Navigating the New Arbitration Landscape: Comparative Insights and Key Amendments

4 min 54 sec January 18, 2026 (Edited)

International arbitration is encountering a significant period of reform as leading institutions update their procedural frameworks to address the increasing complexity, urgency and cross-border nature of modern commercial disputes.

The most recent developments come from the Singapore International Arbitration Centre (“SIAC”), which has issued the SIAC Rules 2025, entering into force on 1 January 2025, and the Hong Kong International Arbitration Centre (“HKIAC”), whose 2024 HKIAC Administered Arbitration Rules took effect on 1 June 2024, introducing enhanced mechanisms for efficiency, emergency relief and multi-contract case management. In contrast, the International Chamber of Commerce (“ICC”) continues to administer cases under the ICC Rules of Arbitration 2021 and the London Court of International Arbitration (“LCIA”) operates under the LCIA Arbitration Rules 2020, both of which already incorporate significant reforms focused on procedural flexibility and tribunal autonomy.

In the UAE, DIAC revised its Rules in 2022 to complement the UAE Arbitration Law of 2018 and the newest regional set of Rules, Arbitrate AD’s 2024 Rules, has replaced the ADCCAC Rules from 2007. Collectively, these developments enhance legal certainty and efficiency for businesses operating across the UAE, the GCC and Asia-Pacific in the year ahead.

Across the board, all these arbitral rules share a common element – they now use digital technology to support their operations. The HKIAC Rules 2024 allow electronic communication and virtual hearings through Articles 3.1 and 13.1, while the SIAC Rules 2025 enable electronic filing submission and virtual proceedings through Rules 4, 32.5, and 39.2. The ICC Rules 2021 permit hearings to take place either in person or remotely under Article 26(1), and the LCIA Rules 2020 establish a fully digital system under Articles 4, 9.7 and 19.2. This approach is mirrored regionally, as the DIAC Arbitration Rules 2022 and the ArbitrateAD Arbitration Rules 2024 require written communications to be exchanged digitally. Collectively, these provisions reflect a broader recognition that the future of arbitration is adapting to the development of technology and digitalization.

Enhancing Procedural Efficiency

The latest amendments and revisions demonstrate that all institutions support both suitable regulatory actions and expedited court procedures. The Streamlined Procedure of SIAC under Rule 13/Schedule 2 enables parties to resolve disputes worth SGD 1 million or less through a three-month process which results in a tribunal award. The Expedited Procedure under Rule 14 and Preliminary Determination system under Rule 14 of SIAC enables tribunals to address essential matters at the commencing of proceedings.

The HKIAC follows its established pattern through Articles 42 and 43 of its 2024 Rules which establish an expedited procedure as they have raised the sum of dispute from HK$25 million to HK$50 million. The dispute resolution systems of SIAC and HKIAC share common features which enable them to handle fast-paced large-scale disputes.

The ICC enhances its operational efficiency through its new policy which extends the Expedited Procedure to cases worth up to USD 3 million. The LCIA maintains its ability to modify procedures through adaptable methods instead of requiring exact quantitative standards. Although the LCIA lacks an official expedited process, its Expedited Formation mechanism together with Article 14 efficiency requirements allow parties to obtain fast results through suitable circumstances.

Both DIAC and Arbitrate AD include expedited procedures based on value of disputes.

Emergency and Urgent Relief

The institutions focus on improving their non-urgent case management systems while they build up their emergency response mechanisms. The 2025 SIAC reforms create an enhanced emergency system under Rule 25, which enables parties to request emergency arbitrator assistance before filing their Notice of Arbitration and tribunals can issue protective preliminary orders through ex parte procedures within 24 hours.

The HKIAC operates an emergency arbitrator system which follows UNCITRAL guidelines to deliver immediate protection. The LCIA extends its emergency provisions through Article 9B which allows for emergency arbitrator selection and Article 25 which permits the issuance of interim measures. DIAC and Arbitrate AD likewise have Emergency Arbitrator provisions aimed at ensuring remedies are available with minimum delay.

It is important to note that emergency protection can be obtained through either arbitral institution rules or by selecting a seat that provides access to quick regional, international commercial court access such as the DIFC, ADGM and QICDRC Courts. The selection of these courts as the seat of arbitration enables parties to benefit from faster and more cost-effective court assistance than emergency arbitrator procedures, including ex parte applications, swift injunctions, proceedings conducted in English, and specialist commercial judges.

Managing Complexity: Consolidation and Multi-Contract Disputes

The increased number of commercial deals which include multiple contracts between different parties must align with arbitration systems which can effectively handle consolidated case management. SIAC’s introduction of Rule 17 on Coordinated Proceedings allows related arbitrations to proceed simultaneously. HKIAC operates one of the world’s most advanced consolidation systems through Articles 28 to 30 which enable cases to be merged and allow a single arbitration for multiple contracts.

The ICC supports this development through Article 10 which gives the Court powers to consolidate cases and Article 7(5) which enables tribunal constitution after joinder when suitable. Pursuant to Article 22A of the LCIA Rules, tribunals and the LCIA Court may decide how to handle multiple arbitration cases through consolidation or concurrent proceedings.

DIAC includes provisions for multiple contracts and consolidation, as well as joinder. Articles 9 to 12 of the Arbitrate AD Rules deal with multiple party and multiple contract scenarios.

Award Scrutiny and Enforceability

The modern systems of institutions enable their award procedures to operate at increased speed. The 2025 framework of SIAC establishes a 90-day time period under Rule 46.4(b) for draft award preparation which creates clarity and certainty for parties. The HKIAC improves enforcement capabilities under Article 35 for award procedures in alignment with New York Convention requirements.

The ICC imposes its regime of scrutiny under Article 34. In contrast, the LCIA grants tribunals independence to issue awards pursuant to Articles 26 and 27 without institutional approval. These developments demonstrate that while institutions differ in their approach, they share a commitment to strengthening the reliability and enforceability of arbitral awards. In all cases, it is important that the institute maintains the balance between ensuring the basic elements of any Award are present and being seen to be over-officious in its scrutiny.