Arbitration Institutions And Rules In The United Kingdom
Arbitration Model | Typical Use | Geographic Suitability | Drafting Notes |
|---|---|---|---|
London Court of International Arbitration (LCIA) Arbitration Rules | |||
Institutional arbitration | London-seated and international commercial disputes needing administered arbitration. | Both domestic and international | Use the LCIA model clause specify seat, law, language and number of arbitrators. |
ICC Arbitration Rules | |||
Institutional arbitration | High-value cross-border commercial, infrastructure, energy and M&A disputes. | International | Use ICC standard clause identify seat, governing law, language and arbitrator number. |
UNCITRAL Arbitration Rules | |||
Ad hoc arbitration | Ad hoc international arbitration without full institutional administration. | International | Name an appointing authority and specify seat to avoid procedural deadlock. |
CIArb Arbitration Rules | |||
Institutional arbitration | Commercial disputes requiring a recognised professional arbitration framework. | Both domestic and international | State seat, tribunal size and whether CIArb is to administer or appoint only. |
Arbitration Act 1996 | |||
Ad hoc arbitration | Default legal framework for arbitrations seated in England, Wales or Northern Ireland. | UK domestic | Do not call it institutional rules specify seat for the Act to apply as curial law. |
Arbitration (Scotland) Act 2010 and Scottish Arbitration Rules | |||
Ad hoc arbitration | Arbitrations seated in Scotland, including Scottish domestic commercial disputes. | UK domestic | Use a Scottish seat if the Scottish statutory rules are intended. |
London Maritime Arbitrators Association (LMAA) Terms | |||
Trade association rules, Specialist sector rules | Shipping, charterparty, shipbuilding, offshore and maritime trade disputes. | International | Use LMAA wording align with charterparty terms, seat and appointment process. |
LMAA Small Claims Procedure | |||
Specialist sector rules, Trade association rules | Lower-value maritime claims needing faster and cheaper determination. | International | Check current monetary limit and expressly opt in where needed. |
LMAA Intermediate Claims Procedure | |||
Specialist sector rules, Trade association rules | Mid-value maritime disputes needing proportionate procedure. | International | Confirm value threshold and consistency with any incorporated charterparty arbitration clause. |
GAFTA Arbitration Rules | |||
Trade association rules, Specialist sector rules | International grain, feed and agricultural commodity trade disputes. | International | Use GAFTA standard forms carefully observe short claim and appeal time limits. |
FOSFA Arbitration and Appeal Rules | |||
Trade association rules, Specialist sector rules | Oilseeds, oils and fats commodity disputes. | International | Ensure the relevant FOSFA contract form and arbitration clause are incorporated. |
Refined Sugar Association Arbitration Rules | |||
Trade association rules, Specialist sector rules | International refined sugar trade disputes. | International | Incorporate RSA rules and check quality, sampling and appeal provisions. |
London Metal Exchange (LME) Arbitration Regulations | |||
Trade association rules, Specialist sector rules | Disputes under LME contracts and exchange-related metals transactions. | Both domestic and international | Check whether LME rules apply automatically via exchange contract documentation. |
London Chamber of Arbitration and Mediation (LCAM) Arbitration Rules | |||
Institutional arbitration | Commercial disputes involving SMEs and international parties seeking London administration. | Both domestic and international | Use LCAM model clause and specify seat, law and language. |
CEDR Rules for the Facilitation of Settlement in International Arbitration | |||
Institutional arbitration | Arbitrations where structured settlement facilitation is desired. | International | Clarify interaction between arbitration procedure and settlement facilitation steps. |
Society for Computers and Law Adjudication Rules | |||
Specialist sector rules | Technology and IT disputes needing fast expert determination style procedure. | UK domestic | Not conventional arbitration use only if adjudication rather than arbitral award is intended. |
ICSID Convention Arbitration Rules | |||
Institutional arbitration, Specialist sector rules | Investor-state disputes under investment treaties, legislation or investment contracts. | International | Requires ICSID jurisdiction and consent unsuitable for ordinary private commercial contracts. |
ICSID Additional Facility Rules | |||
Institutional arbitration, Specialist sector rules | Investor-state disputes not qualifying for ICSID Convention arbitration. | International | Check nationality, state consent and enforcement route before selecting. |
Permanent Court of Arbitration (PCA) Arbitration Rules | |||
Institutional arbitration, Ad hoc arbitration | State, intergovernmental, investor-state and complex public international disputes. | International | Specify PCA role, appointing authority function, seat and applicable public law instruments. |
Singapore International Arbitration Centre (SIAC) Arbitration Rules | |||
Institutional arbitration | Asia-related international trade, investment, technology and commercial disputes. | International | Use SIAC model clause do not assume Singapore seat unless stated. |
Hong Kong International Arbitration Centre (HKIAC) Administered Arbitration Rules | |||
Institutional arbitration | China, Hong Kong and Asia-Pacific cross-border disputes. | International | Specify seat and law consider Hong Kong seat for Mainland China enforcement strategy. |
SCC Arbitration Rules | |||
Institutional arbitration | Nordic, European, energy, construction and investment-related disputes. | International | Use SCC model clause specify seat, language and applicable law. |
Swiss Rules of International Arbitration | |||
Institutional arbitration | European and international commercial disputes with neutral-seat preference. | International | Specify seat Swiss rules do not require a Swiss seat. |
DIS Arbitration Rules | |||
Institutional arbitration | German and European commercial, engineering and corporate disputes. | Both domestic and international | Use DIS clause and specify whether expedited or ordinary procedure is intended. |
VIAC Rules of Arbitration and Mediation (Vienna Rules) | |||
Institutional arbitration | Central and Eastern European commercial disputes. | International | Use VIAC model clause specify seat, language and substantive law. |
Paris Arbitration Centre (CPA) Rules | |||
Institutional arbitration | French and international commercial disputes requiring Paris-based administration. | Both domestic and international | State seat and language avoid confusing CPA with the Permanent Court of Arbitration. |
Netherlands Arbitration Institute (NAI) Arbitration Rules | |||
Institutional arbitration | Dutch and international commercial disputes. | Both domestic and international | Specify seat if not the Netherlands use current NAI clause wording. |
CEPANI Arbitration Rules | |||
Institutional arbitration | Belgian, Benelux and international commercial disputes. | Both domestic and international | Use CEPANI model clause and specify seat, language and arbitrator number. |
Madrid International Arbitration Centre (MIAC) Rules | |||
Institutional arbitration | Spanish, Latin American and international commercial disputes. | International | Specify seat and language consider Spanish or bilingual documentation needs. |
Milan Chamber of Arbitration Rules | |||
Institutional arbitration | Italian and international commercial disputes. | Both domestic and international | Use model clause specify seat if not Milan or Italy. |
Dubai International Arbitration Centre (DIAC) Arbitration Rules | |||
Institutional arbitration | Middle East construction, energy, trade and commercial disputes. | International | Specify seat clearly, especially where DIFC, Dubai or foreign seat is intended. |
DIFC-LCIA Arbitration Rules (Legacy Clauses) | |||
Institutional arbitration | Legacy Middle East contracts referring to the former DIFC-LCIA centre. | International | Avoid for new clauses check successor administration and transition provisions. |
Qatar International Centre for Conciliation and Arbitration (QICCA) Rules | |||
Institutional arbitration | Qatar and Gulf construction, infrastructure and commercial disputes. | International | Specify seat, language and governing law to avoid local-law uncertainty. |
Bahrain Chamber for Dispute Resolution (BCDR) Arbitration Rules | |||
Institutional arbitration | Bahrain, Gulf and international financial or commercial disputes. | International | State whether BCDR institutional arbitration or statutory court-linked process is intended. |
ICDR International Arbitration Rules | |||
Institutional arbitration | US-linked and global cross-border commercial disputes. | International | Use ICDR clause distinguish from AAA domestic rules if non-US parties are involved. |
AAA Commercial Arbitration Rules | |||
Institutional arbitration | US domestic commercial disputes and some US-facing contracts. | International | For UK parties, consider ICDR instead for international administration. |
JAMS Comprehensive Arbitration Rules and Procedures | |||
Institutional arbitration | US commercial, technology, employment and consumer-related disputes. | International | Check mandatory consumer or employment protocols before using in standard terms. |
CPR Administered Arbitration Rules | |||
Institutional arbitration | Complex US and international business-to-business disputes. | International | Decide between administered and non-administered CPR rules in the clause. |
CIETAC Arbitration Rules | |||
Institutional arbitration | China-related international trade, investment and commercial disputes. | International | Specify CIETAC commission, seat, language and governing law clearly. |
Shanghai International Arbitration Center (SHIAC) Arbitration Rules | |||
Institutional arbitration | Shanghai, China and international commercial disputes. | International | Use current institutional name and specify seat, language and commission details. |
Beijing Arbitration Commission / Beijing International Arbitration Center Rules | |||
Institutional arbitration | China-related domestic and international commercial disputes. | Both domestic and international | State BAC/BIAC name accurately and specify language for foreign parties. |
Japan Commercial Arbitration Association (JCAA) Commercial Arbitration Rules | |||
Institutional arbitration | Japan-related international commercial and technology disputes. | International | Choose between JCAA commercial, interactive or UNCITRAL-based rules if relevant. |
KCAB International Arbitration Rules | |||
Institutional arbitration | Korea-related international construction, trade and technology disputes. | International | Use KCAB International clause and specify seat, language and governing law. |
ACICA Arbitration Rules | |||
Institutional arbitration | Australia, Asia-Pacific, construction, infrastructure and trade disputes. | International | Use ACICA model clause specify seat if not Australia. |
New Zealand International Arbitration Centre (NZIAC) Arbitration Rules | |||
Institutional arbitration | New Zealand and Pacific region commercial disputes. | Both domestic and international | Specify seat and rules edition consider expedited procedure for smaller claims. |
ADR Institute of Canada Arbitration Rules | |||
Institutional arbitration | Canadian domestic and international commercial disputes. | Both domestic and international | Clarify province, seat, appointing authority and bilingual requirements if relevant. |
Vancouver International Arbitration Centre (VanIAC) International Commercial Arbitration Rules | |||
Institutional arbitration | Canada, Pacific Rim and international commercial disputes. | International | Use VanIAC model clause specify seat and governing law. |
CAM-CCBC Arbitration Rules | |||
Institutional arbitration | Brazilian and Latin American corporate, infrastructure and commercial disputes. | International | Specify language, seat and Brazilian-law formalities where applicable. |
ICDR Canada Arbitration Rules | |||
Institutional arbitration | Canadian cross-border commercial disputes administered by ICDR Canada. | International | Distinguish ICDR Canada from ICDR international or provincial domestic rules. |
CCJA Arbitration Rules | |||
Institutional arbitration, Specialist sector rules | Disputes connected with OHADA member states in Africa. | International | Use where OHADA enforcement and CCJA supervision are commercially relevant. |
Cairo Regional Centre for International Commercial Arbitration (CRCICA) Rules | |||
Institutional arbitration | Middle East and North Africa commercial and construction disputes. | International | Specify seat, language and law rules are UNCITRAL-inspired but institution-administered. |
Kigali International Arbitration Centre (KIAC) Arbitration Rules | |||
Institutional arbitration | East African commercial, infrastructure and investment-related disputes. | International | Specify seat and language consider regional enforcement and neutrality factors. |
Mauritius International Arbitration Centre (MIAC) Arbitration Rules | |||
Institutional arbitration | Africa, India-related and offshore investment commercial disputes. | International | Specify seat do not assume Mauritius seat merely from MIAC administration. |
Arbitration Foundation of Southern Africa (AFSA) International Arbitration Rules | |||
Institutional arbitration | Southern African and international commercial disputes. | International | Use AFSA international clause and specify seat, language and governing law. |
WIPO Arbitration Rules | |||
Institutional arbitration, Specialist sector rules | Intellectual property, technology, life sciences and licensing disputes. | International | Useful for confidentiality and technical expertise specify seat and IP governing law. |
WIPO Expedited Arbitration Rules | |||
Institutional arbitration, Specialist sector rules | Lower-value or time-sensitive IP and technology disputes. | International | Expressly select expedited rules and consider limits on evidence and timetable. |
Court of Arbitration for Sport (CAS) Code of Sports-Related Arbitration | |||
Institutional arbitration, Specialist sector rules | Sports governance, disciplinary, doping and commercial sports disputes. | International | Use only for sports disputes check federation statutes and appeal jurisdiction. |
The Sugar Association of London Arbitration Rules | |||
Trade association rules, Specialist sector rules | Raw sugar and related commodity trade disputes. | International | Check whether raw or refined sugar rules are the correct market standard. |
RICS Dispute Resolution Service Arbitration | |||
Specialist sector rules | Property, rent review, valuation and real estate disputes. | UK domestic | State whether arbitration, expert determination or adjudication is intended. |
Football Association Rule K Arbitration | |||
Specialist sector rules | English football participant and club disputes within FA jurisdiction. | UK domestic | Generally arises from football rules avoid using outside FA-governed disputes. |
JCT Construction Industry Model Arbitration Rules (CIMAR) | |||
Specialist sector rules | UK construction disputes under JCT and related building contracts. | UK domestic | Coordinate with statutory adjudication rights and JCT dispute resolution options. |
Housing Grants, Construction and Regeneration Act 1996 Adjudication Regime | |||
Specialist sector rules | UK construction contracts where adjudication may sit alongside arbitration. | UK domestic | Adjudication rights may be mandatory arbitration can govern final determination. |
TeCSA Arbitration Rules | |||
Specialist sector rules | Technology and construction disputes needing specialist UK practitioners. | UK domestic | Check appointment body wording and relationship with adjudication or court options. |
P.R.I.M.E. Finance Arbitration Rules | |||
Institutional arbitration, Specialist sector rules | Complex finance, derivatives and banking disputes. | International | Consider compatibility with ISDA documentation and court jurisdiction clauses. |
UKJT Digital Dispute Resolution Rules | |||
Specialist sector rules | Digital asset, blockchain, smart contract and crypto disputes. | International | Useful for on-chain enforcement concepts specify seat and technical appointment process. |
Energy Charter Treaty Arbitration Options | |||
Specialist sector rules, Ad hoc arbitration, Institutional arbitration | Energy investment disputes between investors and states under treaty consent. | International | Treaty-based do not use as ordinary commercial rules in private contracts. |
International Commercial Arbitration Court at the Ukrainian CCI (ICAC) Rules | |||
Institutional arbitration | Ukraine, CIS and international trade disputes. | International | Specify institution accurately to avoid confusion with other ICAC bodies. |
ICAC at the Chamber of Commerce and Industry of the Russian Federation Rules | |||
Institutional arbitration | Russia-related commercial disputes and legacy CIS contracts. | International | Consider sanctions, enforceability and institutional status before new use. |
Asian International Arbitration Centre (AIAC) Arbitration Rules | |||
Institutional arbitration | Malaysia, ASEAN, construction and international commercial disputes. | International | Use AIAC model clause and specify seat, language and applicable law. |
Thailand Arbitration Center (THAC) Arbitration Rules | |||
Institutional arbitration | Thailand and ASEAN commercial disputes. | International | Specify seat and language consider local court support and enforcement. |
BANI Arbitration Center Rules | |||
Institutional arbitration | Indonesia-related domestic and international commercial disputes. | Both domestic and international | Identify the intended BANI institution precisely and specify language. |
Philippine Dispute Resolution Center (PDRC) Arbitration Rules | |||
Institutional arbitration | Philippines-related domestic and international commercial disputes. | Both domestic and international | Specify seat, venue and language check whether international rules apply. |
Mumbai Centre for International Arbitration (MCIA) Rules | |||
Institutional arbitration | India-related commercial, infrastructure and finance disputes. | International | Use model clause and specify seat Mumbai venue is not automatically the legal seat. |
Delhi International Arbitration Centre (DIAC India) Rules | |||
Institutional arbitration | India-related domestic and international commercial disputes. | Both domestic and international | Avoid confusion with Dubai DIAC define the institution by full name. |
UAE Federal Arbitration Law | |||
Ad hoc arbitration | Legal framework for arbitrations seated onshore in the UAE. | International | Distinguish onshore UAE seat from DIFC or ADGM seat in the clause. |
UNCITRAL Expedited Arbitration Rules | |||
Ad hoc arbitration | Ad hoc international disputes needing a shorter and simpler procedure. | International | Expressly opt in and name an appointing authority and seat. |
New York Convention on Recognition and Enforcement of Foreign Arbitral Awards | |||
Ad hoc arbitration, Institutional arbitration | Framework for cross-border recognition and enforcement of arbitral awards. | International | Choose a convention-state seat and produce an award capable of enforcement abroad. |
Arbitration Act 1996 Sections 100-104 New York Convention Awards | |||
Institutional arbitration, Ad hoc arbitration | Recognition and enforcement of foreign convention awards in England and Wales. | International | Relevant to enforcement, not procedural rules keep arbitration clause valid and written. |
DIFC Arbitration Law | |||
Ad hoc arbitration | Legal framework for arbitrations seated in the Dubai International Financial Centre. | International | State DIFC as seat if DIFC court supervision is intended. |
ADGM Arbitration Regulations 2015 | |||
Ad hoc arbitration | Legal framework for arbitrations seated in Abu Dhabi Global Market. | International | Specify ADGM seat and avoid ambiguity with onshore Abu Dhabi seat. |
eBRAM Arbitration Rules | |||
Institutional arbitration, Specialist sector rules | Online arbitration for cross-border commercial and technology disputes. | International | Check platform, electronic service and data security provisions before adoption. |
International Islamic Centre for Reconciliation and Arbitration (IICRA) Arbitration Rules | |||
Institutional arbitration, Specialist sector rules | Islamic finance, banking and Sharia-compliant commercial disputes. | International | Clarify governing law, Sharia principles and seat to avoid interpretive conflict. |
Singapore Chamber of Maritime Arbitration (SCMA) Rules | |||
Trade association rules, Specialist sector rules | Shipping, maritime, offshore and trade disputes in Asia-Pacific markets. | International | Specify SCMA rules, seat and appointment process in maritime contracts. |
Society of Maritime Arbitrators (SMA) Rules | |||
Trade association rules, Specialist sector rules | New York maritime, shipping and charterparty disputes. | International | Specify New York or other seat and align with charterparty forum clause. |
German Maritime Arbitration Association (GMAA) Rules | |||
Trade association rules, Specialist sector rules | German and international maritime, shipping and offshore disputes. | International | Specify seat, usually Hamburg or another chosen place, and arbitrator qualifications. |
Chambre Arbitrale Maritime de Paris (CAMP) Rules | |||
Trade association rules, Specialist sector rules | French and international maritime, transport and shipping disputes. | International | Use CAMP clause and specify language if non-French parties are involved. |
Which Arbitration Rules Should A UK Contract Choose?
LCIA, ICC, UNCITRAL and CIArb rules are the most common starting points for UK-facing commercial arbitration clauses. LCIA is often preferred for London-seated international disputes, ICC for high-value cross-border contracts, UNCITRAL where parties want ad hoc arbitration, and CIArb where a lighter administered framework is desired.
Why Does The Seat Matter In A UK Arbitration Clause?
If the clause provides for a London or England and Wales seat, the Arbitration Act 1996 will generally supply the curial law, including rules on tribunal powers, court support and challenges to awards. The institution administers the case, but the seat controls the legal framework for the arbitration.
When Are Specialist Arbitration Rules Better Than General Rules?
Specialist rules can be useful where the dispute is likely to involve maritime, commodities, construction, technology, finance, sport or intellectual property. For example, LMAA and GAFTA are common in shipping and commodities, while WIPO is designed for IP and technology disputes.
What Should Be Included When Referring To Arbitration Rules?
- Name the institution or rules precisely, including any version or current rules wording where relevant.
- State the seat, especially if UK court support and Arbitration Act 1996 supervision are desired.
- Specify the number of arbitrators and appointment method if the chosen rules leave scope for uncertainty.
- Check sector rules carefully, because some trade association rules assume membership, standard form contracts, short time limits or specialist appeal mechanisms.
- Avoid mixing inconsistent rules, such as naming one institution but another body\'s appointment procedure, unless deliberate and clear.

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