ICC Rules 2026: Bringing In New Procedures, Catching Up With Global Practices And Potential Challenges

A. Introduction

1. The International Chamber of Commerce ("ICC") has introduced the 2026 Arbitration Rules ("2026 Rules") which have officially entered into force from 1 June 2026.¹ The 2026 Rules are applicable to arbitrations commenced on or after 1 June 2026, unless the parties have agreed to submit to the 2026 Rules on an earlier date.² ICC has also released its revised Note to Parties and Arbitral Tribunals on the Conduct of ICC Arbitration dated 1 June 2026 ("ICC Note").³

2. The 2026 Rules represent a significant modernization of the ICC's arbitral framework, introducing new procedures, streamlining existing mechanisms, and embracing technological developments in the conduct of international arbitration.

3. While doing away with the requirement of drawing the "Terms of Reference", the 2026 Rules, inter alia, provide for amended cut-off for new claims; early determination of claims and defences, highly expedited arbitration procedure and changes to emergency arbitration.

4. This article examines the principal changes introduced by the 2026 Rules vis-a-vis ICC's 2021 Arbitration Rules ("2021 Rules") while assessing the practical enhancements and implications of the 2026 Rules. The article also draws a parallel with the 2026 Rules to the recently enforced Singapore International Arbitration Centre Rules 2025 ("SIAC Rules 2025") and Hong Kong International Arbitration Centre (HKIAC) Administered Arbitration Rules 2024 ("HKIAC Rules").⁴ Lastly, the article also explores potential challenges that may be faced by practitioners under the 2026 Rules.

B. Elimination of Mandatory Requirement of the Terms of Reference

5. The most significant change in the 2026 Rules is the elimination of the requirement of establishing the "Terms of Reference" ("ToR"). Under the 2021 Rules and also in the prior versions (from 1975 onwards), the arbitral tribunal was required, upon receipt of the file from the Secretariat, to draw up a document defining its ToR.

6. The ToR, inter alia, comprised of details of the parties along with the arbitrators, summary of claims and reliefs sought by each party together with any quantified amounts, list of issues to be determined, place of arbitration, and the applicable procedural rules.⁵

7. Under the 2026 Rules, this requirement is no longer mandatory.⁶ The initial "case management conference" ("CMC") now serves as the procedural anchor point⁷ as instead of first formulating the ToR, the arbitral tribunal can directly proceed with the initial CMC.

8. Arbitral tribunals are required to hold the initial CMC to consult the parties on procedural measures, within 30 days from receiving the file (extendable)⁸ from the Secretariat. Further, the arbitral tribunals need to, during the CMC or as soon as possible thereafter, establish the procedural timetable.⁹

9. Arbitral tribunals may record, key elements of the arbitration on which the parties have agreed in procedural order no. 1 including, inter alia, (i) identification of the parties; (ii) confirmation of the tribunal's jurisdiction; (iii) applicable law; (iv) any additional elements based on the circumstances of the case.¹⁰ To assist arbitrators and parties, the ICC Secretariat is developing a model procedural order to assess these elements.¹¹

10. Pertinently, the 2026 Rules specifically empower arbitral tribunals to hold further CMCs, as it may deem appropriate, to facilitate the efficient conduct of the proceedings.¹²

11. Elimination of the compulsoriness of the ToR stage, a unique feature of an ICC arbitration, may be considered by some to enhance efficiency by removing a time-consuming formality. However, others may view this as giving rise to a potential challenge as the ToR is served to crystallize the issues in dispute at an early stage. Practitioners would now need to rely more heavily on the CMC and procedural timetable to achieve the same clarity regarding the conduct of the proceedings.

C. The New Claims Cut-Off

12. Closely linked to the elimination of the ToR is the revised mechanism for introduction of new claims. Under the 2021 Rules, no new claims could be introduced once the ToR had been signed or approved by the ICC International Court of Arbitration ("Court") without the authorization of the arbitral tribunal.¹³

13. The 2026 Rules now provide that no party may make new claims after the initial CMC, unless authorized by the arbitral tribunal.¹⁴ In determining whether to allow such new claims, the arbitral tribunal is to consider the nature of the new claims, the stage of the arbitration, any cost implications and any other relevant circumstances.¹⁵

14. This change aligns the cut-off for new claims with the new procedural architecture. A potential challenge is that the initial CMC typically occurs earlier in proceedings than the finalization of the ToR, given that the draft ToR is traditionally deliberated upon and finalized at the CMC itself. As a result, parties may face a shorter window to formulate and assert all claims without requiring leave of the tribunal.

15. However, since the ToR step is not a mandatory step in many other leading institutional arbitration rules,¹⁶ dispensing with its mandatory nature by virtue of the 2026 Rules may be seen as a step towards standardizing international best practices in arbitration, especially towards expeditious resolution.

D. Early Determination

16. In addition to cut-off for new claims, the 2026 Rules introduce a procedure for early determination of claims or defences.¹⁷ Any party may apply to the arbitral tribunal for the early determination of one or more claims or defences on the grounds that (a) they are manifestly without merit or (b) are manifestly outside the arbitral tribunal's jurisdiction.¹⁸

17. For early determination to be effective, parties must apply promptly after relevant claims or defences are filed. The arbitral tribunal may consider all relevant circumstances, including, the current stage of the proceedings and the impact on time and cost efficiency.¹⁹

18. If the arbitral tribunal decides to allow the application, the arbitral tribunal will consult the parties and adopt appropriate procedural measures.²⁰ In the context of arbitrations under the ICSID Arbitration Rules and SIAC Rules, the threshold for "manifestly" has previously been interpreted as a high threshold wherein the power of early dismissal is vested with the arbitral tribunal.²¹

19. This notable addition of early determination of claims mirrors developments in other institutional rules and investment arbitration practice. For instance, Rule 46 of the SIAC Rules 2025 allows preliminary determination of issues, either on an application by the parties or where the tribunal deems fit.²² However, 2026 Rules do not confer powers of early determination of any issues to the tribunal suo motu.

20. Unlike the 2026 Rules, the SIAC Rules 2025 do not prescribe specific grounds where early determination may be permitted. Instead, they broadly require only that the preliminary determination is likely to save time and costs, leading to a more efficient dispute resolution.²³

21. Another distinction is that under the SIAC Rules 2025, the tribunal must determine the issues within 90 days of the application's filing, unless the registrar extends the time.²⁴ However, under the 2026 Rules, the arbitral tribunal is given the discretion to adopt "procedural measures it considers appropriate, after consulting the parties".²⁵

22. This discretionary power of the tribunal under the 2026 Rules yet again may be considered to be antithetical to the very idea behind allowing early determination i.e., expediency and efficiency. On the other hand, practitioners will agree that the complexities involved in applications seeking early determination may provide some flexibility to the tribunals in considering such applications. There is evidence in favour and against both scenarios. Striking balance is the key for the stakeholders.

E. Emergency Arbitration: Elaborating the Scope

23. The scope of the Emergency Arbitrator Provisions, moved from Appendix V to Appendix IV, has also been expanded. Unlike the 2021 Rules, which only bound signatories and their successors,²⁶ the 2026 Rules also apply to parties that are signatories to the arbitration agreement, their successors, or any party which the President determines to be bound by the arbitration agreement.²⁷

24. The 2026 Rules extend the restriction on emergency arbitration to arbitration agreement arising from investment protection laws²⁸ in addition to the restriction on arbitration agreements arising from treaties under the 2021 Rules.²⁹ Further, the 2026 Rules have narrowed the enquiry under the emergency arbitrator's order to "whether the emergency arbitrator has jurisdiction to order Emergency Measures".³⁰ In contrast, the 2021 Rules required the emergency arbitrator to determine both jurisdiction and ³¹

F. Emergency Arbitration: Preliminary Orders

25. In line with the recent developments in other institutional arbitration rules, ICC has introduced 'Preliminary Orders' under the emergency arbitration mechanism. A party may, at any stage of the emergency arbitration proceedings, request a preliminary order directing another party not to frustrate the purpose of the application.³²

26. Such request may be made and decided upon without notice to all other parties.³³ The application and the request for a preliminary order are transmitted to all other parties as soon as the emergency arbitrator has decided on the request and issued the order.³⁴

27. Similarly, Schedule 1 of the SIAC Rules 2025 also lay down a comprehensive mechanism which permit a party to request the appointment of an emergency arbitrator concurrently with the submission of an application for a Protective Preliminary Order ("PPO"), on an ex parte³⁵

28. Upon acceptance of such a request by the President of the SIAC Court of Arbitration, an emergency arbitrator is appointed, who assesses the PPO application and issues a decision within 24 hours of their appointment. The decision on the PPO application is communicated to the SIAC Secretariat, which relays the order to all parties, including the party against whom the PPO has been sought.³⁶

29. Subsequently, the emergency arbitrator also allows all parties, the opportunity to present their case at the earliest possible moment, with the remainder of the emergency arbitration procedure proceeding as usual. Under the SIAC Rules 2025, the PPO expires 14 days after its issuance.³⁷

30. Unlike the SIAC Rules 2025, which provide concrete timelines for the determination and expiry of preliminary orders, the 2026 Rules are less prescriptive. They state only that, if a preliminary order is granted, the emergency arbitrator must "immediately afford all other parties the reasonable opportunity to present their case" and may modify the order accordingly.³⁸

31. This introduction empowers parties to avail quick recourse in cases where the disputes require swift interference. However, the contours of the same are unknown and specific parameters for determining the circumstances warranting such a relief have not been set out in the rules. Nonetheless, this mechanism may reduce parties seeking pre-arbitration ex-parte reliefs from local jurisdictional courts.

G. Highly Expedited Arbitration: A New Procedure

32. The 2026 Rules introduce an entirely new procedure, 'Highly Expedited Arbitration', set out in Appendix VI of the 2026 Rules.³⁹ This procedure applies when all parties consent to its applicability.⁴⁰ Highly Expedited Arbitration Procedure ("HEAP") is an opt-in process available regardless of the claim amount.⁴¹  The Highly Expedited Arbitration provisions contain several distinctive features.

33. In a 'Highly Expedited Arbitration', the dispute is decided by a sole arbitrator.⁴² Unless the parties have jointly nominated the sole arbitrator within 20 days from the respondent's receipt of the Request for Arbitration ("RFA") and statement of claim, the Court is to directly appoint any person it considers suitable.⁴³

34. Joinder of additional parties and consolidation of arbitrations are not permitted.⁴⁴ The arbitral tribunal must render its final award within three months from the date of the initial CMC.⁴⁵ The arbitral tribunal may decide the dispute solely on the basis of documents, with no hearing and no examination of witnesses or experts.⁴⁶

35. A request for 'Highly Expedited Arbitration' must include the claimant's statement of claim accompanied by the evidence relied upon.⁴⁷ The respondent must submit its answer to RFA and statement of defence within 30 days, together with any counterclaim and supporting evidence.⁴⁸

36. No extensions of procedural time limits are granted unless agreed by the parties.⁴⁹ The Highly Expedited Arbitration provisions shall no longer apply if the parties agree or if the Court decides, after consultation, that they should no longer apply and in such case, the Court shall decide whether the arbitration continues under the expedited provisions or the 2026 Rules.⁵⁰ This new procedure may resolve straightforward disputes rapidly and cost-effectively.

H. Enhancements to the Expedited Procedure Provisions

37. The Expedited Procedure Provisions ("EPP"), moved from Appendix VI to Appendix V in the 2026 Rules, have also been revised. The monetary threshold for application has been increased to US$ 4,000,000 for arbitration agreements concluded on or after 1 June 2026.⁵¹

38. For agreements concluded between 1 January 2021 and 1 June 2026, the threshold remains US$ 3,000,000, and for those concluded between 1 March 2017 and 1 January 2021, it remains US$ 2,000,000.⁵² However, if an alternative fee scale applies, the EPP Threshold Amount set in Article 1(3) of Appendix V will be determined basis the Schedule of Fees.⁵³ Further, parties can also decide to opt out of EPP.⁵⁴

I. Other Notable Changes

39. Some other notable changes are:

1. 40. The 2026 Rules mandate electronic communications with the Secretariat as the default⁵⁵ and permit electronic signature of awards, signature in counterparts, and electronic notification.⁵⁶ Deliberations and hearings may now be conducted in hybrid form or by videoconference.⁵⁷
2. Under the 2026 Rules, joinder after tribunal constitution no longer requires the additional party to agree to the ToR (naturally since the ToR is given a go by). Instead, it requires that the additional party to accept the tribunal's constitution and that the tribunal decide to accept the request for joinder, taking into account jurisdiction, timing, conflicts and procedural impact.⁵⁸ This enhances flexibility but raises due process concerns where parties are joined at an advanced stage.
3. Article 44 of the 2026 Rules formally regulates tribunal secretaries, who must satisfy the same independence and impartiality requirements as arbitrators and may not be delegated decision-making authority.⁵⁹ A further layer of transparency is accorded as the appointment must not create additional financial burden on the parties, and direct fee arrangements are prohibited.⁶⁰
4. Under the 2026 Rules, the ICC Court may now decide to proceed with a truncated tribunal "after the last hearing or the filing of the last substantive submissions, whichever is later", rather than only after the closing of the proceedings.^[61] This change is designed to mitigate the risk of delay caused by the death, resignation, or removal of an arbitrator at a late stage of the proceedings, once both parties' cases have been fully presented, thereby preserving procedural efficiency and avoiding the need to revisit completed phases of the arbitration.
5. The Court's extent of scrutiny of the award in the post-hearing stage now expressly extends to the validity and enforceability of the award, in addition to mandatory law at the seat,⁶² broadening the 2021 formulation which referenced only mandatory law.⁶³ This should reduce enforcement risks, though it may add time to the post-hearing phase.

6. In ICC Rules, Article 1(3) of Appendix III of the 2026 Rules stlite that "ICC will accept third-party payments upon receipt of satisfactory evidence of the legal relationship between the mandated third-party payer and the party in the case."⁶⁴ Further, Article 12(6) of the 2026 Rules requires each party to promptly inform the Secretariat, the arbitral tribunal and the other parties of the existence and identity of any non-party that has entered into an arrangement for the funding of claims and defences and under which that non-party has an economic interest in the outcome of the arbitration.

7. The 2026 Rules provide a more proactive framework for disclosures by codifying two principles. First, any doubt as to whether a disclosure should be made must be resolved in favour of disclosure.^[65] Second, a disclosure does not, in itself, establish a lack of independence or impartiality.⁶⁶ These provisions have been introduced in the 2026 Rules to encourage prompt and full disclosure of the facts and circumstances required under Article 12(2). In addition, the 2026 Rules introduce a mandatory procedural step requiring each party to submit to the Secretariat a list of persons and entities that prospective arbitrators should consider for disclosure purposes, together with the reasons for their inclusion.⁶⁷ This would expedite the conflict check process.
8. The 2026 Rules also set out the applicable fees and costs of arbitration in a dedicated Schedule of Fees, enhancing transparency for users.⁶⁸ The Secretary General assumes responsibility for fixing advances on costs and overseeing most financial aspects of the arbitration, with the ICC Court retaining responsibility for the arbitrators' fees and administrative expenses.⁶⁹

J. Further Scope for Amendments

40. Upon comparing the 2026 Rules to the recently introduced and enforced SIAC Rules 2025 and HKIAC Rules, there is some room for enhancements and additions to the ICC Rules, to increase its transparency, efficiency and reliability:

1. 41. Under the SIAC Rules 2025, tribunals are empowered to encourage adoption of mediation at the first CMC,⁷⁰ and to make any directions including a suspension of proceedings to allow parties to adopt amicable dispute resolution methods like mediation at any stage of the arbitration.⁷¹ Additionally, parties are encouraged to consider such amicable dispute resolution methods at the inception of the arbitration.⁷² Interestingly, the Indian Government encourages public sector undertakings to prefer mediation over arbitration in disputes arising out of public procurement contracts.⁷³ Such a provision or suggestion is absent in the ICC Rules.
   
   
2. While the ICC Note under the 'Case Management Techniques' specifies that "the arbitral tribunal may encourage the parties to consider settling all or part of their disputes, either by negotiation or through any form of amicable dispute resolution, such as mediation under the ICC Mediation Rules",⁷⁴ the same has not been formally incorporated into the 2026 Rules. The 2026 Rules may be more readily adopted as the preferred procedural rules by parties, especially in emerging arbitration hubs such as India, if it reflects the policy direction of encouraging mediation at the first stage of dispute resolution. This would enable the parties to settle amicably without incurring the large costs of arbitration wherever possible.
3. The HKIAC Rules also specifically provide for an additional ground for application of the early determination procedure,⁷⁵ where "even if such points of law or fact are submitted by another party and are assumed to be correct, no award could be rendered in favour of that party".⁷⁶ This "no case to answer" or "strike-out" ground has no equivalent in the 2026 ICC Rules, which are limited to claims that are (a) manifestly without merit, or (b) manifestly outside the tribunal's jurisdiction.⁷⁷ Therefore, the ICC Rules may choose to refine the grounds further, referencing the HKIAC Rules.
4. The HKIAC Rules impose a 45-day strict deadline for the tribunal to declare proceedings closed after the last substantive submissions, and a three-month deadline from closure for the tribunal to render the award.⁷⁸Under the 2026 ICC Rules, closure is to occur "as soon as possible",⁷⁹ and the time limit for the final award is fixed by the President based on the procedural timetable, a flexible mechanism with no fixed outer deadline in ordinary proceedings. The ICC Rules may benefit from a strict deadline as it would support ICC's objective to increase efficiency of its mechanism.
5. There are some other notable provisions in the SIAC Rules and HKIAC Rules that are absent in the 2026 Rules, like inter alia, adoption of environmentally sustainable procedures for arbitration,⁸⁰ the registrar being empowered to conduct administrative conference with parties to discuss procedural direction prior to constitution of the tribunal to enhance parties' confidence in the process,⁸¹ the tribunal being permitted to conduct two or more arbitrations concurrently,⁸² broad institutional powers to revoke appointment of any arbitrator,⁸³ and provision for appointment of tribunal secretaries irrespective of either parties' participation.⁸⁴

K. Conclusion

41. The 2026 Rules represent a thoughtful and comprehensive modernization of the ICC's arbitral framework. The elimination of ToR, the introduction of Highly Expedited Arbitration, the formal recognition of early determination applications and of electronic procedures demonstrate the ICC's responsiveness to the evolving needs of international arbitration users. At the same time, the reforms do leave some scope for further refinement with processes in other international institutional arbitration rules that the ICC Rules may benefit from adopting. A note of caution for practitioners as they will need to be alert to the shortened window for new claims, the compressed timelines in expedited procedures, and the due process implications of ex parte preliminary orders.

Footnotes

1. International Chamber of Commerce Arbitration Rules 2026, available at https://iccwbo.org/dispute-resolution/dispute-resolution-services/arbitration/rules-procedure/2026-arbitration-rules/

2. Article 1(2), ICC Rules 2026.

3. Note to Parties and Arbitral Tribunals on the Conduct of ICC Arbitration, 1 June 2026, available at https://iccwbo.org/wp-content/uploads/sites/3/2026/06/2026_ICC_Note-to-Parties-and-AT.pdf

4. Our analysis of the SIAC Rules 2025 can be accessed at -_https://www.mondaq.com/india/trials-appeals-compensation/1572466/siac-rules-2025-new-procedures-increased-efficiency-and-accountability

5. Article 23(1), ICC Rules 2021.

6. In arbitrations under the 2026 Rules, if the parties and the arbitral tribunal decide to establish the ToR, the same will not be transmitted to the Court; Part III : Case Management Techniques, Paragraph I(6)(h), Note to Parties and Arbitral Tribunals on the Conduct of ICC Arbitration, 1 June 2026, available at https://iccwbo.org/wp-content/uploads/sites/3/2026/06/2026_ICC_Note-to-Parties-and-AT.pdf.

7. Article 24, ICC Rules 2026.

8. Article 24(1), ICC Rules 2026.

9. Articles 24(1) and 24(2), ICC Rules 2026.

10. ICC, Unveiling the 2026 ICC Arbitration Rules, part 2: Moving beyond mandatory Terms of Reference, 15 May 2026, available at https://iccwbo.org/news-publications/news/unveiling-the-2026-icc-arbitration-rules-part-2-moving-beyond-mandatory-terms-of-reference/

11. ICC, Unveiling the 2026 ICC Arbitration Rules, part 2: Moving beyond mandatory Terms of Reference, 15 May 2026, available at https://iccwbo.org/news-publications/news/unveiling-the-2026-icc-arbitration-rules-part-2-moving-beyond-mandatory-terms-of-reference/

12. Articles 24(4), ICC Rules 2026.

13. Article 23(4), ICC Rules 2021.

14. Article 25, ICC Rules 2026.

15. Article 25, ICC Rules 2026.

16. The LCIA (London Court of International Arbitration), SIAC (Singapore International Arbitration Centre) rules, UNCITRAL Arbitration Rules, AAA/ICDR (American Arbitration Association), either omit entirely or do not mandate a Terms of Reference step.

17. Article 30(1), ICC Rules 2026.

18. Article 30(1)(a) and (b), ICC Rules 2026.

19. Unveiling the 2026 ICC Arbitration Rules, part 5: Early determination, 27 May 2026, https://iccwbo.org/news-publications/news/unveiling-the-2026-icc-arbitration-rules-part-5-early-determination/ .

20. Article 30(2), ICC Rules 2026.

21. Chapter 11, Early Dismissal of Claims and Defences (SIAC Rule 29), in John Choong, Mark Mangan, et al., A Guide to the SIAC Arbitration Rules (Second Edition) (2018), pages 202 – 213.

22. Rule 46.1 and 46.5, the Arbitration Rules of the Singapore International Arbitration Centre ("SIAC Rules 2025").

23. Rule 46.1, SIAC Rules 2025.

24. Rule 46.4(b), SIAC Rules 2025.

25. Article 30(2), ICC Rules 2026.

26. Article 29(5), ICC Rules 2021.

27. Article 1(2) of Appendix IV, ICC Rules 2026; Unveiling the 2026 ICC Arbitration Rules, part 3: Expedited Procedure Provisions and Emergency Arbitration, available at https://iccwbo.org/news-publications/news/unveiling-the-2026-icc-arbitration-rules-part-3-expedited-procedure-provisions-and-emergency-arbitration/.

28. Article 1(3)(c) of Appendix IV, ICC Rules 2026.

29. Article 29(6)(c), ICC Rules 2021.

30. Article 6(2) of Appendix IV, ICC Rules 2026.

31. Article 6(2) of Appendix V, ICC Rules 2021.

32. Article 7(1) of Appendix IV, ICC Rules 2026; Unveiling the 2026 ICC Arbitration Rules, part 3: Expedited Procedure Provisions and Emergency Arbitration, available at https://iccwbo.org/news-publications/news/unveiling-the-2026-icc-arbitration-rules-part-3-expedited-procedure-provisions-and-emergency-arbitration/.

33. Article 7(1) of Appendix IV, ICC Rules 2026.

34. Article 7(3) of Appendix IV, ICC Rules 2026.

35. Schedule 1, SIAC Rules 2025.

36. Schedule 1(27), SIAC Rules 2025.

37. Schedule 1(31) - 1(33), SIAC Rules 2025.

38. Article 7(4) of Appendix IV, ICC Rules 2026.

39. Article 33, ICC Rules 2026.

40. Article 33, ICC Rules 2026.

41. ICC, Unveiling the 2026 ICC Arbitration Rules, part 4: Highly Expedited Arbitration Provisions, available at https://iccwbo.org/news-publications/news/unveiling-the-2026-icc-arbitration-rules-part-4-highly-expedited-arbitration-provisions/.

42. Article 4(1) of Appendix VI, ICC Rules 2026.

43. Article 4(2) of Appendix VI, ICC Rules 2026.

44. Articles 3(1) and 3(2) of Appendix VI, ICC Rules 2026.

45. Article 7(1) of Appendix VI, ICC Rules 2026.

46. Article 6(3) of Appendix VI, ICC Rules 2026.

47. Article 2(6) of Appendix VI, ICC Rules 2026.

48. Articles 2(5) and 2(6) of Appendix VI, ICC Rules 2026.

49. Article 2(9) of Appendix VI, ICC Rules 2026.

50. Article 1(2) of Appendix VI, ICC Rules 2026.

51. Article 1(3)(c) of Appendix V, ICC Rules 2026; Unveiling the 2026 ICC Arbitration Rules, part 3: Expedited Procedure Provisions and Emergency Arbitration, available at https://iccwbo.org/news-publications/news/unveiling-the-2026-icc-arbitration-rules-part-3-expedited-procedure-provisions-and-emergency-arbitration/.

52. Articles 1(3)(a) and 1(3)(b) of Appendix V, ICC Rules 2026.

53. Article 1(3) of Appendix V, ICC Rules 2026.

54. Article 1(4) of Appendix V, ICC Rules 2026.

55. Article 3(1), ICC Rules 2026.

56. Article 38(1), ICC Rules 2026.

57. Articles 19(3) and 27(1), ICC Rules 2026.

58. Article 8(6), ICC Rules 2026.

59. Articles 44(1) and 44(2), ICC Rules 2026.

60. Article 7 of Appendix III, ICC Rules 2026.

61. Article 16(5), ICC Rules 2026; Article 15(5), ICC Rules 2021.

62. Article 37(3), ICC Rules 2026.

63. Article 7 of Appendix II, ICC Rules 2021.

64. Article 1(3) of Appendix III, ICC Rules 2026.

65. Article 12(2), ICC Rules 2026.

66. Article 12(4), ICC Rules 2026.

67. Article 12(5), ICC Rules 2026.

68. Articles 40-41, Appendix III and Schedule of Fees, ICC Rules 2026.

69. Article 40, ICC Rules 2026.

70. Rule 32.4, SIAC Rules 2025.

71. Rule 50.2, SIAC Rules 2025.

72. Rules 6.4 and 7.3, SIAC Rules 2025.

73. Ministry of Finance, Office Memorandum, Guidelines for Arbitration and Mediation in Contracts of Domestic Public Procurement, available at https://doe.gov.in/files/circulars_document/Guidelines_for_Arbitration_and_Mediation_in_Contracts_of_Domestic_Public_Procurement.pdf

74. Part III: Case Management Techniques, Paragraph I(3), ICC Note.

75. Article 43, HKIAC Rules.

76. Article 43.1(c), HKIAC Rules.

77. Article 30(1)(a) and (b), ICC Rules 2026.

78. Article 31, HKIAC Rules.

79. Article 28, ICC Rules 2026.

80. Rule 32.4(b), SIAC Rules 2025; Articles 13.1 and 34.4(f), HKIAC Rules.

81. Rule 11, SIAC Rules 2025.

82. Article 30, HKIAC Rules.

83. Article 13.10, HKIAC Rules.

84. Rule 24, SIAC Rules 2025.