Model arbitration clauses

The wording of the arbitration clause is of particular importance. Thus, due attention must be devoted to this issue, in order to avoid the risk that the will of the parties to resort to arbitration is not achieved. Several arbitral institutions are aware of this fact. This is the reason why they have prepared model arbitration clauses ready to be used.

Here below, you can find some of these model clauses.

  • Arbitration Institute of the Stockholm Chamber of Commerce (SCC): “Any disputes, controversy or claims arising out of or in connection with this contract, or the breach, termination or invalidity thereof, shall be finally settled by arbitration in accordance with the Arbitration Rules of the Arbitration Institute of the Stockholm Chamber of Commerce” – for other model clauses and further details, please see the SCC’s website;
  • Cairo Regional Centre for International Commercial Arbitration (CRCICA): “Any dispute, controversy or claim arising out of or relating to this contract, or the breach, termination or invalidity thereof, shall be settled by arbitration in accordance with the Rules of Arbitration of the Cairo Regional Centre for International Commercial Arbitration” – for further details, please see the CRCICA’s website;
  • China International Economic and Trade Commission (CIETAC): “Any dispute arising from or in connection with this Contract shall be submitted to China International Economic and Trade Arbitration Commission (CIETAC) for arbitration which shall be conducted in accordance with the CIETAC’s arbitration rules in effect at the time of applying for arbitration. The arbitral award is final and binding upon both parties” – for further details, please see the CIETAC’s website;
  • Curia Mercatorum: “Any dispute arising out of or in connection with this contract shall be finally settled by arbitration in accordance with the Curia Mercatorum Mediation/Arbitration Rules. [OPTIONAL] The proceedings shall be held in ………………… (venue) in ……………………..(language)” – for other model clauses, please see the Curia Mercatorum’s website;
  • European Court of Arbitration (CEA): “Any dispute between the parties relating to or arising from this contract shall be submitted to a procedure of mediation conducted by a sole mediator, appointed and proceeding in accordance with the Mediation Rules of this body by the local branch – if any – of the Mediation Centre for Europe, the Mediterranean and the Middle East having its seat in Strasbourg, which Rules are in force at the date of filing of the application for mediation.
    In the event of the mediation not being successful, the arbitration proceedings will be conducted according to the Rules of the European Court of Arbitration by a sole arbitrator who will be appointed, if the dispute is domestic, by the local Chapter – if any – of the European Court of Arbitration and in the absence of a local Chapter, as well as to all non domestic disputes, by the Central Registrar competent for that area: Strasbourg for Northern and Central Europe and Valencia for disputes between parties belonging to Southern Europe, the Mediterranean and the Middle East (as to France, the Department of Provence, Alpes, Côte d’Azur, les Bouches du Rhône, Var, Roussillon and Languedoc) Portugal, the Balkans, Romania, Bulgaria, Ukraine and in general all the countries of Eastern Europe. Place of Arbitration ________________________. Language of the proceedings _________________
    ” – for other model clauses, please see the CEA’s website;
  • International Chamber of Commerce (ICC): “All disputes arising out of or in connection with the present contract shall be finally settled under the Rules of Arbitration of the International Chamber of Commerce by one or more arbitrators appointed in accordance with the said Rules” – for other model clauses, please see the ICC’s website;
  • Istanbul Arbitration Centre (ISTAC): “Any disputes arising out of, or in connection with the present contract shall be finally settled through arbitration under the Istanbul Arbitration Centre Arbitration Rules” – for further details, please see the ISTAC’s website;
  • Milan Chamber of Arbitration (CAM): “All disputes – included those of not contractual nature – arising out of, related or connected to this agreement shall be settled by arbitration under the Rules of the Milan Chamber of Arbitration (the Rules), by a sole arbitrator / three arbitrators, appointed in accordance with the Rules, which are deemed to be incorporated by reference into this clause” – for other model clauses, please see the CAM’s website;
  • Piedmont Court of Arbitration: “Any dispute arising from this contract shall be subject to binding arbitration (“rituale”) under the Rules of the Piedmont Court of Arbitration. Arbitration shall adopt the ordinary procedure by law or the fast-track (ex aequo et bono) arbitration depending on the value in dispute, as provided for in these Rules” – for other model clauses, please see the Piedmont Court of Arbitration’s website;
  • Russian Arbitration Center: “Any and all disputes, controversies or claims arising out of or in connection with this Contract, or a breach, termination or invalidity hereof, shall be settled by arbitration at the Russian Arbitration Center at the Autonomous Non-Profit Organisation “Russian Institute of Modern Arbitration” in accordance with the Arbitration Rules. The Parties agree that for the purposes of sending written submissions, notifications and other written documents the following e-mail addresses shall be used: [ name of the Party ]: [e-mail address ] [ name of the Party]: [e-mail address ] In the event of change of the e-mail address specified above the Party shall immediately notify the other Party of such change and, if the arbitration has already commenced, also notify the Russian Arbitration Center at the Autonomous Non-Profit Organisation “Russian Institute of Modern Arbitration”. If such notice is not given, the Party failing to give notice shall be responsible for any written submissions, notifications and other written documents being sent to a wrong e-mail address. The Parties hereby agree to be bound by and to execute the arbitral award”; for other model clauses, please see the Russian Arbitration Center’s website;

  • Singapore International Arbitration Centre (SIAC): “Any dispute arising out of or in connection with this contract, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (” SIAC “) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (” SIAC Rules “) for the time being in force , which rules are deemed to be incorporated by reference into this clause. The seat of the arbitration shall be [Singapore]. * The Tribunal shall consist of _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ** arbitrator(s). The language of the arbitration shall be _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ” – for other model clauses and further details, please see the SIAC’s website;
  • Venice Chamber of Arbitration: “All disputes arising out or in connection with this agreement with particular reference to, without limitation, its execution, performance, validity, default, termination and assessment of relevant damages, shall be settled by arbitration under the Arbitration Rules adopted by the Venice Chamber of Arbitration by an Arbitral Tribunal which shall consist of a Sole Arbitrator/three arbitrtors appointed by the Venice Chamber of Arbitration in accordance with those Rules. The Arbitral Tribunal shall decide in accordance with the rules of law of … The seat of the arbitration shall be … The language of the arbitration shall be …” – for other model clauses, please see the Venice Chamber of Arbitration’s website;
  • Vienna International Arbitral Centre (VIAC): “All disputes or claims arising out of or in connection with this contract, including disputes relating to its validity, breach, termination or nullity shall be finally settled under the Rules of Arbitration of the International Arbitral Centre of the Austrian Federal Economic Chamber in Vienna (Vienna Rules) by three arbitrators appointed one or in accordance with the said Rules” – for further details, please see the VIAC’s website.

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