SIAC Rules 2025: new standards in International Arbitration?

The Singapore International Arbitration Centre (“SIAC”) has published its 7th Edition Arbitration Rules, which came into effect on 1 January 2025 (“SIAC Rules 2025”).

This article outlines three key changes introduced by the SIAC Rules 2025 and compares them to similar features in the arbitration rules of the International Chamber of Commerce (“ICC”) and the United Nations Commission on International Trade Law (“UNCITRAL”), as summarised below.

Expedited Procedure

The criteria for applicability of the expedited procedure under Rule 14 of the SIAC Rules 2025 have changed in three aspects:⁹

• First, while under the former version of the SIAC Rules, an application has to be filed with the Registrar for the Expedited Procedure to apply even where parties agree, Rule 14.1 of the SIAC Rules 2025 provides that the arbitration “shall be conducted” in accordance with the Expedited Procedure where the parties have agreed so, without an application.
• Second, the threshold for application of the Expedited Procedure has been increased from SGD 6 million to SGD 10 million.¹⁰
• Third, the ground of “in cases of exceptional urgency” has been replaced with the broader ground of “the circumstances of the case warrant the application of the Expedited Procedure”.¹¹

As a result of these three changes, there is scope to consider that the SIAC Rules 2025 allow for broader application of the Expedited Procedure compared to the UNCITRAL Rules (which only allow for Expedited Procedure where there is agreement) and ICC Rules (which have a lower ceiling on the amount in dispute). This is consistent with the aim of “expeditious and cost-effective conduct of the arbitration proportionate to the complexity of the claim and the amount in dispute”. With this change, a greater number of disputes is likely to qualify for an expedited procedure under the SIAC Rules 2025.

Interim measures prior to the constitution of Tribunal

The SIAC Rules 2025 provide that an application for emergency interim relief may be made even before filing a Notice of Arbitration.¹³

There is also a separate provision for the application of Protective Preliminary Orders (“PPOs”), which can be granted ex parte (i.e., without notice to the other parties) within 24 hours of application to prevent actions that could undermine emergency relief. This includes orders for asset preservation or orders to prevent the destruction of evidence.¹⁴

While the SIAC Rules 2016 empowered the Emergency Arbitrator to award preliminary orders, the express provision of ex parte PPOs is unique to the SIAC Rules 2025.

Coordinated Proceedings

The SIAC Rules 2025 have introduced a novel Coordinated Proceedings mechanism, designed to increase overall efficiency for multi-party and multi-contract disputes.

Under Rule 17 of the SIAC Rules 2025, where (i) the same Tribunal is constituted in two or more arbitrations, and (ii) a common question of law or fact arises out of or in connection with all the arbitrations, a party may request that these arbitrations be conducted concurrently or sequentially, heard together with aligned procedural steps, or that one arbitration be suspended pending the resolution of another.¹⁷

Unlike consolidated proceedings, whereby two or more arbitrations are consolidated into a single arbitration, coordinated arbitrations remain separate proceedings.¹⁸

This Coordinated Proceedings mechanism is also unique to the SIAC Rules 2025. It is intended to facilitate the streamlined resolution of complex arbitrations, reduce the risk of conflicting outcomes, and avoid duplication of costs. This is particularly advantageous in scenarios involving standard form agreements or interconnected contracts, where consolidation and joinder are not feasible.

Concluding remarks

Through these changes, the SIAC Rules 2025 aim to provide parties with more means to enhance efficiency in the dispute resolution process. These new features seek to address the needs of legal users who require quick resolution for their disputes by according primacy to the parties’ agreement. The changes also provide more options for parties seeking interim relief or ways of conducting multiple proceedings as efficiently as possible.

¹ 14.1 SIAC Rules 2025.
² Article 30 read with Appendix VI (Article 1) ICC Rules 2021.
³ Article 1(5) UNCITRAL Arbitration Rules.
⁴ Rule 12.1 SIAC Rules 2025.
⁵ Clause 2 Schedule 1 SIAC Rules 2025.
⁶ Article 29(1) ICC Rules 2021.
⁷ Article 26(1) UNCITRAL Arbitration Rules.
⁸ Rule 17.1 SIAC Rules 2025.
⁹ Rule 14 SIAC Rules 2025.
¹⁰ For an application to be made under Rule 14.2(a) of the SIAC Rules 2025.
¹¹ For an application to be made under Rule 14.2(c) SIAC Rules 2025.
¹² Rule 3.5(b) SIAC Rules 2025.
¹³ Schedule 1 Clause 2 SIAC Rules 2025.
¹⁴ Schedule 1 Clause 25 SIAC Rules 2025. There are also built-in protections, including that the Emergency Arbitrator shall provide an opportunity to any party against whom a PPO is directed to present its case at the earliest practicable time; the applicant must notify counterparties within 12 hours, or the order will expire after three days, and the PPO expires 14 days after issuance.
¹⁵ Schedule 1 Clause 8 SIAC Rules 2016.
¹⁶ Rule 17.1 SIAC Rules 2025.
¹⁷ Rule 17.1 SIAC Rules 2025.
¹⁸ Rule 17.3 SIAC Rules 2025.