Arbitration in Singapore: law, SIAC Rules 2025, costs and enforcement

The short version

• Singapore arbitration law has two statutes. The International Arbitration Act 1994 (IAA), based on the Model Law of the United Nations Commission on International Trade Law (UNCITRAL), covers international arbitration in Singapore. The Arbitration Act 2001 (AA) covers domestic cases.
• In the 2025 International Arbitration Survey by Queen Mary University of London, respondents could name up to five seats. London was named by 34% and Singapore and Hong Kong by 31% each.
• Cases started at the Singapore International Arbitration Centre (SIAC) from 1 January 2025 use the SIAC Rules 2025. Where S$1 million or less is in dispute, counterclaims included, the three-month Streamlined Procedure applies unless the parties exclude it or SIAC’s President decides otherwise. Up to S$10 million, a party can apply for the six-month Expedited Procedure.
• SIAC publishes maximum fees. On S$5 million in dispute, claims and counterclaims together, SIAC’s administration fee is at most S$36,000 and each arbitrator’s fee at most S$130,000, plus a S$3,000 filing fee (S$3,270 for Singapore parties) and any goods and services tax (GST).
• An IAA award cannot be appealed on a point of law. It can only be set aside on the grounds in Model Law art 34 and IAA s 24, by an application made within three months of receiving the award.
• Singapore’s Ministry of Law (MinLaw) consulted on IAA reform from 21 March to 2 May 2025. Its press-release and consultation listings showed no bill as of 26 October 2026. The SIAC Rules 2025 do not mention AI.^{1,3,4,9,10,11,12}

What law governs arbitration in Singapore?

Two Acts govern arbitration in Singapore. The IAA covers international arbitration and the AA covers domestic arbitration, as the Court of Appeal noted when comparing their stay provisions ([2025] SGCA 25, [25]). The AA applies where Singapore is the place of arbitration and Part 2 of the IAA does not apply (AA s 3).^2,30

The Model Law is UNCITRAL’s 1985 template for national arbitration laws, amended in 2006. The IAA adopted the 1985 text (MinLaw’s 2025 consultation paper, para 2) and has been in force since 27 January 1995, according to Singapore Statutes Online. UNCITRAL lists Singapore from 1994.^1,6,9

If one side goes to court despite an arbitration agreement, the other can ask for a stay, an order pausing the court case. Under the AA a court keeps some discretion to refuse a stay (AA s 6(2)). Under the IAA it does not ([2025] SGCA 25, [25]).³⁰

Singapore acceded to the New York Convention, the 1958 treaty on recognising and enforcing foreign arbitral awards, on 21 August 1986, with effect from 19 November 1986. It applies the Convention only to awards made in another contracting state, a limit known as the reciprocity reservation.⁵

Why do parties choose Singapore as a seat?

Users rank Singapore among their most preferred seats, and it is open to foreign participants. Foreign counsel can represent parties in arbitrations seated in Singapore, and MinLaw says it puts no restrictions on the choice of governing law or arbitrators (para 8(a), (b)). Third-party funding, where an outside funder pays a party’s costs for a share of any recovery, has been allowed for international arbitration since 2017. Conditional fee agreements, where a lawyer’s fee depends on the result, followed in 2022.^14,15

In the 2025 Queen Mary survey, respondents could name up to five seats. London was named by 34% and Singapore and Hong Kong by 31% each (Chart 3, printed p 7). London and Singapore were the only seats in the top five in every region (Chart 2, printed p 6).⁴

Hong Kong and Singapore are close. In Asia-Pacific, Hong Kong was named by 45% and Singapore by 40% (Chart 2, printed p 6). For rules, the International Chamber of Commerce (ICC) Rules were named by 39%, and the Hong Kong International Arbitration Centre (HKIAC) and SIAC Rules by 25% each (Chart 5, printed p 10).⁴

The two seats’ laws also differ on appeals. Hong Kong lets parties opt in to an appeal on questions of law, which the IAA does not provide (MinLaw consultation paper paras 22, 23). For how London compares, see arbitration in London, and for the Indian side, arbitration in India.⁹

Which institutions run arbitrations in Singapore, and under what rules?

SIAC runs domestic and international arbitrations under the SIAC Rules 2025, its 7th edition, which apply to cases started on or after 1 January 2025 unless the parties agree otherwise (rr 1.2, 1.5). MinLaw also names the Singapore Chamber of Maritime Arbitration (SCMA), and in August 2026 still discussed the SIAC Rules 2025 (para 57). SIAC’s website showed a bot check on 26 October 2026, so we could not check its own listings for a later edition. See SIAC’s entry in our AI rules tracker.^3,14,16

• The Singapore International Commercial Court (SICC), officially launched on 5 January 2015, is a division of the General Division of the High Court and a supervisory court for international arbitrations seated in Singapore.
• MinLaw says Singapore has welcomed the Permanent Court of Arbitration (PCA), the ICC International Court of Arbitration, the American Arbitration Association’s International Centre for Dispute Resolution (AAA-ICDR) and the World Intellectual Property Organization (WIPO) Arbitration and Mediation Center. The Singapore Office of the International Centre for Settlement of Investment Disputes (ICSID) was officially launched on 26 August 2026, ICSID’s first staffed office outside its Washington, D.C. headquarters.
• In ad hoc cases, run without an institution, SIAC appoints arbitrators on request for a fee: S$5,000 for one arbitrator, or S$5,450 for Singapore parties (Schedule of Fees).^{3,14,18,23,24,25}

What should the arbitration clause say, and what can be arbitrated?

A Singapore arbitration clause should name the seat and the language, because under the SIAC Rules the tribunal decides both if the parties do not (rr 36.1, 37.1). The seat is the arbitration’s legal home. Its law governs the procedure and its courts supervise the case and hear challenges to the award (Anupam Mittal v Westbridge Ventures II Investment Holdings [2023] SGCA 1, [75]). Hearings can take place somewhere else (r 39.2).^3,27

• The clause can choose a track, the Streamlined or Expedited Procedure, or exclude either in writing (rr 13.1(a), 13.3, 14.1, 14.4).
• It can fix the number of arbitrators and how they are nominated. Without agreement, SIAC appoints a sole arbitrator unless the Registrar decides the dispute warrants three (rr 19.1, 21, 22).
• SIMC publishes model Arb-Med-Arb clauses for adding mediation to a SIAC arbitration.^3,22

Any dispute the parties have agreed to arbitrate can be arbitrated unless that is contrary to public policy (IAA s 11(1), quoted in Anupam Mittal [46]). Before an award, arbitrability, meaning whether a dispute can be arbitrated at all, is decided first by the law of the arbitration agreement, with Singapore public policy also applying as the law of the seat ([55]). Under Singapore law, claims of corporate oppression can be arbitrated ([61]).²⁷

The law of the arbitration agreement is found in three stages, the test from BCY v BCZ (Anupam Mittal [62]). Courts look first for an express choice, then an implied one, starting from the law of the main contract. Failing both, they apply the law with the “closest and most real connection”, usually the law of the seat (consultation paper para 28). MinLaw has asked whether to keep this test, put a rule in the IAA or follow the UK Arbitration Act 2025, under which the law of the seat governs unless the parties expressly agree otherwise (paras 30, 31).^9,27

How does a SIAC arbitration work, step by step?

A SIAC arbitration starts on the day SIAC’s Registrar receives the claimant’s Notice of Arbitration, which can be filed through SIAC Gateway, SIAC’s case management system (rr 2.1, 6.1, 6.2). The Notice must describe the dispute and the relief sought, disclose any third-party funder and come with the filing fee (r 6.3). An unpaid fee can end the case (r 6.6). The respondent has 14 days to reply (r 7.1). Before an award is issued, the tribunal sends a draft to SIAC for review, a step called scrutiny (rr 53.2 to 53.4).³

• Related arbitrations can be consolidated (r 16) or coordinated (r 17), and additional parties can be joined to a case (r 18).
• Once formed, the tribunal can grant interim relief itself, and asking a court for interim relief does not breach the arbitration agreement (rr 45.1, 45.2).
• Preliminary determination and early dismissal are not available in Streamlined cases (Sch 2 para 18).
• Unless the parties agree otherwise, everyone in the case owes a continuing duty of confidentiality (r 59.1). The tribunal must also discuss information security at the first case management conference (r 61.2).³

How long does arbitration in Singapore take, and what does it cost?

In a SIAC case, how long arbitration in Singapore takes depends on the track, and what it costs depends mainly on the amount in dispute. A Streamlined award is due three months after the tribunal is formed and an Expedited award six months after, unless the Registrar extends time (Sch 2 para 15; Sch 3 para 6). Standard cases have no fixed end date, but the draft award is due 90 days after the last submission unless the Registrar decides otherwise (r 53.2). We give no average, because we could not open SIAC’s own figures.³

In a SIAC case, the cost of arbitration in Singapore covers the filing fee, the tribunal’s and SIAC’s fees and expenses, and any emergency arbitrator, tribunal secretary or tribunal-appointed expert (r 57.2), plus each side’s legal costs (r 58.1). The Schedule of Fees in force from 1 January 2025 shows how SIAC fees are calculated, in bands by the amount in dispute. Its figures are maximums, though the Registrar can exceed them (r 57.4(b)).³

• Filing fee: S$3,000, or S$3,270 for Singapore parties, including 9% GST.
• SIAC’s administration fee: at least S$5,000 (S$2,500 in Streamlined cases), up to S$150,000 above S$1 billion.
• Each arbitrator’s fee: set by band, up to S$2 million.
• Emergency arbitrator: a S$5,000 administration fee (S$5,450 for Singapore parties), a S$30,000 deposit and a S$25,000 fee, unless the Registrar decides otherwise.
• Challenge to an arbitrator: a S$10,000 filing fee (S$10,900 for Singapore parties).
• Worked example, S$5 million in dispute: SIAC’s fee is at most S$24,000 plus 0.4% of the S$3 million above S$2 million, a total of S$36,000. Each arbitrator’s is at most S$85,000 plus 1.5% of that S$3 million, a total of S$130,000.
• Streamlined example, S$1 million in dispute: the maximums of S$15,000 for SIAC and S$60,000 for each arbitrator halve to S$7,500 and S$30,000, unless the Registrar decides otherwise (Sch 2 para 16).
• Who pays: each side pays half the deposits unless the Registrar directs otherwise (r 56.1), and the tribunal can order one party to pay another’s legal costs (r 58.1).³

What role do Singapore courts play during an arbitration?

Singapore courts support the arbitration and step in only where the Model Law or the IAA allows (Model Law art 5; DMZ v DNA [1], [20]). They review afresh a tribunal’s ruling on its own jurisdiction, meaning its power to hear the dispute, on a challenge under IAA s 10(3) or in a set-aside application (consultation paper para 33).^1,8,9,31

Courts can also grant interim measures, orders that protect assets or evidence until the award, but only if the tribunal has no power or is unable for the time being to act effectively (IAA s 12A(6); KBP v Novo Nordisk [80]). Section 12A applies wherever the arbitration is seated. In 2026 the Court of Appeal held that it reaches a non-party that an emergency arbitrator’s order would not clearly bind, and a party given no notice where notice could let it defeat the relief ([88]).^1,33

MinLaw says Singapore amended its law so that an emergency arbitrator, an arbitrator appointed for urgent relief before the tribunal is formed, counts as an “arbitral tribunal” and its orders can be enforced. For domestic cases this is AA s 2(1).^2,14

In DMZ v DNA the Court of Appeal held that the courts had no power to review SIAC’s ruling on when an arbitration began ([3], [7]). A court second-guessing a procedural decision in an ongoing arbitration without express power would be “most exceptional, if at all it arises” ([43]).³¹

Unless the parties agree otherwise, the parties and the tribunal owe a duty of confidentiality under the common law. MinLaw’s 2020 amending Bill recognised the power of the tribunal and the High Court to enforce that duty without codifying it, and the amending Act took effect on 1 December 2020.^1,13

Can you appeal or set aside an arbitral award in Singapore?

The IAA provides no appeal against an award, even for a serious error of law. Apart from challenges to jurisdiction rulings, the route is an application to have the award set aside (consultation paper para 22). Set aside means a court at the seat cancels the award. The application must be made within three months of receiving the award, and the courts have held that limit absolute, even for fraud (Model Law art 34(3); consultation paper para 18).^8,9

The grounds are those in article 34 of the Model Law, such as an invalid agreement or a conflict with public policy (CBX v CBZ [12]). IAA s 24 adds two more: fraud or corruption, and a breach of natural justice that prejudiced a party’s rights. Natural justice means the right to a fair hearing before an unbiased tribunal.^1,8,26

In DJP v DJO, at least 212 of the award’s 451 paragraphs came from two earlier awards in parallel cases ([2], [73]). The Court of Appeal found that a fair-minded observer would suspect anchoring bias, the unconscious tendency to rely on an earlier conclusion without fresh analysis ([74]). Relying on material from the parallel cases that had never been put to the parties breached the fair hearing rule ([82]), and setting aside the whole award was upheld ([84], [87]). Copying uncontested, relevant facts may be acceptable ([44]).²⁸

A court can set aside part of an award (CBX v CBZ [64]). It can instead pause the application so the tribunal can remove the ground for setting aside (Model Law art 34(4)), but once it has set an award aside it cannot send the matter back ([78]; DJP v DJO [88]).^8,26,28

Applications to set aside awards in international arbitrations seated in Singapore can be heard in the SICC, where DJP v DJO and DPT v DPV began. The High Court’s decision can be appealed without permission (consultation paper para 13). Domestic awards are set aside under AA s 48(1) (DKT v DKU [5]).^{9,23,28,29,35}

How are arbitral awards enforced in and from Singapore?

To enforce an international or foreign arbitral award in Singapore, the winning party applies to the High Court for permission under IAA ss 19 and 29, and the court can enter judgment in the terms of the award (Pacmar [10], [11]). The losing party can resist a foreign award on the grounds in IAA s 31, such as a breach of natural justice (s 31(2)(c)) or a conflict with the “public policy of Singapore” (s 31(4)(b)) (ONI v GNC [28]; Anupam Mittal [48]).^1,27,32,34

An action to enforce an award must be brought within six years of the date the losing party fails to honour it, which is usually the date the award is issued (Limitation Act 1959 s 6(1)(c); Pacmar [3], [55], [60]).³²

A Singapore award is enforced abroad under the New York Convention, which has 172 parties; see New York Convention grounds. Enforcing a Singapore award in India is covered in arbitration in India.⁵

For ICSID awards, the Court of Appeal held in October 2026 that Spain, by joining the ICSID Convention, had submitted to the Singapore courts’ jurisdiction over proceedings to register or enforce them. State immunity, a state’s protection from another country’s courts, therefore did not bar registration (Spain v NextEra [30] to [33]). Registration runs under the Arbitration (International Investment Disputes) Act 1968, which gives no route to review the merits ([18], [48]).³⁶

Under SIMC’s Arb-Med-Arb Protocol, a settlement reached in mediation during an arbitration can be recorded as a consent award, an award in the terms the parties agreed. The Singapore Convention on Mediation, the 2018 United Nations treaty on enforcing international mediated settlements, has 25 parties and has been in force for Singapore since 12 September 2020.^7,22

What changed in 2025 and 2026, and which judgments matter?

The SIAC Rules 2025 took effect on 1 January 2025. MinLaw says they introduced the Streamlined Procedure and raised the Expedited threshold from S$6 million to S$10 million (paras 57, 58). The Court of Appeal’s leading judgments are in the table below, including DJP v DJO on a copied award and Spain v NextEra on an ICSID award against a state.^3,16,28,36

MinLaw consulted on IAA reform from 21 March to 2 May 2025, drawing on a study by the Singapore International Dispute Resolution Academy (SIDRA). The consultation paper asks for views on eight issues (para 4). Among them are a permission requirement for appeals to the Court of Appeal from set-aside decisions, a shorter set-aside time limit, an opt-in appeal on points of law (para 26) and the choice-of-law question above (para 31).^9,10

As of 26 October 2026, MinLaw’s press-release and consultation listings show no bill or published response. We found no Singapore statute called the Arbitration Act 2025; the Act of that name in MinLaw’s paper is the United Kingdom’s (paras 29, 30). The last Act aimed at the IAA itself was the International Arbitration (Amendment) Act 2020. Its Bill was tabled on 1 September 2020 and the Act took effect on 1 December 2020. Singapore Statutes Online lists later amendments made by other Acts, the latest in force from 9 March 2025.^1,9,11,12,13

What does Singapore say about AI in arbitration?

We found no Singapore rule on AI written for arbitration; the guidance that exists, from the courts and MinLaw, covers court users and legal work in general. We found no SIAC rule or guidance on AI as of 21 October 2026, and the SIAC Rules 2025 do not mention it. SIAC’s website showed a bot check, so its own listings could not be read.^3,19,20

The Singapore Courts’ guide on generative AI, meaning AI that produces text or other content on request, has applied since 1 October 2024 to all matters in the Supreme Court, the State Courts and the Family Justice Courts (para 1). It allows AI tools for court documents if the guide is followed, needs no declaration of AI use unless the court asks, and leaves users “fully responsible” for their documents (paras 3(1), 3(3), 5(1)). It does not mention arbitration. Because the SICC is part of the Supreme Court, we infer that it covers set-aside applications there.^20,23

MinLaw’s Guide for Using Generative AI in the Legal Sector (6 March 2026) is non-binding (para 4) and does not mention arbitration either. Speaking at TechLawFest in September 2026, MinLaw’s Senior Minister of State said lawyers remain responsible for what they file (para 44). The speech added that filings citing cases invented by AI, known as hallucination, have reached courts in Singapore and elsewhere (para 45; see false citations). SIMC launched a Mediation AI Assistant in August 2024 (AI in mediation).^17,19,21

DJP v DJO does not mention AI. In our reading, what it says about templates and outside material ([44], [73] to [83]) applies to any drafting aid, AI included. The judgment does not deal with delegation; the separate rule that a tribunal cannot hand its decision to anyone else is explained under non-delegation. For how courts elsewhere have treated AI use, see the Québec annulment in AI in arbitration and our explainer on it.²⁸

In a SIAC case, the tribunal must discuss information security with the parties at the first case management conference and may give directions on it (r 61.2). We suggest raising AI tools in that discussion and recording what is agreed in Procedural Order No. 1; the SIAC Rules do not require this. The AI rules tracker compares SIAC with HKIAC and the ICC Rules 2026.³

What is still open in Singapore arbitration?

• What MinLaw does with its 2025 IAA consultation, including the opt-in appeal on points of law.
• How much an arbitrator may reuse from earlier awards after DJP v DJO ([44], [71]).
• Whether SIAC will publish AI guidance. The courts’ AI guide covers court matters only and does not mention arbitration.
• How a court would treat an award drafted with heavy AI help under the natural justice ground in IAA s 24(b). We found no Singapore case.^1,9,20,28