The SIAC Rules and expedited procedures
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The seventh edition of 2025
SIAC's arbitration rules have been revised at regular intervals after public consultation. The seventh edition, the SIAC Rules 2025, was released on 18 December 2024 and came into force on 1 January 2025, replacing the edition of 2016. The Centre describes three aims: fairness of the proceedings, efficiency proportionate to the amount and complexity of the dispute, and the enforceability of the award.1
The third aim is served by the scrutiny of awards. Every draft award is reviewed by the Secretariat and approved by the Registrar, who may draw the tribunal's attention to points of form and substance without interfering with its discretion. In 2025, 192 awards were issued in SIAC cases on this basis.2 The scrutiny reduces the risk of formal defects that a losing party might later exploit before a court.
The Expedited Procedure
The Expedited Procedure was introduced in 2010. A party may request a fast-track procedure, normally before a sole arbitrator, with an award due within six months of the constitution of the tribunal. Under the 2025 Rules it is available where the amount in dispute does not exceed S$10 million, a ceiling raised from S$6 million, or on the other grounds that the Rules specify.3
The procedure is heavily used. Between 2010 and the end of 2025, SIAC received 1,169 requests and accepted 667 of them. In 2025 alone it received 130 requests and accepted 55.4 The figures show that users value a predictable timetable. A trading company owed US$3 million for a cargo of palm oil has little interest in a procedure that lasts three years and consumes a third of the claim in fees.
The Streamlined Procedure
The 2025 Rules added a further tier for small claims. The Streamlined Procedure applies on application where the amount in dispute does not exceed S$1 million. A sole arbitrator decides on written submissions, without document production and without fact or expert witnesses unless the tribunal directs otherwise. The final award is due within three months of the constitution of the tribunal, with fees capped at half the maximum of the schedule. In its first year, 60 cases proceeded under the new procedure. Some were concluded within the three-month timetable.5
The tiered structure answers a frequent criticism of international arbitration, namely that it is too slow and costly for the ordinary disputes of commerce. For the small and medium-sized trading companies of Southeast Asia, which form an important clientele of the financial centre, a three-month procedure at capped fees makes arbitration a realistic alternative to the courts of the counterparty's home country.
Emergency arbitrators and protective orders
SIAC introduced the emergency arbitrator in 2010. A party that needs urgent relief before the tribunal is constituted can ask the Centre to appoint a single arbitrator within a short period, who may order the preservation of assets or restrain a call on a guarantee. SIAC received 19 applications in 2025 and has accepted 191 since 2010.6
The 2025 Rules extended the mechanism. An application may now precede the notice of arbitration, which must follow within seven days. A party may also seek a protective preliminary order without notice to the other side, for situations in which advance warning would allow a counterparty to move assets. Four such applications were made in 2025, of which one was accepted.7 For banks and traders, the instrument offers a counterpart within arbitration to the freezing injunction of the courts.
Complex cases and third-party funding
Further innovations of 2025 address complex disputes. Under Rule 46 a party may apply for a preliminary determination of an issue, which can narrow a dispute early. Under Rule 17, arbitrations raising a common question of law or fact can be coordinated procedurally while each produces its own award. The older tools of consolidation and joinder remain in heavy use, with 107 applications for consolidation in 2025.8 A syndicated loan, a chain of commodity sales or a project financed by several lenders typically involves several contracts. Without consolidation or coordination, the same facts would be argued before several tribunals, with the risk of inconsistent results.
The 2025 Rules also require each party to disclose any third-party funding agreement and the identity of the funder.9 Singapore law has permitted third-party funding of international arbitration since 2017.10 The disclosure rule responds to the growth of a funding industry that finances claims in exchange for a share of the proceeds. Its purpose is to allow arbitrators to detect conflicts of interest with funders.
Common misconception
It is often assumed that every arbitration seated in Singapore is a SIAC arbitration. The seat and the institution are distinct choices. An arbitration under the ICC Rules or the UNCITRAL Rules may be seated in Singapore, while a SIAC arbitration may be seated elsewhere. The seat determines the arbitration law and the supervisory court, which for a Singapore seat means the International Arbitration Act and the Singapore courts. The institution determines who administers the case and under which rules. The leading recent decision on a copied award, DJP v DJO, concerned an ICC arbitration seated in Singapore.
Notes
- Clifford Chance, “SIAC releases the SIAC Rules 2025”, December 2024: released 18 December 2024, in force 1 January 2025; SIAC, Annual Report 2025, Year in Review, items 1 and 2: 7th edition in force 1 January 2025; aims of “(a) fairness of the proceedings; (b) efficiency in the conduct of the arbitration proportionate to the amount and complexity of issues in dispute; and (c) enforceability of any award”. ↩
- SIAC, Annual Report 2025, Statistics 2025, “Awards”: 192 awards in 2025; “SIAC’s scrutiny process enhances the enforceability of awards.” ↩
- Clifford Chance, December 2024 (n above): Rule 14.2, threshold raised from S$6 million to S$10 million, and Rule 14.2(c); SIAC, Annual Report 2025, Year in Review: “an increased threshold for the six-month Expedited Procedure”. ↩
- SIAC, Annual Report 2025, Statistics 2025, “Expedited Procedure (EP)”. ↩
- Clifford Chance, December 2024 (n above): Rule 13 and Schedule 2, paras 1, 11, 15 and 16; SIAC, Annual Report 2025: “In 2025, 60 cases proceeded under SP”; CEO's Report on cases “concluded within the three-month timeline”. ↩
- SIAC, Annual Report 2025, Statistics 2025, “Emergency Arbitrator Applications (EA)”: 19 applications in 2025, 18 accepted; 191 accepted since 2010. ↩
- Clifford Chance, December 2024 (n above): Schedule 1, paras 2 and 6; protective preliminary orders before counterparties are notified; SIAC, Annual Report 2025, Statistics 2025, “Protective Preliminary Order (PPO)”: 4 applications in 2025, 1 accepted; “These provisions were introduced in 2025.” ↩
- Clifford Chance, December 2024 (n above): Rules 17 and 46; SIAC, Annual Report 2025, Statistics 2025, “Consolidation and Joinder”: 640 consolidation and 87 joinder applications since 2016; 107 and 9 in 2025. ↩
- Clifford Chance, December 2024 (n above): Rule 38. ↩
- Civil Law Act 1909, s 5B, and Civil Law (Third-Party Funding) Regulations 2017, permitting funding of international arbitration and related proceedings by qualifying funders; later extensions to domestic arbitration and certain SICC proceedings. ↩
For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.