Contract clause
Arbitration clause with a Singapore seat: a SIAC sample
An arbitration clause with a Singapore seat sends disputes under a contract to private arbitration whose legal home is Singapore, so the International Arbitration Act 1994 and the Singapore courts supervise it. Most such clauses adopt the Singapore International Arbitration Centre's rules and its model clause wording.
Choosing Singapore as the seat of arbitration puts a contract's disputes under Singapore's International Arbitration Act, which gives the UNCITRAL Model Law force of law, and under the Singapore courts' supportive supervision. A clause adopting the SIAC rules, one or three arbitrators and English, with the governing law stated separately, is the usual starting point for Asia Pacific deals.
Indunil Asanka · Co-founder
3 min read · Published
Sample clause
Written for supply agreement between Straits Cold Chain Pte Ltd, a fictional Singapore logistics company, and a fictional Jakarta food distributor.
Arbitration. (a) Any dispute arising out of or in connection with this contract, including any question about its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre in accordance with the Arbitration Rules of the Singapore International Arbitration Centre for the time being in force. (b) The seat of the arbitration is Singapore. (c) The tribunal consists of one arbitrator. (d) The language of the arbitration is English. (e) This contract is governed by the laws of Singapore, and this arbitration agreement is also governed by the laws of Singapore. (f) Nothing in this clause prevents a party seeking urgent interim relief from a court of competent jurisdiction.
Sample wording, not legal advice.
Variants
SIAC institutional arbitration
Most cross border commercial contracts with an Asian counterparty, where an established institution administers the case.
Any dispute arising out of or in connection with this contract shall be finally resolved by arbitration administered by SIAC under its Rules for the time being in force. The seat is Singapore, the tribunal has three arbitrators, and the language is English.
Ad hoc arbitration under the UNCITRAL Rules
Parties who prefer no administering institution, often with a state party or where costs are tightly controlled.
Any dispute shall be resolved by arbitration under the UNCITRAL Arbitration Rules. The seat is Singapore, and the appointing authority is the President of the Court of Arbitration of SIAC.
Expedited procedure for small claims
Contracts where most disputes will be modest in value and a fast award matters more than a full process.
The parties agree that the Expedited Procedure in the SIAC Rules applies to any dispute where the amount in dispute does not exceed the limit set in those Rules.
What to negotiate
Seat, not just venue
The seat decides which country's arbitration law applies and which courts can set aside an award; hearings can take place anywhere. Saying arbitration in Singapore without naming the seat invites argument. State the seat expressly, as the sample does, and keep the venue separate if hearings may be held elsewhere.
One arbitrator or three
One arbitrator is faster and cheaper; three suits high value or complex disputes where each side wants to appoint an arbitrator it trusts. Clauses can provide one arbitrator below a value threshold and three above it, or leave it to the rules to decide.
Law of the arbitration agreement
The law governing the arbitration agreement itself can differ from the law of the main contract, and courts in different countries have taken different approaches when the parties say nothing. Naming it expressly, as the sample's sub clause (e) does, removes a common ground for preliminary argument.
The risk of leaving it out
Without an arbitration clause, a dispute between a Singapore company and an Indonesian distributor goes to whichever court will hear it, possibly in a jurisdiction neither side trusts, and a judgment may be hard to enforce across the border. An arbitral award with a Singapore seat is enforceable in the more than 170 countries party to the New York Convention.
The International Arbitration Act 1994
Singapore's International Arbitration Act 1994 governs international arbitrations seated in Singapore and gives the UNCITRAL Model Law on International Commercial Arbitration the force of law, with some modifications. The Singapore courts support arbitration, intervening mainly to assist, for example with interim measures, and to hear limited challenges to awards. The Ministry of Law keeps the Act under review. Law checked on 21 October 2026. This page explains how the law works and is not legal advice.
The choices and what each changes
Seat: the arbitration law and the supervising courts. Rules: who administers the case, how arbitrators are appointed, emergency arbitrators and expedited procedure. Number of arbitrators: cost and speed against perceived fairness on large claims. Language: the cost of translation and the pool of arbitrators. Governing law of the contract and of the arbitration agreement: which law decides the merits and whether the clause itself is valid. Each line in the sample makes one of these choices.
SIAC rules and model clause
The Singapore International Arbitration Centre publishes model clauses and its arbitration rules, which provide for emergency arbitrators, an expedited procedure for smaller claims and consolidation of related cases. Adopting the rules for the time being in force, as the sample does, means the current rules at the start of the arbitration apply. Parties should check the current rules and the model clause wording before signing.
Where the clause sits in a generated document
Master services, supply and distribution agreements carry this clause near the end with governing law. When asking the AI document generator for a cross border contract, name the seat, the rules, the number of arbitrators, the language and the law governing both the contract and the arbitration agreement.
Documents that carry this clause
Master services agreementA data consultancy and an insurer sign this once and then buy work under it for three years. It is the rare contract whose whole purpose is to make the next twenty contracts short.
Distribution agreement template with territory and targetsAn exclusive distribution agreement is a trade: a territory in exchange for volume. This one appoints a New Zealand distributor for a skincare range at 48 per cent of recommended retail, with purchase targets rising from NZD 240,000 to NZD 420,000 across three years, and exclusivity that converts to non exclusive if a target is missed by more than 15 per cent.Questions people ask
What is the SIAC model clause?
A short arbitration clause published by the Singapore International Arbitration Centre that refers disputes to arbitration administered by SIAC under its rules, with blanks for the seat, number of arbitrators, language and governing law. Using it reduces the risk of a defective clause.
Why choose Singapore as the seat?
Singapore has a modern arbitration law based on the UNCITRAL Model Law, courts that support arbitration and rarely interfere with awards, and a large pool of experienced arbitrators. Awards made there are enforceable in New York Convention countries across the region and beyond.
What is the expedited procedure?
A faster track under the SIAC Rules for smaller or urgent disputes, with a sole arbitrator, shorter time limits and often a decision on documents alone. It applies when the parties agree, when the amount in dispute is under the limit in the rules, or in cases of exceptional urgency.
Can a party still go to court for urgent relief?
Yes, most clauses and the rules allow a party to seek urgent interim relief from a court, and SIAC also offers an emergency arbitrator who can grant interim measures before the tribunal is formed. The clause should not exclude either by accident.
Does an Indonesian party have to agree to Singapore?
Yes, arbitration depends on both parties' agreement in the contract. Singapore is often chosen as a neutral seat between parties from different countries. Indonesia is a party to the New York Convention, so a Singapore award can be enforced there through its courts.
Put the clause in a finished document
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Written and checked by the OneCraft team. Last checked .