# International Arbitration Institution Comparison

## Overview

This guide compares the five major international commercial arbitration institutions: ICC (International Chamber of Commerce), LCIA (London Court of International Arbitration), SIAC (Singapore International Arbitration Centre), HKIAC (Hong Kong International Arbitration Centre), and AAA-ICDR (American Arbitration Association - International Centre for Dispute Resolution).

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## 1. Institution Profiles

### ICC International Court of Arbitration

**Headquarters:** Paris, France
**Case Management Offices:** 12 worldwide (including Hong Kong, Singapore, New York, Sao Paulo)
**Founded:** 1923
**2024 Caseload:** ~900+ new cases
**Current Rules:** ICC Arbitration Rules 2021 (effective 1 January 2021)
**Website:** iccwbo.org

**Distinguishing Features:**
- Most established international institution
- Scrutiny of awards by ICC Court
- Terms of Reference requirement
- Global reach and recognition
- Appendix IV expedited procedure

### LCIA

**Headquarters:** London, United Kingdom
**Founded:** 1892
**2024 Caseload:** ~350+ referrals
**Current Rules:** LCIA Arbitration Rules 2020 (effective 1 October 2020)
**Website:** lcia.org

**Distinguishing Features:**
- Hourly rate fee structure (lower for large claims)
- Strong English law expertise
- Efficient appointment process
- Emergency arbitrator provisions
- Expedited formation of tribunal

### SIAC

**Headquarters:** Singapore
**Founded:** 1991
**2024 Caseload:** ~400+ cases
**Current Rules:** SIAC Rules 2016 (6th Edition), 2025 Rules forthcoming
**Website:** siac.org.sg

**Distinguishing Features:**
- Asia-Pacific focus
- Early dismissal procedure
- Expedited procedure
- Multiple arbitrator appointment mechanisms
- Arb-Med-Arb protocol

### HKIAC

**Headquarters:** Hong Kong SAR, China
**Founded:** 1985
**2024 Caseload:** ~500+ cases
**Current Rules:** HKIAC Administered Arbitration Rules 2024
**Website:** hkiac.org

**Distinguishing Features:**
- Gateway to Mainland China
- Competitive fee structure
- Early determination procedure
- Strong multilingual capability
- Arrangement with Mainland China courts

### AAA-ICDR

**Headquarters:** New York, United States
**Founded:** 1926 (AAA); ICDR established 1996
**2024 Caseload:** ~1,000+ international cases
**Current Rules:** ICDR International Arbitration Rules 2021
**Website:** adr.org/icdr

**Distinguishing Features:**
- North American focus
- Domestic and international capabilities
- Emergency measures of protection
- Document-only procedure option
- Extensive panel of arbitrators

---

## 2. Fee Comparison

### Administrative Fees

| Institution | Small Claim (USD 500K) | Medium Claim (USD 5M) | Large Claim (USD 50M) |
|-------------|----------------------|---------------------|---------------------|
| ICC | ~$24,000 | ~$55,000 | ~$115,000 |
| LCIA | ~$14,000 | ~$40,000 | ~$90,000 |
| SIAC | ~$12,000 | ~$35,000 | ~$75,000 |
| HKIAC | ~$15,000 | ~$38,000 | ~$85,000 |
| AAA-ICDR | ~$12,500 | ~$42,000 | ~$95,000 |

*Note: Approximate figures; check current fee schedules for accurate calculations*

### Arbitrator Fee Structures

**ICC:**
- Fixed by ICC Court based on amount in dispute
- Scaled rates: typically 0.5%-3% of amount in dispute
- Set ranges with Court discretion

**LCIA:**
- Hourly rates (currently GBP 500 maximum)
- No link to amount in dispute
- More predictable for large claims

**SIAC:**
- Schedule based on amount in dispute
- Or hourly rates (by agreement)
- Cap on arbitrator fees in expedited procedure

**HKIAC:**
- Schedule based on amount in dispute
- Hourly rates available
- Competitive with SIAC

**AAA-ICDR:**
- Compensation schedules based on claim amount
- Daily or hourly rates for hearings
- Flexibility in arrangements

### Sample Cost Comparison (USD 10M Dispute, 3 Arbitrators)

| Component | ICC | LCIA | SIAC | HKIAC |
|-----------|-----|------|------|-------|
| Registration | $5,000 | ~$2,000 | ~$2,000 | ~$2,000 |
| Admin Fees | ~$65,000 | ~$45,000 | ~$42,000 | ~$45,000 |
| Arbitrator Fees | ~$150,000-300,000 | ~$180,000 (hourly) | ~$120,000-200,000 | ~$120,000-200,000 |
| **Total Range** | **$220K-370K** | **$227K+** | **$164K-244K** | **$167K-247K** |

*Note: Excludes party legal costs, expert fees, hearing venue costs*

---

## 3. Procedural Rules Comparison

### Commencement

| Aspect | ICC | LCIA | SIAC | HKIAC | AAA-ICDR |
|--------|-----|------|------|-------|----------|
| Filing Document | Request for Arbitration | Request for Arbitration | Notice of Arbitration | Notice of Arbitration | Notice of Arbitration |
| Answer Deadline | 30 days | 28 days | 14 days | 30 days | 30 days |
| Advance on Costs | Required early | Required | Required | Required | Required |

### Tribunal Constitution

| Aspect | ICC | LCIA | SIAC | HKIAC | AAA-ICDR |
|--------|-----|------|------|-------|----------|
| Default No. of Arbitrators | 1 (or 3) | 1 (unless circumstances warrant 3) | 1 (unless parties agree or claim > $50M) | 1 (or 3 depending on circumstances) | 1 (unless circumstances warrant 3) |
| Appointment Authority | ICC Court | LCIA Court | President of Court of Arbitration | HKIAC Council | ICDR Administrator |
| Challenge Decision | ICC Court | LCIA Court | Court of Arbitration | HKIAC Council | ICDR Administrator |

### Key Procedural Features

| Feature | ICC | LCIA | SIAC | HKIAC | AAA-ICDR |
|---------|-----|------|------|-------|----------|
| Terms of Reference | Required | No | No | No | No |
| Scrutiny of Award | Yes (ICC Court) | No | No (unless requested) | No | No |
| Case Management Conference | Required | Encouraged | Required | Required | Required |
| Procedural Timetable | Within 2 months of TOR | Set by tribunal | Set by tribunal | Set by tribunal | Set by tribunal |

---

## 4. Emergency Arbitrator Procedures

### Availability

| Institution | Available | Pre-Rules Application | Opt-Out Allowed |
|-------------|-----------|----------------------|-----------------|
| ICC | Yes (since 2012) | No (unless agreed) | Yes |
| LCIA | Yes (since 2014) | No (unless agreed) | Yes |
| SIAC | Yes (since 2010) | Yes (by agreement) | Yes |
| HKIAC | Yes (since 2013) | No (unless agreed) | Yes |
| AAA-ICDR | Yes (since 2006) | No (unless agreed) | Yes |

### Emergency Arbitrator Timeline

| Stage | ICC | LCIA | SIAC | HKIAC | AAA-ICDR |
|-------|-----|------|------|-------|----------|
| Application | Before file constituted | Before tribunal constituted | Before tribunal constituted | Before tribunal constituted | Before tribunal constituted |
| Appointment | Within 2 days | Within 3 days | Within 1 day | Within 2 days | Within 1 day |
| Schedule | Within 2 days of appointment | As soon as possible | As soon as possible | Within 2 days | As soon as possible |
| Decision | Within 15 days | As soon as possible (no deadline) | Within 14 days | Within 14 days | As soon as possible |
| Form | Order | Order or Award | Order | Decision | Interim award |

### Emergency Arbitrator Fees

| Institution | Application Fee | EA Fees |
|-------------|-----------------|---------|
| ICC | USD 40,000 (advance) | Included |
| LCIA | GBP 30,000 (deposit) | Hourly rates |
| SIAC | SGD 50,000 (deposit) | Capped at SGD 30,000-60,000 |
| HKIAC | HKD 200,000 (deposit) | Up to HKD 200,000 |
| AAA-ICDR | USD 35,000 (deposit) | Set by Administrator |

---

## 5. Expedited Procedures

### Thresholds and Timelines

| Institution | Claim Threshold | Time to Award | Opt-Out |
|-------------|----------------|---------------|---------|
| ICC | USD 3 million (or agreement) | 6 months | No (automatic if threshold met) |
| LCIA | GBP 1 million (Expedited Formation) | No specific timeline | By agreement |
| SIAC | SGD 6 million (or agreement) | 6 months | Yes |
| HKIAC | HKD 25 million (or agreement) | 6 months | Yes |
| AAA-ICDR | Not specified | 60 days (document only) | N/A |

### Expedited Procedure Features

**ICC Appendix VI:**
- Single arbitrator (unless Court decides otherwise)
- No Terms of Reference
- Streamlined procedure
- Award in 6 months (extendable)

**SIAC Expedited Procedure:**
- Single arbitrator
- Limited document production
- Document-only or short hearing
- Award in 6 months

**HKIAC Expedited Procedure:**
- Single arbitrator presumption
- Shortened timelines
- Documents-only option
- 6-month award deadline

---

## 6. Joinder and Consolidation

### Joinder of Additional Parties

| Institution | ICC | LCIA | SIAC | HKIAC | AAA-ICDR |
|-------------|-----|------|------|-------|----------|
| Before Tribunal Constituted | Yes | Yes | Yes | Yes | Yes |
| After Tribunal Constituted | With consent or tribunal/institution approval | With tribunal/LCIA Court approval | With tribunal approval | With tribunal approval | With tribunal approval |
| Requires Same Agreement | No (but prima facie showing) | Generally yes | Generally yes | No (but prima facie showing) | Generally yes |

### Consolidation

| Institution | ICC | LCIA | SIAC | HKIAC | AAA-ICDR |
|-------------|-----|------|------|-------|----------|
| Authority | ICC Court | LCIA Court | Registrar/Court | HKIAC | ICDR |
| Same Agreement Required | Yes (or compatible) | Yes | Yes (or compatible) | Yes (or compatible) | Yes |
| Common Questions | Required | Required | Required | Required | Required |
| Party Consent | Not required | Not required | Not required | Not required | Not required |

---

## 7. Specialized Features

### Early Dismissal/Determination

| Institution | Available | Grounds |
|-------------|-----------|---------|
| ICC | No specific procedure | Tribunal has inherent power |
| LCIA | No specific procedure | Tribunal has inherent power |
| SIAC | Yes (Rule 29) | Manifestly without merit, manifestly outside jurisdiction |
| HKIAC | Yes (Article 43) | No legal merit, no reasonable prospect |
| AAA-ICDR | Limited | Under tribunal discretion |

### Third-Party Funding Disclosure

| Institution | ICC | LCIA | SIAC | HKIAC | AAA-ICDR |
|-------------|-----|------|------|-------|----------|
| Mandatory Disclosure | Yes (2021) | Tribunal discretion | Yes (2017) | Yes (2018) | Tribunal discretion |
| Timing | Promptly | When relevant | Promptly | Promptly | As directed |
| Content | Identity of funder | Identity of funder | Identity of funder | Identity and interest | As directed |

### Virtual/Remote Hearings

All institutions have embraced virtual hearings with:
- Express procedural provisions (post-2020)
- Technology guidance notes
- Cyber-protocols
- Hybrid hearing capability

---

## 8. Award Timeline and Scrutiny

### Time to Render Award

| Institution | Standard Deadline | Extensions |
|-------------|-------------------|------------|
| ICC | 6 months from TOR (9 for 3 arbitrators) | ICC Court approval |
| LCIA | No fixed deadline (tribunal decides) | N/A |
| SIAC | 45 days from close of hearing | Registrar approval |
| HKIAC | 3 months from close of hearing | HKIAC approval |
| AAA-ICDR | 60 days from close of hearing | Administrator approval |

### Award Scrutiny

| Institution | Scrutiny | By Whom | Effect |
|-------------|----------|---------|--------|
| ICC | Mandatory | ICC Court | May require modifications |
| LCIA | None | N/A | N/A |
| SIAC | Optional | Registrar | Minor corrections |
| HKIAC | None | N/A | N/A |
| AAA-ICDR | None | N/A | N/A |

**ICC Scrutiny Scope:**
- Form of award
- Potential errors (arithmetic, typographical)
- Enforceability concerns
- May draw attention to points of substance

---

## 9. Regional Considerations

### Asia-Pacific Disputes

**SIAC Advantages:**
- Singapore arbitration-friendly courts
- Model Law jurisdiction
- SICC for complex commercial disputes
- SIMC for mediation integration

**HKIAC Advantages:**
- Access to Mainland China
- Arrangement for Interim Measures
- Mainland-Hong Kong enforcement arrangements
- Bilingual Chinese-English capability

### European Disputes

**ICC Advantages:**
- Established in Europe
- Paris seat with experienced courts
- Civil law expertise
- Recognized globally

**LCIA Advantages:**
- London seat
- English law expertise
- Common law tradition
- Post-Brexit English arbitration law unchanged

### Americas Disputes

**AAA-ICDR Advantages:**
- US-based arbitrators
- Familiarity with US legal concepts
- Extensive domestic integration
- Pan-American reach

**ICC Advantages:**
- New York and Sao Paulo offices
- Neutral forum for cross-border
- Established Latin American practice

---

## 10. Recommended Institution by Scenario

| Scenario | Recommended | Rationale |
|----------|-------------|-----------|
| High-value complex disputes | ICC | Scrutiny, global recognition |
| Large claims, predictable costs | LCIA | Hourly fees, no ad valorem |
| Asia-Pacific focus | SIAC or HKIAC | Regional expertise, costs |
| China-related disputes | HKIAC | PRC arrangement, bilingual |
| US party involved | AAA-ICDR or ICC | Familiarity, enforcement |
| Urgent interim relief | SIAC | Fastest EA appointment |
| Construction disputes | ICC or SIAC | Complex multi-party |
| Investment disputes | ICC (or ICSID) | Experience, recognition |
| Maritime disputes | LCIA or SIAC | Specialized panels |
| IP disputes | ICC or SIAC | Arbitrability, expertise |

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## 11. Model Arbitration Clauses

### ICC Standard Clause
> "All disputes arising out of or in connection with the present contract shall be finally settled under the Rules of Arbitration of the International Chamber of Commerce by one or more arbitrators appointed in accordance with the said Rules."

### LCIA Standard Clause
> "Any dispute arising out of or in connection with this contract, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration under the LCIA Rules, which Rules are deemed to be incorporated by reference into this clause."

### SIAC Standard Clause
> "Any dispute arising out of or in connection with this contract, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre in accordance with the Arbitration Rules of the Singapore International Arbitration Centre for the time being in force, which rules are deemed to be incorporated by reference in this clause."

### HKIAC Standard Clause
> "Any dispute, controversy, difference or claim arising out of or relating to this contract, including the existence, validity, interpretation, performance, breach or termination thereof or any dispute regarding non-contractual obligations arising out of or relating to it shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre under the HKIAC Administered Arbitration Rules in force when the Notice of Arbitration is submitted."

### AAA-ICDR Standard Clause
> "Any controversy or claim arising out of or relating to this contract, or the breach thereof, shall be determined by arbitration administered by the International Centre for Dispute Resolution in accordance with its International Arbitration Rules."

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*Last Updated: March 2026*
*Sources: ICC Rules 2021, LCIA Rules 2020, SIAC Rules 2016, HKIAC Rules 2024, ICDR Rules 2021, Institution Websites*
*Disclaimer: Fee estimates are approximate. Consult current fee schedules and rules for accurate information.*