Dünyanın önde gelen tahkim kuralları
Uluslararası sözleşmeniz için hangi kurallar uygun? On kurumsal tahkim kuralı, her birinin ne için olduğu ve uyuşmazlığın işleyişini gerçekten değiştiren usul özellikleri.
Bu içerik henüz çevrilmedi ve İngilizce gösteriliyor.
What the clause is actually choosing
Not a logo. A tribunal, a set of deadlines, a fee scale, and a registry that will or will not scrutinise the award before it issues. The rules you name decide all four.
Start from the dispute, not the institution
There is no single best set of arbitration rules, and any page that ranks them is selling something. The choice is a fit between a dispute nobody can yet see and a procedure that has to be named today — usually in three lines, usually at the end of a negotiation.
So this page is arranged the way the decision is actually made: the questions about the deal first, then the institutions, then the features where they genuinely differ. It is kept current rather than published once; the revision in the margin is the part that matters.
Parties and jurisdictions
Where the parties sit, where the assets sit, and where an award would have to be enforced. The seat is a legal choice before it is a convenient one.
Which courts supervise, and which enforce?
Value and complexity
Quantum sets the fee basis; structure sets the procedure. A mid-value dispute under a complex construction contract is the harder of the two to run.
Ad valorem fees, or hourly?
Need for emergency relief
Whether you may need an order before a tribunal exists. If the answer is even possibly yes, the emergency arbitrator provision stops being a footnote.
Is there an emergency arbitrator?
Cost and time expectations
Expedited tracks are common now; what varies is the threshold, whether it applies automatically, and whether the tribunal can opt out of it.
What triggers the expedited track?
Multiparty and multicontract
Chains of contracts with different signatories are where rule sets diverge most. Joinder and consolidation provisions are worth reading in full, not in summary.
Can related claims be heard together?
Confidentiality and enforcement
Confidentiality is a default in some rules and an election in others. Scrutiny of the award before it issues is the quiet feature that makes enforcement easier.
Is the award scrutinised before it issues?The ten, at a glance
ParisICC
International Chamber of Commerce
High-value, complex and multi-party international disputes; construction, energy, M&A.
Global recognition, administrative supervision by the ICC Court, and scrutiny of awards before issue.
LondonLCIA
London Court of International Arbitration
Financial services, banking, insurance, shareholder disputes, joint ventures.
Flexible procedure, strong tribunal powers, minimal court intervention, cost-efficient.
SingaporeSIAC
Singapore International Arbitration Centre
Asia-Pacific transactions, technology, international trade, shipping, cross-border investment.
Fast proceedings, emergency arbitrator, expedited procedure, modern digital administration.
Hong KongHKIAC
Hong Kong International Arbitration Centre
China-related contracts, Belt and Road projects, shipping, technology, cross-border disputes.
Deep experience with Chinese parties, flexible fee structures, advanced joinder and consolidation provisions.
DubaiDIAC
Dubai International Arbitration Centre
Middle East investments, construction, real estate, infrastructure, oil and gas.
Modern rules following the 2022 revision, consolidation of proceedings, emergency arbitrator, digital administration.
Ad hocUNCITRAL
UNCITRAL Arbitration Rules
Ad hoc arbitration, state contracts, investment disputes, international trade, government agreements.
Not tied to any institution, maximum procedural flexibility, globally accepted model rules.
New YorkICDR
International Centre for Dispute Resolution
International transactions connected to the United States; technology, healthcare, distribution agreements.
The international division of the AAA, strong North American expertise, emergency measures, comprehensive guidance.
ViennaVIAC
Vienna International Arbitral Centre
Central and Eastern Europe, energy, commercial disputes, cross-border investments.
Cost-efficient, fast administration, multilingual support, well-balanced procedural flexibility.
RiyadhSCCA
Saudi Center for Commercial Arbitration
Saudi Arabia, Vision 2030 projects, construction, energy, government projects.
Rapid international growth, modern framework, emergency arbitrator, strong institutional support.
IstanbulISTAC
Istanbul Arbitration Centre
Türkiye-related commercial contracts, regional trade, construction, energy, infrastructure.
Competitive costs, fast-track arbitration, emergency arbitrator, efficient administration.
Feature matrix
claimed in the source not claimed
| Rules | Seat | Expedited or fast track | Emergency arbitrator | Joinder and consolidation | Award scrutiny | Digital administration | Procedural flexibility | Cost efficiency |
|---|---|---|---|---|---|---|---|---|
| ICC | Paris | not claimed | not claimed | not claimed | claimed in the source | not claimed | not claimed | not claimed |
| LCIA | London | not claimed | not claimed | not claimed | not claimed | not claimed | claimed in the source | claimed in the source |
| SIAC | Singapore | claimed in the source | claimed in the source | not claimed | not claimed | claimed in the source | not claimed | not claimed |
| HKIAC | Hong Kong | not claimed | not claimed | claimed in the source | not claimed | not claimed | not claimed | claimed in the source |
| DIAC | Dubai | not claimed | claimed in the source | claimed in the source | not claimed | claimed in the source | not claimed | not claimed |
| UNCITRAL | Ad hoc | not claimed | not claimed | not claimed | not claimed | not claimed | claimed in the source | not claimed |
| ICDR | New York | not claimed | claimed in the source | not claimed | not claimed | not claimed | not claimed | not claimed |
| VIAC | Vienna | not claimed | not claimed | not claimed | not claimed | not claimed | claimed in the source | claimed in the source |
| SCCA | Riyadh | not claimed | claimed in the source | not claimed | not claimed | not claimed | not claimed | not claimed |
| ISTAC | Istanbul | claimed in the source | claimed in the source | not claimed | not claimed | not claimed | not claimed | claimed in the source |
This table is filled strictly from each institution's own summary of what its rules provide. A blank cell means the summary does not claim the feature — not that the rules lack it. Every cell needs checking against the current rules, with the article recorded, before it is relied on in drafting.
Drafting the clause
The arbitration clause is drafted in a few lines, usually last. Those few lines decide how an entire dispute is run.
Choose deliberately. Resolve effectively.
Four terms, and the rules supply everything else. Most fights about an arbitration clause turn on one of these four being missing rather than on any of them being wrong.
The rules
Which institution's procedure governs, and with it which registry administers the case and on what fee scale. Name the rule set, not the institution's building.
Left out: you have agreed to arbitrate without saying how.The seat
The legal place of the arbitration — the courts that supervise it and, on most analyses, the law governing the agreement to arbitrate. Not the same thing as the city a hearing happens to sit in.
Left out: the tribunal or the institution chooses it for you.The number of arbitrators
One or three. A cost decision as much as a procedural one: at the values these clauses usually cover, it is the difference between one set of fees and three.
Left out: the rules supply a default, which may suit neither party.The language
The language of the proceedings. The cheapest term in the clause to agree, and among the most expensive to omit — it settles translation cost before it settles anything else.
Left out: argued later, when losing the point costs most.How this page is maintained
Reviewed quarterly and on any rules revision. Corrections are made in place and the revision number is raised; the page is never replaced by a second version, so a link to it stays a link to the current text. If you find a cell that no longer matches the rules, tell us and we will correct it.