With Dubai Arbitration Week approaching, the Dubai International Arbitration Centre ("DIAC") will again return to the fore of discussion amongst the arbitration community. As a contribution to the debate around whether DIAC will become a leading international arbitral centre, this article sets out and compares the material provisions of the relatively new DIAC rules ("Rules") against the rules of competitor institutions such as the ICC, LCIA, SIAC, HKIAC, CIETAC, ADCCAC, BCDR, QICCA and SCCA.
Provided with this article are two easy reference comparison tables which juxtapose the rules of various centres on everything from the centre's location, to the commencement of proceedings, to cost allocation. These tables will be especially helpful to legal teams that are grappling with the perennial question from commercial colleagues of "which arbitral institution should we use on this matter", or indeed to commercial colleagues looking to understand or pre-empt their legal team's advice on the choice and/or key differences between competing options.
For ease of comprehension and printing, the comparison is in two parts with the DIAC Rules appearing in each. Part 1 juxtaposes the DIAC Rules with the "Top 5" arbitration centres (ICC, LCIA, SIAC, HKIAC and CIETAC) and can be viewed here. Part 2 covers the other key arbitration rules (ADGM, ADCCAC, BCDR, QICCA, SCCA, SCC, JCAA, ICDR, JAMS and UNCITRAL) and can be viewed here. The tables can of course be joined to enable comparison between any combination of the aforementioned rules.
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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.