ICDPASO Commercial Arbitration Rules Interpretation Series: Article 4. Arbitration Notice

The "Arbitration Notice" is a formal notification issued by the management body of the arbitration proceedings to all parties involved and the relevant jurisdictional arbitral authority, either upon accepting a case application or when one party explicitly submits the case to the arbitral body as stipulated in the contract. Depending on the circumstances, it may be accompanied by relevant procedural rules and case materials. The " Application for Arbitration " is a written arbitration application material submitted by the parties in accordance with the relevant arbitration clauses of the agreed jurisdiction. The "Arbitration Notice" and the "Application for Arbitration" are two key documents for initiating arbitration proceedings, however, their functions and legal meanings differ. Generally speaking, as a document for procedure commencement, the core function of the arbitration notice is to inform the respondent and the institution that the arbitration proceedings have begun in accordance with the provisions of the arbitration rules; The arbitration application, on the other hand, makes substantive claims outside of the initiation of the arbitration proceedings, including a statement of the facts of the case, arbitration basis, and specific requests. Under the vast majority of international commercial arbitration rules, the Arbitration Notice should be sent directly by the Claimant to the Respondent, while the arbitration application should be submitted by the Claimant to the relevant arbitral management authority or jurisdictional body.In order to efficiently promote the arbitration process and clarify the management functions of the Court of Arbitration, Article 4 of the ICDPASO Commercial Arbitration Rules choose "Arbitration Notice" as a necessary requirement for initiating arbitration proceedings. At the same time, Article 19 of the ICDPASO Commercial Arbitration Rules provides a flexible arrangement that allows for the direct conversion of the Arbitration Notice into an Application for Arbitration, if specific content requirements are met.

This article will be based on the ICDPASO Commercial Arbitration Rules system, deeply analyzing its "Arbitration Notice" system, interpreting the elements that an effective Arbitration Notice under the ICDPASO rules should possess item by item, and further interpreting the institutional logic and institutional value orientation behind the rules, to provide theoretical and practical guidance for practitioners to initiate commercial arbitration.

I. ICDPASO Commercial Arbitration Rules Article 4. Arbitration Notice

Article 4. Arbitration Notice1. The party initiating arbitration (hereinafter referred to as the “Claimant”) shall submit a written Arbitration Notice to the Court of Arbitration and pay the case registration fees in accordance with the Arbitration Fee Schedule of the ICDPASO. The Claimant shall serve a copy of the Arbitration Notice to the Respondent and inform the Court of Arbitration of such service, including the method and date thereof. 

2.  The Arbitration Notice shall generally include:(a) an expression of intention that the dispute be referred to arbitration; (b) the names, addresses, e-mail addresses and other known contact information of the parties and their representatives (if any); (c) a statement of the disputed issue and the claim. If damages are involved, an amount shall be preliminarily estimated and quantified if possible (d) the arbitration agreement on which the arbitration is based, with a copy attached thereto; (e) the contract or other legal documents that cause or are related to the dispute, with copies attached thereto if possible. 

3. If the parties have not reached an agreement in advance on the seat of arbitration, the language of arbitration, the governing law and the formation of the Arbitral Tribunal, the Claimant may put forward the suggestions in the Arbitration Notice.

4. If the Court of Arbitration considers that the Arbitration Notice complies with the provisions of Paragraph 2 of this Article, it shall issue an Acceptance Notice to the parties within ten (10) days from the date of payment of the case registration fees by the Claimant. If the Claimant fails to make payment for the case registration fees at the time of submitting the Arbitration Notice, the Court of Arbitration shall prescribe the time limit for payment; the Claimant’s failure to pay the case registration fees within the aforesaid time limit shall be deemed to mean that the Arbitration Notice has not been submitted. 

5. The arbitral proceedings shall commence upon the date of receipt of the Arbitration Notice by the Court of Arbitration.

II. Analysis of the Significance of the Rule “Arbitration Notice” 

As a necessary prerequisite for initiating arbitration proceedings, the delivery and effectiveness of the Arbitration Notice usually mark the commencementof the arbitration proceedings. Regardless of whether it is institutional arbitration or ad hoc arbitration, the principle of party autonomy is respected in the initiation of arbitration proceedings. Arbitration proceedings must be initiated voluntarily by one party, and the Claimant shall deliver a written Arbitration Notice or arbitration application containing necessary information such as the expression of arbitration intention, arbitration requests, and basis for arbitration to the arbitration institution or the Respondent. The date of receipt of the Arbitration Notice often marks the commencement of the commercial arbitration proceedings in legal terms, thereby interrupting the Limitation Period, clarifying the arbitration basis and scope, and initiating the court proceedings.

As the initial stage of the arbitration proceedings, the standardization and completeness of the Arbitration Notice directly affect whether the arbitration proceedings can be effectively commenced. The Arbitration Notice or arbitration application submitted by the Claimant, as the core legal document, is not only an important basis for determining arbitration jurisdiction, but also constitutes the basis for parties to provide evidence, the Arbitral Tribunal to investigate, hear and even make an award.

The ICDPASO Commercial Arbitration Rules regulate the obligations of the Claimant and the Court of Arbitration in the commencement of Arbitration Proceedings in Article 4 "Arbitration Notice", providing clear guidance for the Claimant to initiate arbitration proceedings and fully reflecting the characteristics of balancing party autonomy and institutional procedural management under the ICDPASO Commercial Arbitration Rules.

III. Analysis of Article 4, paragraph 1: Guidelines for the Claimant to Initiate Arbitration Proceedings

Article 4, paragraph 1 of the ICDPASO Commercial Arbitration Rules specifies the three obligations that the Claimant must fulfill to commence arbitration proceedings: submitting a written Arbitration Notice to the Court of Arbitration and paying the fees, serving a copy of the Arbitration Notice to the Respondent, and providing proof to the Court of Arbitration that the obligation to notify the Respondent has been fulfilled.

This paragraph establishes a parallel service obligation for the Claimant: The Claimant shall serve a copy of the Arbitration Notice to the Respondent at the same time as submitting the written Arbitration Notice to the Court of Arbitration. There are differences between the provisions of various arbitration rules regarding the notification of the Respondent when initiating arbitration. ICDPASO Arbitration Rules and UNCITRAL Rules1 share similar provisions, it is stipulated that the Claimant shall issue the Arbitration Notice to the Respondent. The ICC Rules stipulate that the Claimant shall submit the Request for Arbitration to the ICC Secretariat, and the Secretariat shall notify the Respondent of the receipt of the Request and the date of such receipt.2 The LCIA Rules require the Claimant to submit proof of actual service of copies of the arbitration application to other parties at the same time as filing the arbitration application with the Arbitral Tribunal. If the Claimant is unable to provide actual service as required by the Arbitral Tribunal, sufficient information about other effective forms of notification should be provided as necessary content of the written arbitration application by the parties. 3The SIAC Rules stipulate that the Claimant shall submit the Arbitration Notice to the SIAC master book and send a copy to the Respondent at the same time.4

This paragraph fully embodies the highlight of the "Party Autonomy" of the ICDPASO Commercial Arbitration Rules, strengthens the initiative and procedural guidance rights of the parties in the initial procedural stage, and reflects bottom-up procedural participation; The "dual notification" system ensures the fairness and transparency of the procedure between the parties, providing both parties with an opportunity to mitigate disputes before the formation of the arbitration tribunal. Through document exchanges, it helps both parties to mitigate disputes and restore communication to a certain extent. In practice, the Court of Arbitration will also adopt assistance in delivery to reduce the possibility of malicious delay by one party and help resolve delivery difficulties.According to Article 4, paragraph 1,when submitting a written Arbitration Notice to the Court of Arbitration, the Claimant shall prepay the case registration fees in accordance with the relevant arbitration case fee standards of the dispute settlement organization. However, in accordance with the relevant provisions of Article 4, paragraph 4 and 5, if the Claimant fails to prepay the case registration fees at the same time as submitting the Arbitration Notice, the Court of Arbitration will still give the Claimant a time limit for payment. Therefore, the payment of case fees under the ICDPASO Commercial Arbitration Rules is actually closer to parallel matters than a necessary prerequisite for commencing arbitration proceedings. Its delay will not result in the overall freezing of the arbitration proceedings, thus achieving priority protection of the procedural rights of the parties.In practice, difficulty in delivery is one of the important factors causing delays in arbitration proceedings. Defects in the delivery process often lead to legal risks in the recognition and enforcement of awards. The ICDPASO Commercial Arbitration Rules adopt a rigorous attitude towards the issue of service of Arbitration Notice, requiring the Claimant to explain to the Arbitral Tribunal the statement in which it served the Arbitration Notice to the Respondent, including the date and method of sending it. This regulation aims to safeguard the Respondent's right to be informed of the commencement of arbitration in a timely, and effectively participate in subsequent proceedings. In addition, the date on which the Respondent receives the Arbitration Notice serves as an important time point in the arbitration proceedings, providing a crucial basis for the Court of Arbitration to calculate the Respondent's response period or address any objections to procedural defects, ensuring the stable progress of arbitration proceedings.

IV. Analysis of Article 4, paragraph 2: Defining the Constituent Elements of Arbitration Notice

Generally speaking, to ensure the effective initiation of arbitration proceedings, a written Arbitration Notice should include the following content: (1) a statement of intention to apply for arbitration, indicating that the Claimant intends to submit the dispute to arbitration; (2) The name and contact information of the parties shall be provided to facilitate effective communication and delivery of relevant documents. If the Claimant has authorized a representative, the name and contact information of the representative shall be listed in the Arbitration Notice; (3) The dispute resolution clause is located in a commercial contract or an arbitration agreement separately signed to resolve commercial disputes, to clarify the applicable arbitration rules and other special matters related to the composition of the arbitration tribunal, and to facilitate the institution's confirmation of whether it has arbitration jurisdiction; (4) The specific arbitration request and the relief and damages sought should be preliminarily estimated and quantified as much as possible. A clear arbitration request helps the Respondent understand the specific reasons for the Claimant's initiation of arbitration and engage in targeted communication and defense. In addition, the arbitration request is closely related to the calculation of the subject matter in question, which directly affects important matters such as the composition of the Arbitral Tribunal in subsequent proceedings under some arbitration rules; (5) Any contract or other legal document that causes or is related to a dispute, the contract that causes the dispute is the main basis for confirming the eligibility of the parties. The Claimant provides detailed case materials at the beginning of the arbitration proceedings, which can help the subsequent arbitration tribunal effectively grasp the case and avoid procedural delays caused by the submission of materials in batches.

In addition to the basic content mentioned above, each arbitration rule has made targeted requirements for the content of the Arbitration Notice based on its characteristics. The UNCITRAL arbitration rules do not require the parties to provide a detailed statement of the case at the beginning of the case, they are more principled in their content provisions and give the parties greater flexibility in the early stages of the procedure; The ICC Rules require the listing of multiple arbitration agreements as necessary content for Arbitration Notices5; SIAC has included the Claimant's suggestions for friendly dispute resolution, such as mediation, as optional content in the Arbitration Notice6; The LCIA Arbitration Rules are based on its exclusive power to appoint arbitrators. When the arbitration agreement requires the parties to nominate arbitrators, the LCIA rules stipulate that the Arbitration Notice must include detailed information about the arbitrator.7

Article 4, paragraph 2 of the ICDPASO Commercial Arbitration Rules also specifies the core content required for the Arbitration Notice submitted by the Claimant, but the rules do not impose mandatory requirements on the content, but adopt a suggestive attitude, stating that “the Arbitration Notice shall generally include”. Its purpose is to avoid difficulties in initiating arbitration proceedings caused by the lack of professionalism in the expression of the Arbitration Notice by the Claimant. In conjunction with the subsequent provisions of paragraph 4, the Arbitral Tribunal has the right to conduct a formal examination of whether the content of the Arbitration Notice complies with the provisions of paragraph 2, providing professional guarantees for the initiation of arbitration proceedings.

The ICDPASO rules separate procedural matters from paragraph 2 and provide separate provisions for matters such as fee payment, advice on procedural matters, or proof of service, without the need for the Claimant to raise them together in the Arbitration Notice. This allows the content of the Arbitration Notice to focus on the dispute itself, thereby simplifying the Arbitration Notice, highlighting the core of the dispute, and improving the clarity and efficiency of the arbitration procedure.

In addition, according to Article 19 " Application for Arbitration" of the ICDPASO Commercial Arbitration Rules, " The Claimant may deem the Arbitration Notice referred to in Article 4 of these Rules as an Application for Arbitration, provided that, the Arbitration Notice shall meet the requirements specified in Paragraphs 2 to 3 of this Article", and the contents and accompanying materials that should be included in the arbitration request shall be detailed in paragraphs 2 to 3. This means that the claimant can submit a detailed document in accordance with the requirements of Article 19 when submitting the Arbitration Notice, without the need to resubmit an independent Application for Arbitration within a specific period after the formation of the tribunal. This regulation avoids the applicant from repeatedly investing energy in the arbitration request, and provides explanations and guidance for parties familiar with initiating arbitration applications through the " Application for Arbitration form". It can also promote the arbitration tribunal to enter the trial process as soon as possible, which is a concrete manifestation of the principle of procedural efficiency.

V. Analysis of Article 4, paragraph 3: Non-mandatory Suggestions for Procedural Matters

Commercial arbitration rules usually choose the Claimant's suggestions on the seat of arbitration, language of arbitration, the governing law, and formation of the Arbitral Tribunal as necessary content of the Arbitration Notice, such as the UNCITRAL rules8, ICC Rules9, and LCIA rules10 in accordance with SIAC Rules11. There are corresponding expressions in it. The ICDPASO Commercial Arbitration Rules have made innovative attempts in this regard by separating suggestions on procedural matters from the content that should be included in the Arbitration Notice in Article 4, paragraph 3 of the arbitration rules, giving parties the right to selectively make relevant suggestions in the Arbitration Notice. This is another manifestation of the "Party Autonomy" approach in the ICDPASO Commercial Arbitration Rules.

In international commercial arbitration practice, for parties involved in non-legal factors, the choice of seat of arbitration, arbitration language, the governing law, and other matters often involves multiple considerations, such as politics and diplomacy. These factors are usually difficult to clearly identify at the very beginning of the arbitration procedure, and need to be accompanied by the progress of the arbitration procedure and the evolution of the situation, to customize the case according to needs and gradually choose the most suitable arbitration procedure path.

Making suggestions on procedural matters optional in the Arbitration Notice not only ensures the procedural autonomy and selectivity of the parties, but also narrows down the scope of formal review by the arbitration institution, improves the efficiency of Arbitration Notice review, ensures the rapid development of preliminary arbitration procedures, and achieves a balance between efficiency and fairness. If both parties are unable to reach a consensus, Article 1, paragraph 5 of the ICDPASO Commercial Arbitration Rules grants the Arbitral Tribunal and the Arbitral Tribunal the power to proceed with the proceedings when matters are not clearly specified in the rules, and further specifies the determination of the language and place of arbitration in the “Conduct of the Arbitration “section, giving the Court of Arbitration and the Arbitral Tribunal the power to decide on corresponding procedural matters before and after the formation of the Arbitral Tribunal, ensuring the fairness, neutrality, and smooth progress of the proceedings.

VI. Analysis of Article 4, paragraph 4: Standardize the acceptance procedure of Arbitration Notice by Court of Arbitration

Article 4, paragraph 4 of the ICDPASO Commercial Arbitration Rules clearly stipulates two core issues: firstly, to grant the examination authority to the Court of Arbitration, which shall make a judgment on whether the Arbitration Notice meets the relevant requirements, and issue a notice of acceptance to all parties after the formal examination is approved and the Claimant completes the payment; Secondly, it clarifies the payment related matters and specifies the corresponding legal consequences for the parties who fail to fulfill their payment obligations within the time limit.

Article 4, paragraph 4, first stipulates the conditions and deadline for the Arbitral Tribunal to send acceptance notices to both parties. The prerequisite for the Court of Arbitration to send acceptance notices is that “the Arbitration Notice complies with the provisions of Paragraph 2 of this Article, allowing the Court of Arbitration to examine the Arbitration Notice submitted by the Claimant. At the stage of initiating the arbitration proceedings, this examination is usually only a formal examination, and the jurisdiction over all disputes defined is fully attributed to the Arbitral Tribunal. Its purpose is to assist the Claimant in confirming that their arbitration request can smoothly initiate the arbitration proceedings, and to clearly distinguish the functions of the Court of Arbitration and the Arbitral Tribunal.

After confirming that the arbitration request meets the requirements of the arbitration rules and that the Claimant has completed the payment in accordance with the regulations, the Court of Arbitration shall issue a notice of acceptance to all parties within the prescribed period. This provision innovatively provides a dual guarantee for the conduct of arbitration proceedings, reducing procedural risks arising from unilateral service by confirming to the parties twice that the Claimant has initiated arbitration on the dispute. The Arbitral Tribunal may provide detailed guidance for the parties to participate in the case proceedings through acceptance notices, and attach the “Arbitration Rules” and “List of Arbitrators” to the parties to ensure that the arbitration proceedings comply with international arbitration norms and practices, while also complying the requirements for the application and acceptance of arbitration cases under the "Arbitration Law of the People's Republic of China" – where ICDPASO is registered.

In the initiation stage of arbitration proceedings, if the parties fail to prepay the fees on time, the institution often suspends the trial of the case, and even considers it as the withdrawal of the arbitration request. If the Claimant fails to pay the registration fee in accordance with the LCIA rules, it shall be deemed that the arbitration proceedings have not yet begun.12 ICC Rules13 in accordance with SIAC Rules14, stipulating that if the Claimant fails to pay the arbitration fees within the prescribed time limit, the trial of the case shall be terminated, but it shall not affect the Claimant's ability to initiate arbitration proceedings again.

The ICDPASO Commercial Arbitration Rules provide a limited payment deadline for parties that meet the requirements of paragraph 2. If the payment is not made within the time limit, it shall be deemed that the Arbitration Notice has not been submitted. This provision clarifies that the initiation of arbitration proceedings must meet both the conditions of "Arbitration Notice + payment", focusing on maintaining the rigor and efficiency of the procedure, emphasizing that "full performance of obligations is a prerequisite for the right to initiate", and providing deterministic protection for the parties.

It should be further clarified that ICDPASO implements a phased fee model centered on the parties involved, which does not require a one-time prepayment of all arbitration fees at the time of filing, but instead charges corresponding fees in stages based on the progress of the case to different procedural nodes. This mechanism effectively alleviates the difficulties in initiating procedures in some cases due to the high amount of disputed subject matter and the high payment pressure on the parties involved. At the beginning of the arbitration proceedings, ICDPASO only charges a fixed amount of case registration fee when accepting cases, which will automatically be converted into a prepayment of arbitration fees. This arrangement facilitates the Claimant to flexibly modify the arbitration request during the initiation stage of the procedure, avoiding the cumbersome procedures of fee adjustments and duplicate payments caused by request changes, and effectively improving the efficiency of arbitration.

VII. Analysis of Article 4, paragraph 5: Clarify the criteria for determining the commencement of arbitration proceedings

The commencement date of arbitration proceedings has important legal significance. It is not only the legal starting point for determining multiple procedural time limits, but also causes interruptions in the statute of limitations of arbitration in some jurisdictions. Once the arbitration proceeding begins, important procedural steps such as the time limit for the composition of the Arbitral Tribunal shall be calculated based on this. At the same time, the arbitration institution or tribunal officially acquires jurisdiction over the case from that point.

Most commercial arbitration rules based on the institutional arbitration model stipulate that the date on which the arbitration institution receives the arbitration application shall be deemed as the date of commencement of the arbitration. As stipulated by the ICC rules, the date on which the Secretariat receives the Request shall be deemed to be the date of commencement of the arbitration in all respects15.The SIAC rules stipulate that the date on which the Registrar receives the Notice is the date of commencement of arbitration16. The LCIA rules adopt the standard that the commencement date of arbitration is the actual date on which LCIA receives the registration fee17. At the same time, due to its principle of requiring the submission of arbitration requests and accompanying documents in electronic form, if the Claimant has already paid the registration fee in advance, the arbitration shall be deemed to have begun on the date on which the secretary receives the application electronically. The UNCITRAL rules stipulate that arbitration proceedings shall be deemed to commence from the date on which the Respondent receives the Arbitration Notice, which is a manifestation of its ad hoc arbitration characteristics. In the absence of a permanent arbitration institution, proceedings are usually initiated by the parties serving an Arbitration Notice to the other party18.

The ICDPASO Commercial Arbitration Rules stipulate in Article 4, paragraph 5 that “the arbitration proceedings shall commence upon the date of receipt of the Arbitration Notice by the Court of Arbitration ”, fully respecting the Claimant's autonomy to initiate commercial arbitration. Even if there are difficulties in serving the Arbitration Notice to the Respondent, the arbitration proceedings can still be smoothly initiated. After the arbitration procedure begins, the Court of Arbitration can play a corresponding service guarantee function, provide professional service assistance in the follow-up, and ensure the fair and efficient progress of the procedure. Upon receiving the Claimant's Arbitration Notice, the ICDPASO Court of Arbitration can immediately initiate the service guarantee work for the arbitration procedure, register the case, conduct cost budgeting, preliminarily review the validity and jurisdictional issues of the arbitration agreement, and calculate the deadline to assist in the establishment of the arbitration tribunal, laying a foundation for the efficient operation for arbitration tribunal.

The use of the date of receipt of the Arbitration Notice by the Court of Arbitration instead of the actual payment of the case registration fee as the basis for the commencement of the arbitration proceedings reflects the priority guarantee of the ICDPASO Commercial Arbitration Rules for procedural efficiency, reduces the risk of disputes in determining the starting time of the proceedings, ensures the predictability of legal effects such as the interruption of the arbitration statute of limitations, and avoids procedural delays caused by delayed payment by the parties.

VIII. Conclusions on Article 4: Significance of the Integration and Development Practice of International Commercial Arbitration 

The provisions on "Arbitration Notice" under the ICDPASO Commercial Arbitration Rules reflect its core concept of balancing "flexibility and autonomy" and "efficiency and security". On the one hand, it highly respects the wills of the parties in the arbitration proceedings, provides a wide range of procedural choices, and ensures the smooth commencement of arbitration proceedings. On the other hand, by establishing specific mechanisms such as payment deadlines and requiring Claimants to provide proof of service, the rigor and efficiency of the arbitration procedure are guaranteed, avoiding unnecessary delays caused by "party autonomy" and "procedural rights" exceeding reasonable limits. The ICDPASO Commercial Arbitration Rules regulate the core content of Arbitration Notice and authorize the Court of Arbitration to conduct a formal examination of their contents, which helps to identify procedural risks promptly. It is of great significance for clarifying arbitration jurisdiction, preventing procedural flaws, improving case handling efficiency, and also provides important guarantees for the effective promotion of arbitration procedures.

Based on the aforementioned concept, Article 4 provides clear and explicit behavioral guidance for commercial entities, always adhering to the principle of “Party Autonomy”. It integrates the prevailing norms of international commercial arbitration and makes innovative attempts, ultimately achieving a good balance between party autonomy and efficient procedural norms. If the “dual” notification mechanism is used to effectively safeguard the procedural participation rights of the parties and fully leverage the management and service functions of the Court of Arbitration, Flexible requirements are imposed on procedural matters such as suggestions to facilitate the parties to quickly initiate arbitration proceedings. At the same time, clear regulations are established in other provisions of the arbitration rules to determine key procedural matters, ensuring the organic connection and systematization between the provisions of the arbitration rules and reflecting the inherent logical rigor of the rules.

Overall, the provisions of Article 4 of the ICDPASO Commercial Arbitration Rules align with the positioning of ICDPASO as an international organization and the distinctive features of its one-stop dispute resolution services. Facing parties with diverse backgrounds, ICDPASO not only provides arbitration services, but also prioritizes the efficient initiation of procedures and is committed to responding to the actual needs of the parties. Based on a deep understanding and flexible application of Article 4 of the Arbitration Rules, commercial entities can quickly and effectively initiate arbitration proceedings. This not only lays a solid foundation for commercial entities to timely safeguard their own rights and interests, but also enables parties to fully utilize the flexibility provided by arbitration rules to negotiate and adjust relevant requests and procedural matters in subsequent stages, in order to flexibly respond to complex and changing commercial situations.

1. UNCITRAL Arbitration Rules art. 3.1(2021), which provides that: “The party or parties initiating recourse to arbitration (herein after called the ‘claimant’) shall communicate to the other party or parties (hereinafter called the ‘respondent’) a notice of arbitration.”2. ICC Arbitration Rules art. 4.1(2021), which provides that: “A party wishing to have recourse to arbitration under the Rules shall submit its Request for Arbitration (the ‘Request’) to the Secretariat at any of the offices specified in the Internal Rules. The Secretariat shall notify the claimant and respondent of the receipt of the Request and the date of such receipt.”3. LCIA Arbitration Rules art. 1.1 (2020), which provides that: “Any party wishing to commence arbitration under the LCIA Rules (the ‘Claimant’) shall deliver to the Registrar of the LCIA Court (the ‘Registrar’) a written request for arbitration (the ‘Request’), ...”4. SIAC Rules art. 6.1(2025), which provides that: “The Claimant shall deliver a Notice of Arbitration to the Registrar and the Respondent. Subject to compliance with Rule 4 of these Rules, the Claimant may file the Notice online with the SIAC Secretariat through SIAC Gateway.”5. ICC Arbitration Rules art. 4.3(f) (2021), which provides that: “where claims are made under more than one arbitration agreement, an indication of the arbitration agreement under which each claim is made.”6. SIAC Rules art. 6.4(a) (2025), which provides that: “...any comment on the adoption of amicable dispute resolution methods such as mediation under the SIAC-SIMC AMA Protocol for the settlement of all or part of the dispute.”7. LCIA Arbitration Rules art. 1.1(Ⅴ) (2020), which provides that: “if the Arbitration Agreement (or any other written agreement) howsoever calls for any form of party nomination of arbitrators, the full name, email address, postal address and telephone number of the Claimant’s nominee.”8. UNCITRAL Arbitration Rules art. 3.3(2021), which provides that: “The notice of arbitration shall include the following: ... (g) A proposal as to the number of arbitrators, language and place of arbitration, if the parties have not previously agreed thereon.”9. ICC Arbitration Rules art. 4.3 (2021), which provides that: “The Request shall contain the following information: ... h) all relevant particulars and any observations or proposals as to the place of the arbitration, the applicable rules of law and the language of the arbitration.”10. LCIA Arbitration Rules art. 1.1(Ⅳ) (2020), which provides that: “...a statement of any procedural matters for the arbitration (such as the arbitral seat, the language(s) of the arbitration, the number of arbitrators, their qualifications and identities) upon which the parties have already agreed in writing or in respect of which the Claimant makes any proposal under the Arbitration Agreement”.11. SIAC Rules art. 6.3(g) (2025), which provides that: “...any comment as to the applicable rules of law, seat of the arbitration, language of the arbitration, number of arbitrators, and procedure for the constitution of the Tribunal”.12. LCIA Arbitration Rules art. 1.1(Ⅵ) (2020), which provides that: “...confirmation that the registration fee prescribed in the Schedule of Costs has been or is being paid to the LCIA, without actual receipt of which the Request shall be treated by the Registrar as not having been delivered and the arbitration as not having been commenced under the Arbitration Agreement”.13. ICC Arbitration Rules art. 4.4(2021), which provides that: “...In the event that the claimant fails to comply with either of these requirements, the Secretariat may fix a time limit within which the claimant must comply, failing which the file shall be closed without prejudice to the claimant’s right to submit the same claims at a later date in another Request.”14. SIAC Rules art. 6.6 (2025), which provides that: “If the Registrar determines that the Notice does not comply or substantially comply with any of the requirements under Rule 6.3, or the Claim Filing Fee is not paid upon the ling of the Notice, the Registrar may set a period of time for the Claimant to remedy the deficiency in the Notice or to make payment of the Claim Filing Fee. If the Claimant fails to do so within the period of time set by the Registrar, the Registrar may terminate the arbitration without prejudice to the Claimant ling a Notice in another proceeding.”15. ICC Arbitration Rules art. 4.2(2021), which provides that: “The date on which the Request is received by the Secretariat shall, for all purposes, be deemed to be the date of the commencement of the arbitration.”16. SIAC Rules art. 6.2(2025), which provides that: “The date on which the Notice is received by the Registrar shall be deemed to be the date of commencement of the arbitration. The SIAC Secretariat shall notify the parties of the commencement of the arbitration.”17. LCIA Arbitration Rules art. 1.4(2020), which provides that: “The arbitration shall be treated as having commenced for all purposes on the date upon which the Request (including all accompanying documents) is received electronically by the Registrar (the “Commencement Date”), provided that the LCIA has received the registration fee. Where the registration fee is received subsequently the Commencement Date will be the date of the LCIA’s actual receipt of the registration fee.”18. UNCITRAL Arbitration Rules art. 3.2(2021), which provides that: “Arbitral proceedings shall be deemed to commence on the date on which the notice of arbitration is received by the respondent.”