Comparison of International Arbitration Rules - Sixth Edition
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The International Arbitration Team at Hogan Lovells LLP continues the work started by colleagues at Simpson Thacher & Bartlett LLP in compiling the current Sixth Edition of Comparison of International Arbitration Rules of prevailing rules that guide international arbitration proceedings throughout major centers across the world. All of the international arbitration rules compared in this edition are current and up to date as of 2022. The publication is an invaluable resource for all lawyers as it provides the most up-to-date comparison of major institutional rules. Whether you are helping clients draft arbitration provisions for contracts; advising sovereign and quasi-sovereign entities preparing critical legislation; helping clients through arbitration proceedings; or researching the cornerstone of international arbitration, the knowledge contained in Comparison of International Arbitration Rules, Sixth Edition is your guide. This book allows you to spend less time searching and more time solving your client’s most pressing legal issues and problems.
This completely current Sixth Edition reflects all the amendments made to the rules following the COVID-19 pandemic, including the 2021 ICC Rules, the 2021 AAA/ICDR Rules, the 2020 LCIA Rules, and the 2022 ICSID Convention Arbitration and Conciliation Rules recently approved on July 1st.
COMPARISON OF INTERNATIONAL ARBITRATION RULES OF
ICC, AAA/ICDR, LCIA, SCC, ICSID, UNCITRAL, AND CPR
- A CHART OF PARALLEL PROVISIONS -
ARBITRATION CLAUSE
Model Clause
Effect of Arbitration Clause/Application of Rules
COMMENCEMENT OF ARBITRATION
Notice or Request for Arbitration
Answer and Counterclaims/Reply
Registration Fee/Advance on Costs
Joinder of Parties
Consolidation
CONSTITUTION OF THE ARBITRAL TRIBUNAL
Number of Arbitrators
Nationality/Qualifications of Arbitrators
Disclosure by Arbitrators
Appointment of Arbitrators
Challenge of Arbitrators
Replacement of Arbitrators
Truncated Tribunals
Compensation of Arbitrators
Communications Between Parties and Arbitrators
Liability of Arbitrators/Arbitral Institutions
GENERAL CONDITIONS
Notices and Communications/Calculation of Periods of Time
Place of Arbitration
Language/Translations
Representation and Assistance
Confidentiality/Privacy
PRELIMINARY MATTERS
Jurisdictional Issues
Applicable Substantive Law
Punitive Damages
ARBITRAL PROCEEDINGS
Transmission of File to Arbitrators
Conduct of Proceedings Generally/Applicable Procedural Law
Procedural Rulings
Expedited Proceedings
Terms of Reference/Procedural Timetable/Pre-Hearing Conference
Statement of Claim
Statement of Defense/Counterclaims/Reply
Amendments to Claims/Defenses
Further Written Statements
Time Limits
Disclosure/Discovery
Hearings
Evidence
Witnesses
Experts
Interim Measures
Emergency Arbitral Interim Measures
Default
Waiver of Rules
Closure of Hearings or Proceedings
ARBITRAL DECISIONS/AWARDS
Time Limits for Award
Quorum/Dissents
Place, Form, Notification and Effect of Award
Currency of Award/Interest
Determination and Allocation of Arbitration Costs
Correction, Interpretation or Supplementation of Award
Settlement/Other Termination
Recourse Against Award
APPENDIX
International Chamber of Commerce (“ICC”) Arbitration Rules
London Court of International Arbitration (“LCIA”) Arbitration Rules
Stockholm Chamber of Commerce (“SCC”) Arbitration Rules
International Centre for the Settlement of Investment Disputes (“ICSID”) Arbitration Rules
United Nations Commission on International Trade Law (“UNCITRAL”) Arbitration Rules
Hogan Lovells LLP is led by the 170-plus member market-leading international arbitration team at Hogan Lovells can strategically steer the most important dispute regardless of size, complexity, or seat. They handle all aspects, as well as the before and after — from pre-arbitration litigation to post-award proceedings to appeals before the highest courts around the world. Hogan lawyers have held high-level positions on arbitration boards worldwide – the ICC Task Force on the Revision of Rules of Arbitration; the ICDR Panel (chairmanship), which drafted the International Expedited Procedures; and the UNCITRAL Working Group of Commercial Arbitration and Conciliation.
This resource would not have been possible without the efforts of our cross-office team, led by Oliver Armas (Partner, New York), Richard Lorenzo (Partner, Miami), Kieron O’Callaghan, and Nathan Searle (Partners, London). Other valued members of the team that worked on this publication include Melissa Ordonez (Counsel, Paris), Orlando Cabrera (Senior Associate, Mexico City), Scott Macpherson (Senior Associate, London), Gulshan Gill (Associate, London), Irina Goga (Associate, New York), Charlie Howell (Associate, London), Jack Shaked (Associate, New York), Lédéa Sawadogo-Lewis (Business Lawyer, Paris), and Katie Dunn (Solicitor Trainee, London).
EDITORS
Oliver J. Armas is a Partner in Hogan Lovells’ New York office and the Global Head of the International Arbitration practice. Ollie has handled arbitrations under the rules of many of the major arbitral institutions around the world, including the ICC, AAA/ICDR, LCIA, ICSID, HKIAC, SIAC, DIAC, and DIFC, among others. He is also a highly sought-after arbitrator. Fluent in Spanish, and with an understanding of Portuguese, Ollie routinely counsels clients on matters involving Latin America. Ollie has also served as part of the faculty of the Columbia Law School – Chartered Institute of Arbitrators Comprehensive Course on International Arbitration, as well as being a guest lecturer at Harvard Law School, NYU School of Law, and The University of Pennsylvania Law School.
Nathan Searle is a Partner in Hogan Lovells’ London office. Nathan has extensive experience in African related disputes and coordinates the firm’s dispute practice in the region. Nathan also has experience in other emerging markets including Asia, India, Russia, and the CIS. Nathan is appointed to the LCIA African Users Council as councilor, a co-chair of the LCIA’s Young International Arbitration Group (YIAG) and is a member of the Advisory Board for the Association of Young Arbitrators (AYA).
CONTRIBUTORS
Orlando Federico Cabrera Colorado is a Senior Associate in Hogan Lovells’ Mexico City and Miami offices. He leverages his knowledge of common and civil law jurisdictions, and his fluency in English, Spanish, Portuguese, and French to counsel international arbitration clients seamlessly across borders and languages. Having studied law in Canada, Mexico, and the United States, Orlando draws on his deep understanding of complex domestic and international disputes to effectively represent clients in ICSID, ICC, LCIA, and UNCITRAL arbitrations throughout Latin America, North America, and Europe. With more than ten years of experience, Orlando, a listed arbitrator by the Arbitration Center of the Lima Chamber of Commerce and the International Center for Conciliation and Arbitration, advises governments and corporate investors on dispute resolution and political risk management. Approaching each matter with profound intellectual curiosity, Orlando, an associate to the Madrid Court of Arbitration, represents clients in mining, energy, telecommunications, finance, construction, transport, national security, real estate assets, and government contracting. Orlando, a Fellow of the Chartered Institute of Arbitrators (CIArb) and Board Secretary of CIArb’s North American Branch, frequently writes, speaks, and organizes events on international arbitration. He currently serves as a Young ICCA Events Coordinator.
Katie Dunn is a fourth seat Trainee Solicitor in Hogan Lovells’ London office.
Gulshan Gill is an Associate in Hogan Lovells’ London office. Gulshan represents international clients in arbitrations and litigations. Gulshan’s experience includes helping clients navigate disputes across a range of industry sectors. He has also acted for clients in LCIA, ICC and ICSID arbitrations.
Irina Goga is an Associate in Hogan Lovells’ New York office. Irina focuses her practice on litigation and international arbitration. She has experience in commercial arbitration in the consumer and technology sectors and has handled matters ranging from contractual disputes to corporate governance. Irina graduated from New York University School of Law where she served as the Symposium Editor for the NYU Journal of International Law and Politics, organized events for the International Arbitration Association, and participated in the NYU Law in Paris program. She also worked on civil rights issues, such as prison reform and discrimination, alongside organizations such as the New York Civil Liberties Union and the Sikh Coalition.
Charlie Howell is an Associate in Hogan Lovells’ London office.
Scott Macpherson is a Senior Associate in Hogan Lovells’ London office. Scott focuses on public international law, and in particular, dispute settlement under investment treaties. Scott acts for States, international organizations, and businesses in international disputes, primarily international arbitrations under the ICSID, SCC, UNCITRAL, LCIA, and ICC rules in addition to ad-hoc arbitrations and arbitration related litigation before the English courts. Scott regularly delivers trainings and lectures on international investment law and dispute settlement.
Melissa Ordonez is a Counsel in Hogan Lovells’ Paris office. Melissa focuses her practice on commercial and investment treaty arbitration. She is French/Colombian and has lived in several countries including Sweden, the Netherlands and the UK. Thanks to her unique multicultural background, Melissa works on complex arbitrations involving various regions of the world. She is known for her strategic skills and brings extensive experience of arbitration under the rules of the ICC, LCIA, ICSID and UNCITRAL, acting for companies from diverse industries as well as on behalf of States. Melissa is also a member of the firm's Latin American practice with substantial experience in international arbitration in the region.
Ledea Sawadogo-Lewis is a Business Lawyer in the Hogan Lovells’ Paris office.
Jack Shaked is an Associate in the Hogan Lovells’ New York office. Jack’s work on four continents has given him experience in cross-cultural collaboration and his experience in North America, Europe, Asia, and Africa allows him to seek the best possible outcomes for clients. In law school, Jack worked as a student attorney for the International Refugee Assistance Project and participated in three separate legal clinics. While working at the Department of Defense Office of General Counsel, he split his focus between investigations and issues at the intersection of cybersecurity and international law. Working with Transparency International in Paris, Jack authored a report on how to best structure future anti-corruption sanction regimes to survive legal challenges.
“The updated Comparison of International Arbitration Rules is an extremely useful tool for arbitrators and practitioners: easy-to-use, comprehensive, and well organized. The authors have made a tremendous contribution to the practice of arbitration with this reference guide.” -Meg Kinnear, Secretary-General of the International Centre for Settlement of Investment Disputes (ICSID)
“This updated Comparison book is a practical guide that once again provides an interesting and useful contribution to the arbitration library, which users of arbitration will be happy to turn to for quick and easy reference.” -Jacomijn van Haersolte-van Hof, Director General of the London Court of International Arbitration (LCIA)
“This edition is a rich user-friendly reference that offers a truly practical guide and a very resourceful compass for clients, practitioners, scholars and all those who wish to navigate through the intricacies of the prevailing rules that guide arbitration proceedings.” -Mohamed S. Abdel Wahab, Professor of Private International Law and International Arbitration - Cairo University and Founding Partner and Head of International Arbitration - Zulficar & Partners Law Firm (Egypt)
Hogan Lovells LLP is led by the 170-plus member market-leading international arbitration team at Hogan Lovells can strategically steer the most important dispute regardless of size, complexity, or seat. They handle all aspects, as well as the before and after — from pre-arbitration litigation to post-award proceedings to appeals before the highest courts around the world. Hogan lawyers have held high-level positions on arbitration boards worldwide – the ICC Task Force on the Revision of Rules of Arbitration; the ICDR Panel (chairmanship), which drafted the International Expedited Procedures; and the UNCITRAL Working Group of Commercial Arbitration and Conciliation.
This resource would not have been possible without the efforts of our cross-office team, led by Oliver Armas (Partner, New York), Richard Lorenzo (Partner, Miami), Kieron O’Callaghan, and Nathan Searle (Partners, London). Other valued members of the team that worked on this publication include Melissa Ordonez (Counsel, Paris), Orlando Cabrera (Senior Associate, Mexico City), Scott Macpherson (Senior Associate, London), Gulshan Gill (Associate, London), Irina Goga (Associate, New York), Charlie Howell (Associate, London), Jack Shaked (Associate, New York), Lédéa Sawadogo-Lewis (Business Lawyer, Paris), and Katie Dunn (Solicitor Trainee, London).
EDITORS
Oliver J. Armas is a Partner in Hogan Lovells’ New York office and the Global Head of the International Arbitration practice. Ollie has handled arbitrations under the rules of many of the major arbitral institutions around the world, including the ICC, AAA/ICDR, LCIA, ICSID, HKIAC, SIAC, DIAC, and DIFC, among others. He is also a highly sought-after arbitrator. Fluent in Spanish, and with an understanding of Portuguese, Ollie routinely counsels clients on matters involving Latin America. Ollie has also served as part of the faculty of the Columbia Law School – Chartered Institute of Arbitrators Comprehensive Course on International Arbitration, as well as being a guest lecturer at Harvard Law School, NYU School of Law, and The University of Pennsylvania Law School.
Nathan Searle is a Partner in Hogan Lovells’ London office. Nathan has extensive experience in African related disputes and coordinates the firm’s dispute practice in the region. Nathan also has experience in other emerging markets including Asia, India, Russia, and the CIS. Nathan is appointed to the LCIA African Users Council as councilor, a co-chair of the LCIA’s Young International Arbitration Group (YIAG) and is a member of the Advisory Board for the Association of Young Arbitrators (AYA).
CONTRIBUTORS
Orlando Federico Cabrera Colorado is a Senior Associate in Hogan Lovells’ Mexico City and Miami offices. He leverages his knowledge of common and civil law jurisdictions, and his fluency in English, Spanish, Portuguese, and French to counsel international arbitration clients seamlessly across borders and languages. Having studied law in Canada, Mexico, and the United States, Orlando draws on his deep understanding of complex domestic and international disputes to effectively represent clients in ICSID, ICC, LCIA, and UNCITRAL arbitrations throughout Latin America, North America, and Europe. With more than ten years of experience, Orlando, a listed arbitrator by the Arbitration Center of the Lima Chamber of Commerce and the International Center for Conciliation and Arbitration, advises governments and corporate investors on dispute resolution and political risk management. Approaching each matter with profound intellectual curiosity, Orlando, an associate to the Madrid Court of Arbitration, represents clients in mining, energy, telecommunications, finance, construction, transport, national security, real estate assets, and government contracting. Orlando, a Fellow of the Chartered Institute of Arbitrators (CIArb) and Board Secretary of CIArb’s North American Branch, frequently writes, speaks, and organizes events on international arbitration. He currently serves as a Young ICCA Events Coordinator.
Katie Dunn is a fourth seat Trainee Solicitor in Hogan Lovells’ London office.
Gulshan Gill is an Associate in Hogan Lovells’ London office. Gulshan represents international clients in arbitrations and litigations. Gulshan’s experience includes helping clients navigate disputes across a range of industry sectors. He has also acted for clients in LCIA, ICC and ICSID arbitrations.
Irina Goga is an Associate in Hogan Lovells’ New York office. Irina focuses her practice on litigation and international arbitration. She has experience in commercial arbitration in the consumer and technology sectors and has handled matters ranging from contractual disputes to corporate governance. Irina graduated from New York University School of Law where she served as the Symposium Editor for the NYU Journal of International Law and Politics, organized events for the International Arbitration Association, and participated in the NYU Law in Paris program. She also worked on civil rights issues, such as prison reform and discrimination, alongside organizations such as the New York Civil Liberties Union and the Sikh Coalition.
Charlie Howell is an Associate in Hogan Lovells’ London office.
Scott Macpherson is a Senior Associate in Hogan Lovells’ London office. Scott focuses on public international law, and in particular, dispute settlement under investment treaties. Scott acts for States, international organizations, and businesses in international disputes, primarily international arbitrations under the ICSID, SCC, UNCITRAL, LCIA, and ICC rules in addition to ad-hoc arbitrations and arbitration related litigation before the English courts. Scott regularly delivers trainings and lectures on international investment law and dispute settlement.
Melissa Ordonez is a Counsel in Hogan Lovells’ Paris office. Melissa focuses her practice on commercial and investment treaty arbitration. She is French/Colombian and has lived in several countries including Sweden, the Netherlands and the UK. Thanks to her unique multicultural background, Melissa works on complex arbitrations involving various regions of the world. She is known for her strategic skills and brings extensive experience of arbitration under the rules of the ICC, LCIA, ICSID and UNCITRAL, acting for companies from diverse industries as well as on behalf of States. Melissa is also a member of the firm's Latin American practice with substantial experience in international arbitration in the region.
Ledea Sawadogo-Lewis is a Business Lawyer in the Hogan Lovells’ Paris office.
Jack Shaked is an Associate in the Hogan Lovells’ New York office. Jack’s work on four continents has given him experience in cross-cultural collaboration and his experience in North America, Europe, Asia, and Africa allows him to seek the best possible outcomes for clients. In law school, Jack worked as a student attorney for the International Refugee Assistance Project and participated in three separate legal clinics. While working at the Department of Defense Office of General Counsel, he split his focus between investigations and issues at the intersection of cybersecurity and international law. Working with Transparency International in Paris, Jack authored a report on how to best structure future anti-corruption sanction regimes to survive legal challenges.
“The updated Comparison of International Arbitration Rules is an extremely useful tool for arbitrators and practitioners: easy-to-use, comprehensive, and well organized. The authors have made a tremendous contribution to the practice of arbitration with this reference guide.” -Meg Kinnear, Secretary-General of the International Centre for Settlement of Investment Disputes (ICSID)
“This updated Comparison book is a practical guide that once again provides an interesting and useful contribution to the arbitration library, which users of arbitration will be happy to turn to for quick and easy reference.” -Jacomijn van Haersolte-van Hof, Director General of the London Court of International Arbitration (LCIA)
“This edition is a rich user-friendly reference that offers a truly practical guide and a very resourceful compass for clients, practitioners, scholars and all those who wish to navigate through the intricacies of the prevailing rules that guide arbitration proceedings.” -Mohamed S. Abdel Wahab, Professor of Private International Law and International Arbitration - Cairo University and Founding Partner and Head of International Arbitration - Zulficar & Partners Law Firm (Egypt)
COMPARISON OF INTERNATIONAL ARBITRATION RULES OF
ICC, AAA/ICDR, LCIA, SCC, ICSID, UNCITRAL, AND CPR
- A CHART OF PARALLEL PROVISIONS -
ARBITRATION CLAUSE
Model Clause
Effect of Arbitration Clause/Application of Rules
COMMENCEMENT OF ARBITRATION
Notice or Request for Arbitration
Answer and Counterclaims/Reply
Registration Fee/Advance on Costs
Joinder of Parties
Consolidation
CONSTITUTION OF THE ARBITRAL TRIBUNAL
Number of Arbitrators
Nationality/Qualifications of Arbitrators
Disclosure by Arbitrators
Appointment of Arbitrators
Challenge of Arbitrators
Replacement of Arbitrators
Truncated Tribunals
Compensation of Arbitrators
Communications Between Parties and Arbitrators
Liability of Arbitrators/Arbitral Institutions
GENERAL CONDITIONS
Notices and Communications/Calculation of Periods of Time
Place of Arbitration
Language/Translations
Representation and Assistance
Confidentiality/Privacy
PRELIMINARY MATTERS
Jurisdictional Issues
Applicable Substantive Law
Punitive Damages
ARBITRAL PROCEEDINGS
Transmission of File to Arbitrators
Conduct of Proceedings Generally/Applicable Procedural Law
Procedural Rulings
Expedited Proceedings
Terms of Reference/Procedural Timetable/Pre-Hearing Conference
Statement of Claim
Statement of Defense/Counterclaims/Reply
Amendments to Claims/Defenses
Further Written Statements
Time Limits
Disclosure/Discovery
Hearings
Evidence
Witnesses
Experts
Interim Measures
Emergency Arbitral Interim Measures
Default
Waiver of Rules
Closure of Hearings or Proceedings
ARBITRAL DECISIONS/AWARDS
Time Limits for Award
Quorum/Dissents
Place, Form, Notification and Effect of Award
Currency of Award/Interest
Determination and Allocation of Arbitration Costs
Correction, Interpretation or Supplementation of Award
Settlement/Other Termination
Recourse Against Award
APPENDIX
International Chamber of Commerce (“ICC”) Arbitration Rules
London Court of International Arbitration (“LCIA”) Arbitration Rules
Stockholm Chamber of Commerce (“SCC”) Arbitration Rules
International Centre for the Settlement of Investment Disputes (“ICSID”) Arbitration Rules
United Nations Commission on International Trade Law (“UNCITRAL”) Arbitration Rules