What Is A Chart Comparing International Commercial Arbitration Rules?

Navigating the complexities of international commercial arbitration can be daunting. A Chart Comparing International Commercial Arbitration Rules, like the one provided by compare.edu.vn, offers a streamlined way to understand the nuances between different sets of rules, assisting parties in making informed decisions. By comparing these rules, businesses can select the arbitration process that best suits their needs, leading to more efficient and cost-effective dispute resolution.

1. What Are International Commercial Arbitration Rules?

International commercial arbitration rules are a set of procedures and guidelines governing the arbitration process for resolving disputes arising from international commercial transactions. These rules provide a framework for the conduct of arbitration proceedings, including the appointment of arbitrators, the submission of evidence, and the rendering of awards. Standard arbitration rules help ensure fairness, efficiency, and enforceability in cross-border disputes.

• Standardization: Sets a clear, predefined process.
• Efficiency: Streamlines dispute resolution, saving time and money.
• Enforceability: Provides a framework recognized internationally.
• Impartiality: Ensures fairness through neutral arbitrator selection and process.

2. Why Is Comparing International Commercial Arbitration Rules Important?

Comparing international commercial arbitration rules is crucial because each set of rules has unique provisions that can significantly impact the arbitration process and outcome. By understanding the differences, parties can select the rules that best align with their specific needs and priorities. Evaluating international arbitration regulations allows businesses to make more informed decisions, potentially saving time, money, and resources while ensuring a fair and efficient resolution of disputes.

• Alignment with Needs: Ensures the rules match specific dispute resolution requirements.
• Cost Efficiency: Helps avoid unexpected costs by understanding fee structures and procedures.
• Fairness: Allows selection of rules that promote impartiality and procedural fairness.
• Strategic Advantage: Provides an opportunity to optimize the arbitration process for the best possible outcome.

3. What Are the Key Elements Compared in International Commercial Arbitration Rules?

When comparing international commercial arbitration rules, several key elements should be considered to ensure a comprehensive evaluation. These elements include:

• Initiation of Arbitration: Understanding how arbitration proceedings are started under different rules.
• Appointment of Arbitrators: Examining the procedures for selecting arbitrators, including default mechanisms.
• Default Deadlines for Response: Reviewing the timelines for responding to a notice of arbitration.
• Number of Arbitrators: Determining the default number of arbitrators and the process for deciding.
• Restrictions on Arbitrators’ Nationality: Assessing any limitations on the nationality of arbitrators.
• Time Limit for Challenging Arbitrators: Knowing the deadlines for challenging the appointment of an arbitrator.
• Rules on Joinder and Consolidation: Understanding the procedures for adding parties or combining arbitrations.
• Tribunal’s Power to Order Interim Measures: Examining the ability of the tribunal to order temporary relief.
• Confidentiality Provisions: Reviewing the rules regarding the confidentiality of the arbitration proceedings.
• Time Limit for Issuing Award: Determining the timelines for the tribunal to issue its final award.
• Availability of Expedited Procedures: Assessing the option for faster arbitration processes.
• Emergency Arbitrator Provisions: Checking the availability of an emergency arbitrator for urgent relief.
• Cost Allocation: Understanding how the costs of arbitration are allocated between the parties.
• Mediation Options: Exploring the availability and integration of mediation into the arbitration process.
• Languages Spoken at the Secretariat: Ensuring language support is available for the parties involved.
• Number of Cases Submitted: Evaluating the popularity and experience of the arbitration institution.
• Average Costs: Comparing the administrative and tribunal fees at different amounts in dispute.
• Office Locations: Assessing the accessibility and global presence of the arbitration institution.

4. What Is the Deemed Start of Arbitration Under Different Rules?

The deemed start of arbitration varies under different rules, marking the official commencement of the arbitration process. Understanding these differences is crucial for determining when certain deadlines and obligations begin to apply.

• ICC Rules 2021: Article 4.2 states the deemed start is the day the request is received by the ICC Secretariat.
• SIAC Rules 2025: Rule 6.2 specifies the date of receipt of the complete Notice of Arbitration by the Registrar.
• HKIAC Rules 2024: Article 4.2 indicates the day the Notice of Arbitration is received by HKIAC.
• VIAC Rules 2021: Article 7.1 sets the day the Statement of Claim is received by the Secretariat or by an Austrian Regional Economic Chamber.
• ICDR Rules 2021: Article 2.2 defines it as the day the Notice of Arbitration is received by the Administrator.
• SCC Rules 2017: Article 8 specifies the day the Request is received by the SCC.
• DIS Rules 2018: Article 6.1 states the day the Request is filed with DIS.
• LCIA Rules 2020: Articles 1.4, 4.4 define it as the date of receipt by the Registrar, whether delivered (hard copy) or transmitted (soft copy).
• Swiss Rules 2021: Article 3.2 specifies the day the Notice of Arbitration is received by the SCAI Secretariat.
• DIAC Rules 2022: Article 4.6 indicates the day the complete Request is received by DIAC.
• CPR Intn’l Administered Rules 2019: Rule 3.4 sets the date on which CPR receives notice of arbitration.
• ISTAC Rules 2017: Article 7.6 indicates the date on which the Request for Arbitration and registration fee are received.
• AIAC Rules 2021: Rule 7.5 defines it as the date on which the Notice of Arbitration is delivered to the respondent.
• JAMS Rules 2021: Article 2.4 (a) specifies the issuance of the Commencement Letter.
• KCAB Rules 2016: Article 8.2 states the day the Request for Arbitration is received by the KCAB Secretariat.
• SCCA Rules 2023: Article 5.4 defines it as the date on which the SCCA determines that the filing requirements have been satisfied and the registration fee has been paid.
• CAM-CCBC Rules 2022: Lacks an express rule; initiation is according to Articles 7.1 and 7.2.

5. What Are the Default Deadlines for Response Under Different Arbitration Rules?

The default deadlines for response are critical as they define the timeframe within which the respondent must reply to the notice of arbitration.

• ICC Rules 2021: Article 5.1 provides 30 days from receiving the request from the ICC Secretariat by the respondent.
• SIAC Rules 2025: Rule 7.1 gives 14 days from receipt of the notice of arbitration by the respondent.
• HKIAC Rules 2024: Article 5.1 allows 30 days from receipt of the Notice of Arbitration by the respondent.
• VIAC Rules 2021: Article 8.1 provides 30 days from receipt of the Statement of Claim.
• ICDR Rules 2021: Article 3.1 allows 30 days after the Administrator confirms receipt of the Notice of Arbitration.
• SCC Rules 2017: Article 9(1) allows a period set by the Secretariat.
• DIS Rules 2018: Article 7.2 gives 45 days from the transmission of the Request.
• LCIA Rules 2020: Article 2.1 provides 28 days from the start of arbitration.
• Swiss Rules 2021: Article 4.1 allows 30 days from receipt of the Notice of Arbitration.
• DIAC Rules 2022: Article 5.1 provides 30 days after the Request has been notified to the Respondent.
• CPR Intn’l Administered Rules 2019: Rule 3.5 allows 30 days after the Commencement Date.
• ISTAC Rules 2017: Article 8.1 provides 30 days after the notification of the Request for Arbitration.
• AIAC Rules 2021: Rule 6.1 allows 30 days after receipt of notice of arbitration.
• JAMS Rules 2021: Article 4.1 provides 30 days after commencement.
• KCAB Rules 2016: Article 9.1 allows 30 days from receipt of the Request for Arbitration by the respondent.
• SCCA Rules 2023: Article 6.1 provides 30 days from commencement of Arbitration, including any plea that the Arbitral Tribunal lacks jurisdiction.
• CAM-CCBC Rules 2022: Article 8.1 provides 15 days from receipt of the Notice of Arbitration.

6. What Is the Default Number of Arbitrators Under Various Rules?

The default number of arbitrators is a crucial aspect of arbitration, impacting both cost and complexity. Here’s how different rules handle this:

• ICC Rules 2021: Article 12.2 defaults to a sole arbitrator but may be three in complex cases.
• SIAC Rules 2025: Rule 19.1 specifies a sole arbitrator.
• HKIAC Rules 2024: Article 6.1 allows HKIAC to decide.
• VIAC Rules 2021: Article 17.2 allows the Board to decide.
• ICDR Rules 2021: Article 12 defaults to a sole arbitrator unless the Administrator decides three are appropriate.
• SCC Rules 2017: Article 16(2) allows the Board to decide.
• DIS Rules 2018: Article 10.2 defaults to three arbitrators unless a party requests a sole arbitrator and the DIS Arbitration Council grants the request.
• LCIA Rules 2020: Article 5.8 specifies a sole arbitrator.
• Swiss Rules 2021: Articles 9.1, 9.2 allow the SCAI Court to decide, generally preferring a sole arbitrator.
• DIAC Rules 2022: Article 10.2 defaults to a sole arbitrator unless the Arbitration Court finds that three arbitrators are appropriate.
• CPR Intn’l Administered Rules 2019: Rule 5.1.a generally specifies three arbitrators but only one if the amount in dispute does not exceed US$ 3 million and CPR does not decide otherwise based on the complexity of the case.
• ISTAC Rules 2017: Article 13.2 allows the Board to decide, considering all relevant circumstances.
• AIAC Rules 2021: Rule 9.3 specifies three arbitrators in international arbitration unless the Director determines otherwise.
• JAMS Rules 2021: Article 7.1 specifies one arbitrator unless JAMS determines otherwise due to the size, complexity, or other circumstances of the case.
• KCAB Rules 2016: Article 11 specifies a sole arbitrator.
• SCCA Rules 2023: Article 15 specifies one arbitrator unless the SCCA Court determines that three arbitrators are appropriate due to the size, complexity, or other circumstances of the case.
• CAM-CCBC Rules 2022: Lacks a default; Article 10.1 states that if the number of arbitrators was not defined, the CAM-CCBC Presidency shall decide if one or three arbitrators shall be appointed.

7. What Are the Default Appointment Procedures for a Sole Arbitrator?

The appointment of a sole arbitrator is a critical step in many arbitrations. Here’s a comparison of the default procedures under different rules:

• ICC Rules 2021: Article 12.3 specifies appointment by the ICC Court if parties fail to agree on an arbitrator within 30 days from the day the respondent received the Request for Arbitration.
• SIAC Rules 2025: Rule 21 requires joint appointment within 21 days from receipt of the request by the Registrar, otherwise by the President of SIAC.
• HKIAC Rules 2024: Articles 7.1, 7.2 require joint appointment within 30 days from service of the Notice of Arbitration or 15 days from HKIAC’s decision, otherwise by HKIAC.
• VIAC Rules 2021: Article 17.3 specifies appointment by the Board if parties fail to agree on an arbitrator within 30 days after receiving the Secretary General’s request.
• ICDR Rules 2021: Article 13.3 states at the written request of any party by the Administrator if parties fail to agree on an arbitrator within 45 days after the Administrator received the Notice of Arbitration; the Administrator may use the ICDR list method in Article 13.6.
• SCC Rules 2017: Article 17(3) requires joint appointment within 10 days, otherwise by the SCC Board.
• DIS Rules 2018: Articles 11, 13.2 require joint appointment within a time limit fixed by DIS, otherwise by the DIS Appointing Committee.
• LCIA Rules 2020: Article 5.6 specifies appointment by LCIA after receipt of the Response or, if no Response, 28 days from the start of arbitration.
• Swiss Rules 2021: Article 10 requires joint appointment within 30 days after the Respondent received the Notice of Arbitration if parties have agreed on a sole arbitrator; if parties receive SCAI Court’s decision to refer the dispute to a sole arbitrator if parties have not agreed upon the number of arbitrators, otherwise by the SCAI Court.
• DIAC Rules 2022: Articles 12.3 specify appointment by the Arbitration Court if parties fail to jointly nominate an arbitrator; an alternative appointment procedure is available in Art. 13.
• CPR Intn’l Administered Rules 2019: Rule 5.3 specifies appointment by CPR through the CPR List Procedure if parties fail to agree on an arbitrator within 30 days after the deadline for notice of defense.
• ISTAC Rules 2017: Article 14 specifies appointment by the Board if parties fail to agree on an arbitrator within 30 days from the notification of the claimant’s Request for Arbitration.
• AIAC Rules 2021: Rule 9.4 specifies appointment by the Director upon the request of any party if parties fail to agree on an arbitrator within 30 days of the respondent’s receipt of the notice of arbitration; a “list procedure” is available in Art. 9.8.
• JAMS Rules 2021: Articles 7.3 and 7.5 specify joint appointment by the parties; otherwise by JAMS through a method including a list of candidates and considering the parties’ responses.
• KCAB Rules 2016: Article 12.1 requires joint appointment within 30 days of the receipt of the Request of Arbitration by the respondent.
• SCCA Rules 2023: Article 16.5 states the SCCA Court if the parties fail to make a joint nomination within 30 days of the commencement of the arbitration.
• CAM-CCBC Rules 2022: Article 13.1 specifies appointment by agreement of the parties; after 15 days, appointed by the CAM-CCBC Presidency if the parties could not agree.

8. How Do the Rules Differ on the Default Appointment of a Three-Member Tribunal?

When a three-member tribunal is required, the appointment process varies significantly across different arbitration rules. This can impact the speed and fairness of the proceedings.

• ICC Rules 2021: Articles 12.4, 12.5 specify that each party nominates an arbitrator; the chair is appointed by the ICC Court.
• SIAC Rules 2025: Rule 22 specifies that each party nominates an arbitrator; if within 14 days of the first nomination a party fails to nominate its arbitrator, the President of SIAC will appoint on its behalf; the chair is appointed by the President of SIAC.
• HKIAC Rules 2024: Article 8.1 specifies that the claimant nominates its arbitrator in the Notice of Arbitration or within 15 days from HKIAC’s decision, and the respondent nominates in the Answer to the Notice of Arbitration or within 15 days after the Claimant’s nomination pursuant to HKIAC’s decision, otherwise by HKIAC.
• VIAC Rules 2021: Article 17.4 specifies that each party nominates an arbitrator; if a party fails to do so within 30 days after receiving the Secretary General’s request, the Board appoints the arbitrator.
• ICDR Rules 2021: Art. 13.3 defers to the default appointment of a sole arbitrator.
• SCC Rules 2017: Article 17(4) specifies that parties appoint an equal number of arbitrators, the chair is appointed by the SCC Board; if a party fails to appoint arbitrator(s) within the stipulated time, the SCC Board appoints arbitrator(s).
• DIS Rules 2018: Articles 12, 13.2 specify that each party nominates an arbitrator; the chair is jointly nominated by co-arbitrators, otherwise selected and appointed by the DIS Appointing Committee.
• LCIA Rules 2020: Article 5.6, 5.8 specifies appointment by LCIA after receipt of the Response or, if no Response, 28 days from the start of arbitration.
• Swiss Rules 2021: Articles 11.1, 11.2 specify that each party designates an arbitrator within the time limit set by the SCAI Court; the chair is jointly designated by the arbitrators within 30 days from the confirmation of the second arbitrator, otherwise arbitrators appointed by SCAI Court.
• DIAC Rules 2022: Article 12.4 specifies that each party nominates one arbitrator; the chair is jointly nominated by co-arbitrators within 10 days after appointment of the second arbitrator, otherwise appointed by the Arbitration Court; an alternative appointment procedure is available in Art. 13.
• CPR Intn’l Administered Rules 2019: Rules 5.1.c, 5.4, 6.1 use a Screened Selection Procedure: both parties each designate one arbitrator without arbitrators knowing which party nominated them; the chair is appointed by CPR; if parties or arbitrators have failed to designate arbitrator, CPR designates the arbitrator.
• ISTAC Rules 2017: Article 14.2, 14.3 specifies that each party nominates one arbitrator and co-arbitrators appoint the chair; if parties or arbitrators fail to do so, the Board appoints the arbitrator.
• AIAC Rules 2021: Rule 9.5 specifies that each party appoints one arbitrator; party-appointed arbitrators choose the chair; if parties/arbitrators fail to appoint the arbitrator, the Director appoints the arbitrator; a “list procedure” is available in Art. 9.8.
• JAMS Rules 2021: Articles 7.4 and 7.5 specify that each party nominates one arbitrator and co-arbitrators appoint the chair; if parties or arbitrators fail to do so, JAMS appoints co-arbitrator and uses a method with a list of candidates for the chair (Art. 7(5)).
• KCAB Rules 2016: Article 12.2 specifies that the claimant nominates one arbitrator in the Request for Arbitration or within such additional period of time fixed by the Secretariat; the respondent nominates one arbitrator in the Answer to the Request for Arbitration or within such additional period of time fixed by the Secretariat.
• SCCA Rules 2023: Article 16.6, 16.10 specifies that each party nominates an arbitrator within 30 days after the commencement of the arbitration, and the presiding arbitrator shall be appointed by the SCCA Court. The SCCA Court may use a list procedure.
• CAM-CCBC Rules 2022: Article 11.1 specifies that both parties each nominate one arbitrator within 15 days after receipt of rules; Article 11.5 specifies that co-arbitrators subsequently appoint the chair; Article 11.8 specifies that if parties/ co-arbitrators fail to appoint the arbitrator, the appointment shall be made by the CAM-CCBC Presidency.

9. How Do Arbitration Rules Handle Restrictions on Arbitrators When Parties Have Different Nationalities?

Restrictions on arbitrators based on the nationalities of the parties are designed to ensure impartiality. Here’s a comparison of how different rules address this issue:

• ICC Rules 2021: Articles 13.5, 13.6 specify that a sole arbitrator/chair should not be of the nationality of any party; if investment arbitration is based on a treaty, no arbitrator should be of the nationality of any party.
• SIAC Rules 2025: Rule 19.7 states that unless parties agree otherwise, if parties are of different nationalities, the President appoints a sole arbitrator of different nationality to the parties.
• HKIAC Rules 2024: Articles 11.2, 11.3 specify that a sole arbitrator/chair should not be of the nationality of any party unless otherwise agreed by all parties or in appropriate circumstances with no objections within a time limit set by HKIAC.
• VIAC Rules 2021: None specified.
• ICDR Rules 2021: Article 13.4 states that at the request of any party or on its own initiative, the Administrator may appoint nationals of a country other than that of any of the parties.
• SCC Rules 2017: Article 17(6) specifies that a sole arbitrator/chair should not be of the nationality of any party.
• DIS Rules 2018: Articles 11, 12.3 specify that a sole arbitrator /chair should not be of the nationality of any party if appointed by the DIS Appointing Committee, unless all parties are of the same nationality or otherwise agreed by the parties.
• LCIA Rules 2020: Article 6.1 specifies that a sole arbitrator/chair should not be of the nationality of any party.
• Swiss Rules 2021: None specified.
• DIAC Rules 2022: Article 11.1 specifies that a sole arbitrator/chair should not be of the nationality of any party unless parties who are not of the same nationality as the proposed arbitrator agree, or the Arbitration Court decides.
• CPR Intn’l Administered Rules 2019: Rule 6.2.b states that upon the request of any party, arbitrators shall be of nationality other than that of the parties.
• ISTAC Rules 2017: None specified.
• AIAC Rules 2021: Rule 10.5 specifies that a sole arbitrator/chair should not be of the nationality of any party, unless otherwise agreed by parties or determined by the Director.
• JAMS Rules 2021: None specified.
• KCAB Rules 2016: Article 12.4 states that upon either party’s request, the Secretariat appoints a sole arbitrator/chair whose nationality is different from the nationalities of the parties.
• SCCA Rules 2023: None specified.
• CAM-CCBC Rules 2022: Article 11.9 states that upon either party’s request, the CAM-CCBC Presidency shall decide about “the need and convenience” to appoint a president of the arbitral tribunal with a nationality different than that of both parties’ case by case.

10. What Is the Time Limit for Challenging an Arbitrator Under Different Rules?

The time limit for challenging an arbitrator is a critical procedural aspect that ensures fairness and impartiality in arbitration proceedings.

• ICC Rules 2021: Article 14.2 specifies 30 days from appointment/confirmation or 30 days from becoming aware of relevant circumstances.
• SIAC Rules 2025: Rule 27.1 allows 15 days of notice of appointment or 15 days from becoming aware of circumstances for challenge.
• HKIAC Rules 2024: Article 11.7 provides 15 days from appointment or 15 days from becoming aware of relevant circumstances.
• VIAC Rules 2021: Article 20.2 allows 15 days from becoming aware of relevant circumstances.
• ICDR Rules 2021: Article 15.1 specifies 15 days from notification of appointment or 15 days from becoming aware of relevant circumstances.
• SCC Rules 2017: Article 19(3) allows 15 days from becoming aware of relevant circumstances.
• DIS Rules 2018: Article 15.2 provides 14 days from becoming aware of relevant circumstances.
• LCIA Rules 2020: Article 10.3 allows 14 days from appointment or, if later, 14 days from becoming aware of relevant circumstances.
• Swiss Rules 2021: Article 13.2 allows 15 days from becoming aware of relevant circumstances.
• DIAC Rules 2022: Article 15.2 provides 15 days from receipt of notification of appointment or 15 days from becoming aware of relevant circumstances.
• CPR Intn’l Administered Rules 2019: Rule 7.6 allows 15 days after receipt of notification of the appointment or becoming aware of relevant circumstances.
• ISTAC Rules 2017: Article 16.2 provides 30 days after notification of choice or appointment of the arbitrator or after relevant circumstances became known.
• AIAC Rules 2021: Rule 11.2 allows 15 days after becoming aware of relevant circumstances.
• JAMS Rules 2021: Article 9.1 allows Within 15 days from notification of appointment or within 15 days of becoming aware of relevant circumstances.
• KCAB Rules 2016: Article 14.3 provides Within 15 days from (1) the date of receipt of the confirmation of the nomination/appointment of the arbitrator or (2) the date on which the party making the challenge becomes aware of the facts and circumstances giving rise to such challenge.
• SCCA Rules 2023: Article 18.3, 14 days after the appointment of the challenged arbitrator or after the circumstances giving grounds for the challenge became known to the party.
• CAM-CCBC Rules 2022: Article 14.1 specifies that a challenge is possible within 10 days after becoming aware of a relevant fact with regards to independence, impartiality or another justifiable cause.

11. How Do Different Rules Handle Joinder of Additional Parties?

The rules governing joinder, or the addition of new parties to an ongoing arbitration, can significantly impact the scope and efficiency of the proceedings.

• ICC Rules 2021: Articles 7.1, 7.5 specify that on request by a party prior to confirmation/appointment of any arbitrator, unless otherwise agreed; requests after confirmation/appointment are subject to the additional party’s acceptance of the tribunal and Terms of Reference and are decided by the tribunal.
• SIAC Rules 2025: Rule 18 allows on application by a party or third-party either before or after formation of tribunal if the third party is prima facie a party to the arbitration agreement or all parties consent.
• HKIAC Rules 2024: Article 27.1 allows on request by a party or third-party before or after the constitution of the tribunal if the joining party is prima facie bound by an arbitration agreement under the Rules or all parties, including the joining party, consent to joinder.
• VIAC Rules 2021: Article 14 allows on request by a party or third-party before or after the constitution of the tribunal.
• ICDR Rules 2021: Article 8 allows on request by a party prior to the appointment of an arbitrator, unless otherwise agreed, or the arbitral tribunal once constituted determines that joinder is appropriate, and the additional party consents to such joinder.
• SCC Rules 2017: Articles 13(1), 13(2) allow on request by a party and only permitted prior to the submission of the Answer, unless the SCC Board decides otherwise.
• DIS Rules 2018: Article 19.1 allows on request by a party and only permitted prior to the appointment of any arbitrator.
• LCIA Rules 2020: Article 22.1(x) allows only on application by a party and consent of applicant and new party required.
• Swiss Rules 2021: Article 6 allows on request by a party or non-party before or after the constitution of the tribunal; application before constitution requires a preliminary decision of the Court.
• DIAC Rules 2022: Article 9 allows a request by a party or non-party; requires consent of all parties or that the joining party is party to the arbitration agreement referred to in the Request.
• CPR Intn’l Administered Rules 2019: Rule 3.12 allows prior to the appointment of any arbitrator upon the request of any party unless CPR finds otherwise.
• ISTAC Rules 2017: No rules available.
• AIAC Rules 2021: Rule 21.1 allows on request of any party to the arbitration or any third party (after the filing of the statement of defence only in exceptional circumstances) if either all parties agree or the third party is prima facie bound by the arbitration agreement or it is necessary for the efficient resolution of the dispute and directly affects the outcome of the proceedings.
• JAMS Rules 2021: Article 6.3 allows on application by any party (including potential third party); Tribunal will decide on such request, after consulting with all parties, taking into account all circumstances it deems relevant and applicable.
• KCAB Rules 2016: Article 21.1 allows on application by a party and (1) an agreement in writing to the joinder between the applicant and the joining third-party or (2) the joining third-party being a part of the same arbitration agreement and agreeing to join the arbitration proceedings.
• SCCA Rules 2023: Article 12, on request by a party prior to the appointment of any arbitrator; requests after appointment are subject to all parties’ agreement and additional party’s acceptance of the tribunal, or agreement of the additional party, additional party’s acceptance of the tribunal and subject to the tribunal’s decision.
• CAM-CCBC Rules 2022: Article 18 By request of the party who wishes to include an additional party (18.1); decided by the CAM-CCBC Presidency before the constitution of the arbitral tribunal (18.2); after the constitution of the arbitral tribunal by the arbitral tribunal itself (18.4); by submission to the CAM-CCBC Presidency by a party that voluntarily whishes to be included (18.5).

12. How Do the Rules Compare on Consolidation of Arbitrations?

Consolidation, the process of combining multiple arbitrations into a single proceeding, can enhance efficiency and consistency in resolving related disputes.

• ICC Rules 2021: Article 10 states that on request by a party, the ICC Court can consolidate pending ICC arbitrations under ICC Rules where the parties agree, all claims are made under the same arbitration agreement(s), or the same parties, in connection with the same legal relationship, and ICC finds arbitration agreements compatible.
• SIAC Rules 2025: Rule 16 states that on request by a party, the SIAC Court or tribunal can consolidate where the parties agree, claims are under the same arbitration agreement, or arbitration agreements are compatible and disputes arise out of the same legal relationship, principal and ancillary contract, or same transaction or series of transactions.
• HKIAC Rules 2024: Article 28.1 states that on request by a party, HKIAC can consolidate where (a) the parties agree, or (b) claims are made under the same arbitration agreement, or (c) claims are made under more than one arbitration agreement, common question of law/fact in all arbitrations, the right to relief is in respect of or arise out of the same transaction or a series of related transactions, and the arbitration agreements are compatible.
• VIAC Rules 2021: Article 15 states that on request by a party, the Board can consolidate proceedings where all parties agree or the same arbitrator(s) was/were appointed and the place of arbitration in all of the arbitration agreements is the same.
• ICDR Rules 2021: Article 9 states that on request by a party or on its own initiative, the Administrator may appoint a consolidation arbitrator. The consolidation arbitrator may consolidate proceedings where applicable rules are administered by AAA or ICDR, and all parties expressly agreed to appoint consolidation arbitrator, all claims are made under the same arbitration agreement, or the same or related parties, disputes in connection with the same legal relationship and arbitration agreements may be compatible.
• SCC Rules 2017: Article 15(1) states that on request by a party, the SCC Board can consolidate a newly commenced SCC arbitration with a pending arbitration where the parties agree, all claims are made under the same arbitration agreement, or the relief sought arises out of the same transaction/series of transactions, and the SCC Board finds arbitration agreements compatible.
• DIS Rules 2018: Article 8.1 states that on request by a party and only if all parties agree.
• LCIA Rules 2020: Article 22A (22.7, 22.8) states that By order of the tribunal upon application by any party and subject to approval by LCIA where: all parties consent, or LCIA arbitrations commenced under same/compatible arbitration agreement between same parties; and no tribunal appointed or composed of same arbitrators
• Swiss Rules 2021: Article 7 states that the SCAI Court can consolidate pending arbitrations under Swiss Rules and will take into account all relevant circumstances, including links between the cases and the progress made in the proceedings.
• DIAC Rules 2022: Article 8.2 states that upon request by any party prior to the appointment of an arbitrator if all claims are made under the same arbitration agreement, or the same parties, compatibility of arbitration agreements, and disputes arise out of the same legal relationship or underlying contracts consist of principal and ancillary contracts or claims arise out of related transactions.
• CPR Intn’l Administered Rules 2019: Rule 3.13 states that upon request of any party and after consultation with the parties where parties have agreed to consolidation, or all claims are made under the same arbitration agreement, or claims are made under different arbitration agreements but between the same parties, the disputes arise in connection with the same legal relationship and CPR finds arbitration agreements compatible.
• ISTAC Rules 2017: Article 11.1 states that upon request of any party where two or more arbitrations are pending under the ISTAC Rules and where