Singapore continues to rise as an international dispute resolution hub

New registrar and new rules at SIAC

SIAC appointed Vivekananda Neelakantan as its new registrar, taking over from Kevin Nash, in November 2024. One month later, SIAC’s updated arbitration rules were released. The revised rules went into effect as of 1 January 2025 and were developed following extensive public consultation with SIAC’s users and stakeholders, such as the SIAC Users Council, arbitration practitioners, arbitrators, business entities, government representatives and academics.

The 2025 rules introduce a number of progressive approaches to arbitration, in particular to further enhance efficiency in arbitration proceedings, transparency, and certainty in the timeframe for issuing awards.

Read more of our report on international arbitration in 2025

• International arbitration: regional, sectoral and industry developments reinforce dispute resolution status
• UAE: recent arbitration reforms while legacy DIFC-LCIA clause debate continues
• Saudi Arabia firmly on the map as key arbitration and dispute resolution hub
• New digital services and legal developments boost international arbitration usage in Qatar
• Egypt a ‘central hub’ for arbitration in the MENA region
• Investment disputes continue to drive international arbitration developments in Africa
• Southern African states form harmonised arbitration framework
• UK arbitration developments continue to enhance position as key dispute resolution jurisdiction
• French arbitration law evolves ahead of 2025 reforms
• Germany to become more attractive for international arbitration proceedings
• Singapore continues to rise as an international dispute resolution hub
• Continued improvements in international arbitration driven by new HKIAC rules and case law
• India continues work to modernise arbitration landscape
• Significant developments in Japan’s arbitration landscape
• South Korea strengthens international arbitration framework
• China continues to improve arbitration process efficiency and effectiveness
• Australian court rulings strengthen pro-arbitration stance and expand scope of arbitration
• Construction projects and contracts must consider sanctions risks
• New types of M&A disputes will drive up international arbitration cases
• Growing demand for expertise in cryptocurrency related arbitration in 2025
• Major changes crystallising in investor-state dispute settlement
• What the future holds for mediation in investor-state dispute settlement

A new streamlined procedure for example will help drive cost-effectiveness for small value and straightforward disputes. The 2025 rules codify already existing practices which give extended power to the arbitral tribunal to manage the proceedings in a cost-efficient way, such as preliminary determination and coordinated proceedings. In the case of coordinated proceedings, the changes will facilitate the resolution of complex multi-party multi-contract disputes when consolidation is not possible. The 2025 rules also incorporate SIAC’s newly launched case management platform, the SIAC Gateway, the primary goal of which is to streamline the arbitration process for users.

To enhance transparency, the 2025 rules strengthen the disclosure requirements for third-party funding while allowing extensive powers to the arbitral tribunal regarding sanctions for non-disclosure.

Finally, the emergency arbitrator procedure in the 2025 rules now includes an ‘ex parte’ preliminary protective order application which provides that the emergency arbitrator is required to determine the request for protective order within 24 hours of their appointment. As to timing for rendering awards, users will be pleased to know that the arbitral tribunal is now required to submit its draft award to SIAC within 90 days from the date of the last directed oral or written submission. This ambitious and fixed timeline reflects the institutions’ efforts to achieve better certainty in the arbitration process.

An other important development of SIAC to follow in 2025 is its proposed SIAC Insolvency Arbitration Protocol. The protocol is designed to provide a dedicated procedure to resolve insolvency-related disputes through arbitration at SIAC. Consultation for the proposed protocol closed on 17 January 2025 with the final version expected later this year.

Popularity as a seat

As reflected by the statistics published in SIAC’s 2023 Annual Report, the proportion of international cases filed with SIAC jumped significantly in 2023, with parties from a record number of jurisdictions involved in disputes handled by the centre. Of the 663 new cases filed in that year, 93% were international, which is an increase from 88% in 2022. Parties involved in the cases filed with SIAC in 2023 represented a record 66 jurisdictions.

Greater China including Hong Kong Special Administrative Region (SAR), India and the US emerged as the top three foreign users during the year, followed by UAE, Malaysia, Indonesia, South Korea, Thailand, France and the UK, highlighting SIAC’s broad appeal across continents. Furthermore, in a recent GAR report, Singapore comes just behind London as the second most popular seat for arbitration.

Building strong ties with the Middle East

Statistics also show that parties from the UAE are among SIAC’s most frequent users. The UAE was the fourth largest contributor to SIAC’s caseload with 59 parties in 2023. This is reflective of the growing significance of Gulf-Asia economic ties.

SIAC has also been building its connection with the region. In November 2024, it hosted a conference in Dubai during Dubai Arbitration Week, exploring the role of Singapore and SIAC in resolving disputes between parties from Asia (including India), the UAE and other Gulf Cooperation Council (GCC) countries, while offering strategies for effective dispute resolution arising out of the heightened economic activity between these two regions.

Another key Middle East initiative saw SIAC enter into a memorandum of understanding (MOU) with Abu Dhabi Global Market (ADGM), the international financial centre of the UAE’s capital, Abu Dhabi. Under the new MOU, SIAC and ADGM will promote international arbitration as a preferred method of dispute resolution for resolving international disputes. SIAC and ADGM will explore the possibility of SIAC establishing a presence in ADGM and other collaborative initiatives.

Aside from SIAC, the SICC – which celebrated its 10-year anniversary in January 2025 – is becoming an established hub for international commercial disputes.

The SICC has also been instrumental with strengthening ties with the Middle East over the past year. In particular, in March of 2024 Singapore and Bahrain entered into a bilateral treaty to establish a new Bahrain International Commercial Court (BICC) and designated the SICC to hear appeals from the BICC. Later in the year, the Singapore Government introduced a bill to set up a dedicated international committee at the SICC to hear appeals from specific foreign jurisdictions. Although introduced in the context of the creation of the BICC the role of the committee is wider and envisions further arrangements between Singapore and foreign jurisdictions. The stated goal of the international committee is to increase Singapore’s offering as an international dispute resolution hub.

Case law updates

A number of important court rulings in the past year show that the Singapore courts are confirming their role as a safeguard of the integrity of the arbitration process, while keeping with their minimal curial intervention.

Exclusive right of seat court to set aside arbitration awards

In a post award anti-suit injunction decision (32-page / 293KB PDF), the SICC dismissed an application to set aside an anti-suit injunction relating to a party’s attempt to set aside an award in the Philippines rendered against it in Singapore. The SICC confirmed that only the seat court, in this case the Singapore court, as the supervisory court has the power to set aside an arbitration award. This shows that Singapore courts have a “territorial” approach to enforcement of arbitration awards internationally, as opposed to the “delocalisation” approach endorsed by the French courts.

In addition, the court found the party seeking to have the award set aside in the Philippines in contempt of court for breaching the anti-suit injunction, thereby demonstrating its pro-arbitration stance.

Setting the bar high for jurisdictional objections to the arbitral tribunal

The Singapore High Court has enforced a provisional award rendered under the rules of the DIFC-LCIA arbitration centre, because the respondent in the arbitration had failed to properly raised jurisdictional objections to the arbitral tribunal with respect to an application for interim measures.

In this case, the respondent in the arbitration contested the enforcement in Singapore of a provisional award rendered by DIAC on the basis that the arbitration agreement had referred disputes to arbitration under the DIFC-LCIA Rules, which was abolished and its rights and obligations assigned to the Dubai International Arbitration Centre (DIAC). The judge considered it a “stretch” to say that the parties had intended to accept administration of their dispute under DIAC and noted significant differences between the DIFC-LCIA rules and those of DIAC, suggesting a different approach from the UAE courts. Nevertheless, the court confirmed enforcement of the provisional award because the respondent had failed to make jurisdictional objections to the application for interim measures. Its conclusion may have been different had respondent properly raised jurisdictional objections.

The Court of Appeal affirmed the decision, clarifying that an objection to jurisdiction must be raised in respect of the tribunal’s jurisdiction to hear the interim application itself, a general objection or reservation of rights is unlikely to be sufficient.

Importance of choosing the right arbitrator

Although there is a high threshold for setting aside an award in Singapore, the SICC decided to set aside an ICC award in a case that it described as “unusual and troubling”. The court ordered the award to be set aside for apparent bias and breach of natural justice, because the arbitral tribunal in question had copied and pasted parts of an earlier award rendered in two parallel proceedings, which involved similar issues but different parties and different seats, and the three tribunals were chaired by the same arbitrator.

The court found that the tribunal used an earlier award from the parallel proceedings as a template and “massaged” it into a state where it dealt or at any rate appeared to deal with the issues in the arbitration in question. The court noted that the tribunal failed to focus on the submissions made by the parties and their respective arguments and instead was heavily influenced by the arguments made in the other arbitrations by other parties. Although the arbitration award was set aside, it confirms the pro-arbitration approach of the Singapore courts. The court stressed that it was not the copying and pasting in itself that rendered the award liable to be set aside but the fact that the parties were denied the right to a fair trial. This case illustrates that choosing the right arbitrator is key, as shown in this case, it was difficult for the presiding arbitrator to start afresh with an open mind and ignore any knowledge or opinions accumulated during the parallel proceedings.

Co-written by Scheherazade Dubash and Johanne Brocas of Pinsent Masons