Singapore has cemented its place as a global leader in arbitration. A recent Global Arbitration Review report has confirmed that Singapore is now the world’s second-most popular location for resolving international disputes, outpacing major hubs like Paris, Hong Kong, Geneva, and New York. Singapore’s reputation for neutrality, a reliable and sophisticated court system, and access to top-tier legal talent all play a role, but the driving force is undoubtedly the Singapore International Arbitration Centre (SIAC).
Since its inception in 1991, SIAC has grown into a leading international arbitral institution. SIAC has also remained committed to continuously adapting and improving its rules, releasing six editions between 1991 and 2016. Now, SIAC has unveiled the 2025 Rules, which apply by default to all arbitrations commenced after 1 January 2025, regardless of when the arbitration agreement was entered into. This latest version, which replaces its 2016 Rules, follows an extensive review process, incorporating feedback from stakeholders around the world. In this post, we break down the key changes in the 2025 SIAC Rules and explain what they mean for businesses and legal professionals.
Ex parte emergency relief (Schedule 1, paragraphs 25-34)
One of the most significant updates in the 2025 SIAC Rules is the provision for ex parte emergency relief. Under the 2016 SIAC Rules, SIAC would appoint an emergency arbitrator (EA) within one day of receiving an application. The EA was then required to deliver an order within 14 days of their appointment. While this process was helpful, it did not address the risk of a party undermining the emergency arbitration by, for example, dissipating assets in anticipation of a dispute.
Under the 2025 SIAC Rules, parties can bring an emergency arbitration and request a protective preliminary order (PPO) to prevent a party from taking action that might “frustrate” the requested emergency relief. Importantly, this application can be made without notifying the counterparty, and an EA must decide the application within 24 hours of their appointment.
This is a significant shift. Previously, parties in need of urgent relief that could not wait two weeks for an EA to deliver its award had to approach a court. However, court proceedings are usually not confidential (see, for example, the recent order of the Singapore International Commercial Court in Novo Nordisk v KBP), and an ex parte order could have serious reputational consequences on the party against whom the relief is obtained. SIAC’s new rules allow parties to obtain the same protection, but with the added benefit of confidentiality.
To prevent abuse, the 2025 SIAC Rules require the party that obtained an ex parte PPO to deliver a copy of the case papers, the PPO, and all other communications to the counterparty within 12 hours. Importantly, parties also have the option to contract out of this provision.
Expedited timeline for submitting awards (Rule 53.1 and 53.2)
There are no fixed timelines for when arbitration awards will be issued. While the complexity of a case naturally affects how long it takes, the efficiency of the arbitrators plays a significant role. Some arbitrators are quick, issuing awards within a few months after the hearing, while others may take a year or more. The 2016 SIAC Rules required tribunals to submit draft awards for review within 45 days of closing proceedings. However, since there was no set deadline for closing proceedings, tribunals often did not do this until just before delivering the award, which could be several months from the final merits hearing.
The 2025 SIAC Rules seek to bring more certainty. Now, tribunals must: (a) provide parties and the SIAC Secretariat with an estimated date for submission of their draft award within 30 days of the last directed submission; and (b) submit the draft award to the SIAC Secretariat for review within 90 days of the last directed submission. Typically, the last directed submission is a cost submission which, in complex arbitrations, tends to be submitted about one to two months after the final merits hearing. Assuming that scrutiny takes about four weeks, the new Rules could theoretically require an award to be issued within five to six months of the final hearing.
In practice, tribunals could extend this timeline by requesting additional written submissions, which would then extend the time for issuing the draft award. Additionally, tribunals handling complex cases may request extensions from SIAC.
Disclosure of third-party funding (Rule 38.1 and 38.3)
Third-party funding, where a third party finances a party’s arbitration, is now common in international arbitration. In 2017, Singapore introduced legislation requiring legal practitioners to disclose the existence of third-party funding to courts or tribunals. However, this requirement applies only to the parties’ counsel; it does not apply to the parties themselves. It also does not apply to non-Singapore based legal practitioners, even if the arbitration were Singapore-seated or conducted under the SIAC Rules.
The 2025 SIAC Rules now mandate parties to disclose the existence, identity, and contact details of any third-party funders (Rule 38.1). This increased transparency aims to reduce conflicts by ensuring that all parties are aware of the third-party funder’s identity. Additionally, Rule 38.3 clarifies that parties cannot enter into third-party funding agreements that may create a conflict of interest with a member of the tribunal.
Coordination of Multiple Proceedings (Rule 17)
Complex cross-border transactions often involve multiple contracts, each with its own dispute resolution clause. While parties can consolidate multiple proceedings, this is often challenging due to stringent rules on the compatibility of arbitration agreements and the different stages of each arbitration.
The 2025 SIAC Rules introduce a new procedure for coordinating separate arbitrations that involve the same tribunal and a common question of law or fact. Tribunals can now direct that these arbitrations be conducted concurrently or sequentially, heard together, suspended pending a determination of other arbitrations, or aligned in any procedural aspects. In line with SIAC’s pledge to bolster procedural efficiency, the introduction of coordinated proceedings in the new Rules minimises duplication of time. This introduction also limits parties’ ability to mount a due-process challenge on account solely of the fact that their arbitration was conducted in a coordinated fashion with another.
Other changes
The 2025 SIAC Rules have introduced several other changes.
- Expedited procedure (Rule 14 and Schedule 3): The threshold for bringing an expedited procedure arbitration, which requires a decision within six months, has been increased from S$6 million (approx. US$4.4 million at the time of publication) to S$10 million (approx. US$7.4 million).
- Preliminary determination of issues (Rule 46): A preliminary ruling on discrete or threshold questions often allows parties to reassess their positions and consider options such as settling their dispute. While tribunals have always had the inherent power to make preliminary determinations, the 2025 SIAC Rules now codify this power by expressly permitting parties to apply for a binding preliminary determination of issues.
- Security for costs and claims (Rule 48 and 49): An order for security for costs protects respondents from frivolous claims by requiring the claimant to provide security for the respondent’s arbitration costs. Conversely, an order for security for claims safeguards claimants from respondents who might, for example, dissipate assets to avoid enforcement of an arbitral award. While tribunals have always had the power to grant such orders, the 2025 SIAC Rules now codify the ability of parties to apply for them, thereby removing any ambiguity about a party’s right to obtain such orders.
