has responsibility for determining applications for expedited procedures and appointment of arbitrators and emergency arbitrators.
The SIAC Rules include measures on joinder, consolidation, and early dismissal of meritless claims or defences. Further provisions were introduced into the 2025 SIAC Rules to make SIAC arbitration even more efficient, such as preliminary determination of particular issues ahead of the final award, and a mechanism for “coordinated proceedings” allowing a Tribunal hearing multiple arbitrations which share common legal or factual issues, to conduct the arbitrations concurrently or sequentially, to align certain procedural aspects, or to suspend one arbitration pending determination of another.
While the SIAC Rules use terminology similar to that of the ICC International Court of Arbitration, the SIAC Court exercises a more limited review function compared to its ICC counterpart. The SIAC secretariat engages in a limited form of review of arbitral awards to ensure basic formalities are satisfied and calculations are correct.
The SIAC charges a filing fee, administrative fee and collects the fees for the arbitrators. These fees and costs are calculated by way of set sum combined with a percentage of the amount involved in the dispute and are generally lower than those administered by the ICC. The SIAC Website has a fee calculator which will provide an indication of the likely fees.
Under the SIAC Rules, the tribunal has a discretion whether to order discovery of documents. Our SIAC precedent clauses exclude the tribunal’s power to order general discovery (on the grounds that the saving in time and cost makes up for the few cases where general discovery might have changed the outcome). Consider whether this will be appropriate in your case before including these words.
In the three arbitrator SIAC clause, wording providing for the presiding arbitrator to be appointed by the two party appointed arbitrators is included otherwise the President of the SIAC Court will, under the SIAC Rules, do so. This amendment therefore provides for the more streamlined approach that appointment by the other two arbitrators brings.