If you’ve just been served a Notice of Arbitration
If you’ve landed on this page, you’ve probably just been handed an envelope or an email from SIAC, ICC, HKIAC, or another arbitration institution. The cover letter says you have a deadline. The Notice itself sets out a dispute, the relief the other side wants, and the arbitrator they’ve nominated. The clock is already running, usually 14 days under the SIAC Rules, or 30 days under the ICC Rules.
I’m Wahab. I run A.W. Law LLC in Chinatown. I appear in arbitration proceedings at the Singapore International Arbitration Centre (SIAC) and across the major institutions for international arbitration.
The first 10 minutes of advice are free. Nothing commits you. If your deadline is this week, message us on WhatsApp now and we’ll find time the same day.
What a Notice of Arbitration actually is
A Notice of Arbitration is the document that starts an arbitration. It’s filed by the claimant with the chosen institution (SIAC, ICC, HKIAC, LCIA, AIAC, CIETAC) or served directly under ad hoc rules. The Notice must identify the parties, point to the arbitration clause in the contract, set out the dispute in summary, state the relief claimed, and propose how the tribunal should be constituted.
What the Notice does to you, as a respondent:
- It starts the institution’s clock. Under the SIAC Rules 2025, you have 14 days from receipt to file a Response. Under the ICC Rules, the standard window is 30 days. HKIAC, LCIA, and AIAC have similar windows in the 14 to 30-day range. The exact deadline is on the institution’s covering letter.
- It locks you into the institution. Once the Response is filed (or the deadline passes), the case is administered by that institution under that institution’s rules. The seat of arbitration, almost always set by the contract clause, dictates the supervisory court, the procedural law, and the enforcement regime.
- It puts pressure on tribunal nomination. Most arbitration clauses provide for a sole arbitrator or a three-member tribunal. For a three-member tribunal, the Response is where you nominate your arbitrator. Get the nomination wrong (or miss the window) and the institution appoints for you.
- It opens the window for a jurisdictional challenge. If you think there’s no valid arbitration agreement, or the dispute falls outside the clause, or the claimant has no standing, the objection must be raised at the earliest opportunity — usually in the Response itself. Wait, and the right is usually lost.
The Notice is shorter than a Singapore High Court Writ, but the strategic decisions in the Response (objections, tribunal nomination, counterclaim) shape the entire case to come. The full Statement of Claim and Statement of Defence come later, after the tribunal is constituted.
When the Response window is your only realistic window
There are three things you should think about in the first 48 hours, before the Response window closes:
- Read the arbitration clause and the contract. Most clauses are clean, but some are ambiguous on the seat, the institution, or the number of arbitrators. A poorly-drafted clause is the start of a fight before the real fight, and the Response is where that argument lands. See our notes on SIAC arbitration and broader international arbitration for the institutional context.
- Decide on jurisdictional objections. If you genuinely think SIAC has no jurisdiction (the clause is invalid, the dispute falls outside scope, the claimant has no standing), the objection has to be in the Response. The tribunal then decides its own jurisdiction under the Kompetenz-Kompetenz principle in the International Arbitration Act 1994. Most jurisdictional challenges fail, but the ones that succeed only succeed if raised at the start.
- Decide on a counterclaim. If the claimant owes you money, breached the same contract, or caused you separate loss, the counterclaim usually belongs in the same arbitration. The institution fee scales with the counterclaim’s value, so the costs need to be weighed against realistic recovery. But filing a separate arbitration later is usually more expensive and slower.
If the Notice landed because of an urgent counterparty action (asset dissipation, evidence destruction, a parallel court suit overseas) you may also need to consider an Emergency Arbitrator application of your own. The SIAC Emergency Arbitrator route grants urgent interim relief, including freezing orders and anti-suit relief, within 14 days of filing. For matters that span both Singapore and the UAE, the DIFC Courts route is sometimes the faster path for parallel interim relief.
Our blog on resolving business disputes without going to court in Singapore covers the practical side of choosing arbitration over litigation.
What to expect from a Notice of Arbitration response
How long it takes.
The Response itself is filed within 14 days (SIAC) or 30 days (ICC). Tribunal constitution then takes 6 to 10 weeks. The full Statement of Defence usually falls due 30 to 45 days after tribunal constitution. Document production runs 2 to 4 months after pleadings close. The merits hearing is usually scheduled 6 to 12 months after constitution, and the award follows within 3 to 6 months of the hearing. End-to-end, a standard SIAC arbitration is 9 to 18 months from Notice to final award. The Expedited Procedure compresses this to 6 months from constitution where the sum in dispute is at or below S$10 million.
How much it costs.
The Response phase alone (Response, tribunal nomination, any jurisdictional objection or initial counterclaim) usually runs S$8,000 to S$25,000 in counsel fees, quoted as a capped tranche in writing. The full arbitration, including pleadings, document production, witness statements, and the merits hearing, scales with the claim value and complexity. SIAC’s institution fee and tribunal fee follow a published schedule and are shared with the claimant per the rules. The 10-min Discovery Session is free, and no paid work begins until you’ve seen and accepted the estimate.
What’s hard.
The Response is short, but the strategic decisions in it are heavy. Three things tend to surprise first-time respondents. First, the timeline starts when the Notice is received, not when you read it. Letters can sit in a corporate mailroom for days. Email service runs from the timestamp on the cover email. Second, the arbitrator you nominate matters as much as your counsel. Tribunals usually decide on majority, and the chair’s view often follows the wing-arbitrators’ early signals. Third, document production in SIAC matters is heavier than in a Singapore court action, often run under the IBA Rules on the Taking of Evidence, and a sloppy production response can wreck a strong case.
How we handle Notice of Arbitration responses at A.W. Law
- Same-day or next-day Discovery Session if the deadline is close. Evenings and weekends if needed.
- One director, start to finish. The director who takes your Discovery Session runs the matter through to award.
- Strategy memo before any filing. You get a written read on the clause, the deadline, jurisdictional grounds, tribunal nomination, and counterclaim economics, all before any paid work begins.
- Capped fees, in writing, in three tranches. Response and tribunal nomination; Statement of Defence, document production, and pleadings; hearing and post-hearing.
- Cross-institutional reach. SIAC, ICC, HKIAC, LCIA, AIAC, CIETAC, DIFC-LCIA, and ad hoc UNCITRAL. We co-counsel with foreign firms where local admission is needed.
- WhatsApp evenings until 10pm on weekdays. Useful when the 14-day clock is already half gone.
- Multilingual. English, Malay, or Tamil.
We’re at 133 New Bridge Road, #20-03 Chinatown Point. Two minutes from Chinatown MRT, Exit E.
What happens next
If you’ve been served a Notice of Arbitration and the clock is running, the next step is simple. Book a free 10-min Notice of Arbitration Discovery Session using the form on this page, or message us on WhatsApp using the button anywhere on the screen. Tell us the date of service and which institution filed it. We’ll find time the same day if the deadline is this week.
Nothing commits you. Most sessions end with a short list of things to gather: the Notice, the contract, the clause, the correspondence, and the rough numbers. You’ll leave knowing how many days you have, what the Response needs to cover, whether to challenge jurisdiction, and what a realistic timeline and cost look like for the full arbitration.
