For many parties, initiating ICC arbitration can seem like entering unfamiliar territory. The process is formal and structured, and the term arbitration itself may carry a sense of complexity, especially for those encountering it for the first time. While it is a well-established mechanism for resolving cross-border disputes, the procedural steps that follow the filing of a Request for Arbitration are not always widely understood. Understanding the ICC arbitration process is essential – not only for lawyers but also for clients, in-house counsel, and business leaders who rely on arbitration clauses in cross-border contracts. Clarity around the process matters: it helps parties avoid surprises, make informed strategic choices, and participate effectively at each stage of the proceedings. So, what actually happens once an ICC arbitration is commenced?
This note provides a step-by-step guide through the life cycle of an ICC arbitration – from filing the Request for Arbitration to the issuance and enforcement of the final award. Drawing on practical insights and guidance from the ICC Rules of Arbitration (the “ICC Rules”), we aim to shed light on what really happens behind the curtain.
Filing the Request for Arbitration – Commencement of ICC Arbitration
The commencement of ICC arbitration formally begins with the filing of a Request for Arbitration under Article 4 of the ICC Rules. This is a critical step that initiates the arbitral proceedings and triggers important procedural deadlines.
The Request for Arbitration must be submitted to the ICC Secretariat, and it should include essential elements listed in Article 4(3) of the ICC Rules, such as:
- the full names and contact details of the parties;
- the full names and contact details of the claimant’s representatives;
- a brief description of the dispute;
- the relief sought together with the amounts of any quantified claims and, to the extent possible, an estimate of the monetary value of any other claims;
- any relevant agreements and, in particular, the arbitration agreement(s);
- the proposed number and choice of arbitrators and any nomination of an arbitrator;
- 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.
It is also essential to accompany the Request for Arbitration with proof of payment of the USD 5,000 filing fee, as the arbitration will not proceed without it.
Except for including the above information, the Request for Arbitration does not require the use of a model form.[1] Requests for Arbitration need not contain all supporting documentation either. However, the parties should include a copy of the arbitration agreement based on which the arbitration is commenced.[2]
Initial ICC Review, Notification of the Request to Respondent, the Answer
The ICC will acknowledge a new Request in writing on the day received or the next business day, stating the receipt date as required under Article 4(1) of the ICC Rules.[3] Once the Request for Arbitration is received and deemed complete, the Secretariat notifies the respondent and sets a deadline, typically 30 days, for the respondent to submit an Answer to the Request. As provided in Article 5(1) of the ICC Rules, an Answer shall contain:
- the full names and contact details of the parties;
- the full names and contact details of the respondent’s representatives;
- the respondent’s comments as to the nature and circumstances of the dispute giving rise to the claims and the basis upon which the claims are made;
- the response to the relief sought;
- proposals or observations concerning the number of arbitrator and their choice;
- any observations or proposals as to the place of the arbitration, the applicable rules of law and the language of the arbitration.
As with the Request, the ICC Rules grant the respondent considerable freedom to determine the level of detail with which to present its case in its Answer. In practice, this level of detail may be influenced by that of the Request. The Answer may also include jurisdictional objections or counterclaims. If counterclaims are submitted, the items listed in Article 5(5) of the ICC Rules shall be included. However, the respondent is not barred from introducing additional counterclaims at a later date. Unless the arbitral tribunal directs otherwise, parties are free to make new claims or amend claims already made at any time until the Terms of Reference are drawn up (see below).[4] The claimant shall submit a reply to any counterclaim within 30 days from receipt of the counterclaims communicated by the ICC Secretariat.[5] The Secretariat may extend the time allowed for submitting a reply if the circumstances of the case so require and until such time as the case is transmitted to the arbitral tribunal.
According to the ICC’s practice, if a respondent fails to submit its Answer, the arbitration will nevertheless proceed, which distinguishes ICC arbitration from certain national court proceedings where a lack of response may halt progress. The respondent’s silence, however, does not waive its right to participate in the proceedings, including the appointment of arbitrators at later stages of the proceedings.
Can a Respondent Request An Extension of Time to File an Answer?
Under Article 5(2) of the ICC Rules, the ICC Secretariat may grant an extension of the standard 30-day time limit to submit an Answer, but only if the respondent formally requests it before the original deadline expires. This request must include the respondent’s comments or proposals concerning the number and choice of arbitrators and, if applicable, the nomination of a co-arbitrator. The Secretariat typically grants an initial extension of up to 30 additional days. If the respondent requests more time than that, it must provide compelling justification, and the ICC Secretariat typically seeks the claimant’s comments before deciding.[6] Requests submitted after the deadline are generally rejected; however, they may be referred to the claimant for input before a decision is made.
The ICC Secretariat usually considers a 30-day extension sufficient, given that the Answer can be relatively brief and more detailed arguments can be submitted later in the proceedings. While the ICC Rules do not explicitly cap the duration of possible extensions, requests for significantly longer periods are rarely granted unless exceptional circumstances exist. For example, in complex multi-party cases or where jurisdictional objections are anticipated, more time may be considered, but only with robust reasoning. Importantly, if a respondent fails to submit an Answer on time and does not apply for an extension, the arbitration will still proceed, and tribunals typically allow the respondent to file a defence later in the process.
Provisional Advance on Costs
Right after the filing of the Request, the ICC Court (the “Court“) will require the claimant to pay a provisional advance on costs. Shortly thereafter, in line with Article 37(2) of the ICC Rules, the Court shall fix the advance on costs in an amount likely to cover the fees and expenses of the arbitrators, the ICC administrative expenses, and any other expenses incurred by ICC related to the arbitration for the claims which have been referred to it by the parties.[7] The advance on costs fixed by the Court pursuant to Article 37(2) shall be payable in equal shares by the claimant and the respondent.
This is a key financial step that ensures the institution has the necessary funds to administer the arbitration and compensate the arbitrators as the proceedings unfold. However, the advance is not set in stone. As the case progresses – especially if it becomes more complex or extends in duration – the ICC may adjust the amount and request a supplementary advance on costs.
Importantly, if one party fails to pay, the other party may be invited to make the payment on their behalf. If the required advances are not paid in full, the Court may suspend or terminate the proceedings in whole or in part, as provided under Article 37(6) of the ICC Rules.[8] Many arbitrations have ended because the parties do not make the required payments.
Constitution of the Arbitral Tribunal
One of the most important stages in any ICC arbitration is the constitution of the arbitral tribunal. As discussed in our previous note, “The Importance of Choosing the Right Arbitrator“, who sits on the panel is one of the most important decisions in an international arbitration.
Single Arbitrator vs. Three-Member Tribunal
The ICC Rules allow parties to agree on either a sole arbitrator or a three-member tribunal.[9] If the parties have not agreed in advance, Article 12(2) of the ICC Rules grants the Court discretion to determine the number of arbitrators based on the circumstances of the case, typically taking into account its complexity and value. The ICC Secretariat will first invite the parties to agree on the number, and in the absence of consensus, it will make a recommendation to the Court.
In practice, smaller or less complex disputes are often heard by a sole arbitrator to streamline proceedings and reduce costs.[10] Larger or more nuanced cases may warrant a three-member tribunal, where each party appoints one arbitrator, and the two co-arbitrators jointly select the president of the tribunal. Three-member arbitral tribunals are slightly less likely to render a poor-quality award than sole arbitrators.
Where parties have agreed on a sole arbitrator, they are invited to jointly nominate a candidate. Under Article 12(3) of the ICC Rules, when parties have agreed to refer their dispute to a sole arbitrator, they are encouraged to jointly nominate that arbitrator within a specified time frame set by the ICC Secretariat or agreed upon by the parties. Although the ICC Rules impose a formal time limit for such a nomination, the Court adopts a flexible approach in practice. If the parties fail to meet the deadline but later agree on a joint nomination before the Court has made an appointment itself, the Court will generally accept the late nomination. This flexibility is underpinned by the principle that a joint nomination, even if made after the deadline, constitutes an implicit mutual extension of the time limit by the parties.
In a three-member tribunal, each party nominates one arbitrator.[11] The ICC requires nominations to be submitted along with the Request for Arbitration (claimant) and the Answer (respondent), failing which the Court may appoint one on the party’s behalf. If a party fails to nominate a co-arbitrator, the Court will step in and appoint the arbitrator on the party’s behalf.
Once the two party-appointed arbitrators are in place, they are asked to agree on the president. If they do not reach a consensus within the specified timeframe, the Court intervenes again to make the appointment.[12]
Article 13(1) of the ICC Rules sets out additional factors the Court shall consider when confirming or appointing arbitrators, including the prospective arbitrator’s nationality, residence and other relationships with the countries of which the parties or the other arbitrators are nationals and the prospective arbitrator’s availability and ability to conduct the arbitration in accordance with the ICC Rules.
After the Arbitral Tribunal Is Constituted
Once the arbitral tribunal or sole arbitrator is formally in place, the actual arbitration commences. After the tribunal is confirmed, the first practical step is typically an introductory communication between the tribunal (or sole arbitrator) and the parties. This is often done through a letter or email to initiate discussion about the next procedural steps and to propose a preliminary meeting or conference. This communication sets the tone for the proceedings and typically includes an invitation for an initial case management conference call (today, usually held by Microsoft Teams or Zoom), allowing the parties to cooperate in drafting the Terms of Reference.
The tribunal then usually schedules the initial case management conference, proposes procedural timelines, and addresses any logistical preferences. It is an opportunity to align expectations early and encourage procedural efficiency. A case management conference is also an excellent opportunity to ensure the parties’ expectations are aligned from the outset.
Terms of Reference (ToR) in ICC Arbitration
One of the most distinctive features of ICC arbitration is the requirement that the parties and the tribunal jointly draft a Terms of Reference.[13] This document outlines the essential details of the case, including the names of the parties, a summary of the claims and relief sought, a list of issues, and the procedural rules that will govern the arbitration (Article 23 of the ICC Rules).
The Terms of Reference must be established within 30 days from the transmission of the file to the arbitral tribunal (Article 23(2) of the ICC Rules)[14]. Terms of Reference are not required in arbitrations under the Expedited Procedure Provisions.
Once the Terms of Reference have been signed by all members of the arbitral tribunal and all parties, the arbitral tribunal is required to submit the signed version to the Court. This is in accordance with Article 23(2) of the ICC Rules, which ensures procedural integrity and formal record-keeping.
Article 23(3) authorises the Court to validate the Terms of Reference even if one or more parties refuse to sign or do not participate in the proceedings. This provision ensures that the Terms of Reference can still be formally acknowledged and take effect, thereby allowing the arbitration to move forward.
Procedural Timetable and Case Management Conference in ICC Arbitration
Alongside the Terms of Reference, the tribunal and parties typically agree on a procedural timetable. This is typically formalised in the form of a procedural order, which addresses issues such as:
- The format and schedule for written submissions;
- Rules on document production and confidentiality;
- Hearing dates (if any); and
- Use of virtual platforms or hybrid arrangements.
The ICC encourages the tribunal to conduct a case management conference to tailor the procedure to the case’s specific needs, promoting cost and time efficiency.[15] These conferences are collaborative and aim to prevent disputes over the procedure in the future.
The Written Phase of the ICC Arbitration Proceedings
With the Terms of Reference signed and a procedural timetable in place, the arbitration moves into its most substantive stage: the written phase. This is where each party presents its case in detail, supported by evidence, legal arguments, witness statements, and expert opinions, as applicable. Though this phase is often conducted entirely in writing, it plays a critical role in shaping the tribunal’s understanding of the dispute. It is said that most cases are decided prior to oral hearings being held, based on the written phase of the proceedings.
Submissions, Witness Statements, and Expert Reports
The written phase usually begins with the Statement of Claim from the claimant, followed by the Statement of Defence and Counterclaim (if applicable) by the respondent. These may be supplemented by replies and rejoinders, depending on the procedural calendar agreed upon.
Typically accompanying these submissions are witness statements – written declarations from individuals with firsthand knowledge of relevant facts – and expert reports, which offer specialised opinions on technical, financial, or industry-specific issues. The timing for filing these is typically synchronised with the parties’ submissions. For example, witnesses supporting the Statement of Claim will file their statements at the same time, with rebuttal witnesses appearing during the rejoinder stage. In some cases, particularly before tribunals with a common law background, witness statements and expert reports may be filed in a separate evidentiary phase, distinct from the main written submissions. This procedural detail should be discussed and agreed upon as early as possible in the arbitration, ideally during the negotiation of the procedural timetable.
Documentary Evidence and Document Production
Documentary evidence plays a vital role in establishing facts in the majority of ICC arbitrations. The process generally permits each party to submit documents that support their claims. These documents are usually submitted alongside the party’s written submissions prior to the hearing.
Beyond the documents already in a party’s possession, the procedure may also provide for requesting the production of documents held by the opposing party. However, it is important for both parties and the arbitral tribunal to recognise that document production is not a standard requirement in every case. Practices surrounding document production can vary significantly due to differing legal traditions, which are often reflected in the backgrounds of the arbitrators, parties, and their legal counsel.
Therefore, unlike some domestic court systems, ICC arbitration does not involve broad discovery. Instead, document production is targeted and controlled, often based on the IBA Rules on the Taking of Evidence in International Arbitration or custom case management orders. This is also one of the major points of discrepancy between common and civil lawyers (see Cross-Cultural Differences and Impact on Arbitration Procedure).
In ICC arbitrations, document production is often conducted as a separate phase between the submission of the Statement of Defence and the Reply. Most tribunals adopt standardised formats for managing these requests, commonly using the Redfern Schedule or the Stern Schedule, which allow parties to organise their requests, objections, and tribunal decisions in a structured, transparent manner. If a separate document production phase is included, each party may request documents from the other side by specifying:
- the category of documents;
- their relevance to the case;
- their materiality to the outcome.
The other party may object, and the tribunal decides whether the documents must be disclosed. The goal is a balanced process that ensures access to key documents without opening the floodgates to fishing expeditions.[16] In some cases, tribunals also allow for confidentiality protections or redactions.
Hearing (If Any)
Once the written phase is complete, many arbitrations proceed to an oral hearing at which the tribunal hears oral arguments, examines witnesses, and clarifies factual or legal issues. While not mandatory in every case, especially in smaller and less complex arbitrations, hearings are a common feature of most ICC arbitrations.
In practice, all important decisions in relation to hearings are typically made after due consultation with the parties. The arbitral tribunal will normally attempt to accommodate the parties’ preferences and, if they are divergent, balance them.[17]
Duration and Organisation of the Hearing
ICC hearings typically last anywhere from one to several days or even a couple of weeks, depending on the complexity of the case and the number of witnesses and/or experts to be examined. The tribunal, in consultation with the parties, will set the hearing dates and allocate time for opening submissions, cross-examinations, expert hot-tubbing (if used), and closing arguments (if any).
In advance of the hearing, the tribunal often issues a procedural order outlining the hearing agenda, sequence of witnesses, logistical arrangements, and rules of conduct. Pre-hearing conferences may also be held to confirm final details and resolve any outstanding procedural issues. [18]
Purpose of the Hearing
The primary function of the hearing is to allow the tribunal to:
- test the credibility of witness and expert testimony;
- clarify ambiguities in written submissions;
- assess the strength of each party’s arguments in real-time.
Unlike traditional litigation, arbitral hearings are generally less adversarial and more focused on cooperative fact-finding. Counsel are encouraged to be succinct and strategic, especially given that hearing time is often divided equally between the parties.
In-Person, Virtual, or Hybrid Hearings
Since the COVID-19 pandemic in 2020, ICC arbitrations have embraced hybrid and virtual hearings, offering flexibility and cost savings. A hybrid hearing may involve the tribunal and some participants convening in person, while others join remotely via secure video conferencing platforms.
While in-person hearings remain preferred for high-stakes or witness-heavy cases, hybrid formats are now widely accepted and often used when parties or arbitrators are based in different jurisdictions. The ICC provides protocols to ensure due process and confidentiality are maintained, regardless of format.
While hearings are often associated with the designated place or seat of arbitration, they do not have to be held there. If the parties and the tribunal agree, hearings can take place at any location that is mutually convenient, whether for logistical, practical, or cost-related reasons.
After the Hearing: Post-Hearing Briefs and Costs Submissions
Once the hearing concludes, the arbitration process enters its final stretch, but several important steps still remain before the tribunal issues its award.
Post-Hearing Briefs
In many ICC arbitrations, the parties agree to submit post-hearing briefs – written submissions that summarise their arguments, highlight key evidence, and respond to points raised during the hearing. These briefs enable parties to reinforce their positions with the benefit of hindsight, often focusing on legal nuances, damaging admissions, or other relevant points that arose during the hearing.
The tribunal will usually fix a deadline for these briefs during or shortly after the hearing. Sometimes, a second round of reply briefs may also be permitted. The goal is to give the tribunal a clear and concise roadmap before deliberations begin.
Costs Submissions
After or alongside the final briefs, the parties also normally file their cost submissions. Each party is typically invited to file a statement of its legal and arbitration-related costs, including counsel fees, expert fees, and disbursements, along with arguments on how the costs should be allocated between the parties.
Under the ICC Rules, the tribunal has the discretion to allocate costs in the final award. It may order one party to bear all or part of the other party’s costs, depending on factors such as the outcome of the case, the parties’ conduct, and procedural efficiency.[19]
Closing of the Proceedings, Deliberations, and Final Award
After all submissions have been made and the hearing (if any) concludes, the arbitral tribunal turns to the task of deliberation and drafting the final award. As provided in Article 27 of the ICC Rules, “[a]s soon as possible after the last hearing concerning matters to be decided in an award or the filing of the last authorized submissions concerning such matters, whichever is later, the arbitral tribunal shall: a) declare the proceedings closed with respect to the matters to be decided in the award; and b) inform the Secretariat and the parties of the date by which it expects to submit its draft award to the Court for approval pursuant to Article 34.”
Article 27 serves to formally conclude the evidentiary and submissions phase, after which no party may present further submissions without the express permission of the arbitral tribunal.[20]
The deliberation process, though often invisible to the parties, is where decisions are made, claims are weighed, and legal reasoning is carefully shaped. The deliberation process is strictly confidential and conducted among the tribunal members only. In three-member tribunals, the arbitrators engage in a collegial discussion to reach a consensus or, at the very least, a majority agreement on the outcome of the case. They assess the written evidence, witness testimony, legal arguments, and applicable law to arrive at their conclusions.
The length of deliberations varies depending on the case complexity, but the tribunal is expected to proceed diligently and without undue delay. ICC tribunals are encouraged to provide an indicative timeline during earlier case management discussions to keep parties informed of expected timing. The Secretariat’s Guide to ICC Arbitration notes that arbitrators are strongly urged to set aside sufficient time for deliberations and writing awards. They must also notify the Secretariat of any known obstacles or delays that could affect the timely submission of the award, as well as any alteration to the expected submission date.[21]
Scrutiny of the Final Award by the Court
Before the award is issued, a unique feature of ICC arbitration comes into play: ICC Court scrutiny. Under Article 34 of the ICC Rules, the draft award must be submitted to the Court for review and approval.
The Court’s review of draft awards may involve a range of interventions, from correcting typographical errors, clerical oversights, and computational mistakes to more substantive observations that can necessitate redrafting parts or even the entirety of the award. Although the general quality of draft awards submitted for scrutiny is high, issues can occasionally arise, particularly in cases involving inexperienced, overextended, or inattentive arbitrators. This review serves a critical preventive function, helping to avoid future delays and expenses associated with correction or interpretation applications under Article 36 of the ICC Rules, especially when defects are identified shortly after the award is issued. More significantly, scrutiny helps mitigate the risk of annulment or non-enforcement of an award due to serious flaws.[22] The Court may propose modifications to the form or even substance (with the tribunal’s consent), which helps reduce the risk of enforcement challenges under the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (the “New York Convention”). Under Article 7 of Appendix II to the ICC Rules (International Rules of the International Court of Arbitration), the Court’s scrutiny also takes into account, to the extent practicable, any mandatory legal requirements applicable at the place of arbitration.
Issuance of the Final Award
Once approved, the final award is signed and formally notified to the parties by the Secretariat, both via email and by courier. ICC tribunals are encouraged to issue the final award within six months of the Terms of Reference being signed; however, this timeline can and frequently is extended, depending on the circumstances.[23] This is expressly set out in Article 31(1), which stipulates that “[t]he time limit within which the arbitral tribunal must render its final award is six months. […] The Court may fix a different time limit based upon the procedural timetable established pursuant to Article 24(2).”
The award is binding on the parties and typically includes:
- the tribunal’s reasoning and findings;
- a ruling on liability and quantum;
- allocation of arbitration and legal costs.
Limited post-award remedies are available under Article 36 of the ICC Rules. A party may request:
- correction of typographical or computational errors;
- interpretation of ambiguous parts of the award; or
- an additional award on claims raised but not decided.
These remedies are strictly procedural and do not allow a re-litigation of the merits.[24] As commentators note, if Article 36 were used as an attempt to appeal the tribunal’s decision on the merits, this would undermine the finality of ICC awards.[25] Requests must typically be filed within 30 days of receiving the award.[26] Hence, while parties may request corrections of clerical errors or interpretation of parts of the award under Article 36, no appeal mechanism is provided for within the ICC framework.
Enforcement & Challenges
Once the final award is rendered, the arbitration officially comes to an end – but for the prevailing party, the next step may involve enforcement. Thanks to the New York Convention, ICC awards are enforceable in over 170 jurisdictions worldwide. This gives parties a powerful tool to convert their award into a court judgment if the losing side fails to comply voluntarily.
While enforcement is generally straightforward, challenges can and do frequently arise in practice.[27] In theory, national courts may refuse enforcement only on narrow grounds, such as a lack of jurisdiction, procedural irregularities, or public policy violations, under Article V of the New York Convention. In practice, however, enforcement is not always straightforward and largely depends on the jurisdiction where the losing party’s assets are located. Local legal systems, procedural requirements, and courts’ attitudes toward foreign arbitral awards can all influence the ease and effectiveness of enforcement.
Conclusion
At first, ICC arbitration might seem complex, but a closer look shows it to be a well-organised and internationally trusted process. From submitting the Request for Arbitration to forming the tribunal, setting the procedure, holding hearings, and ultimately receiving the final award, each step is carefully designed to ensure fairness, transparency, and enforceability.
When parties understand how ICC arbitration works, whether it involves handling procedural case management conferences or hearings, they are better equipped to navigate the process with confidence. Most importantly, arbitration provides what many national court decisions lack: a final and binding decision that can, at least in theory, be enforced in over 170 countries under the New York Convention.
[1] For those seeking a template to guide the preparation of a Request for Arbitration, sample forms – such as this one – can be a helpful starting point.
[2] Article 4(3)(e) of the ICC Rules.
[3] J. Fry, S. Greenberg, F. Mazza, The Secretariat’s Guide to ICC Arbitration (2012), para. 3-108.
[4] Id. para. 3-175.
[5] Article 5(6) of the ICC Rules.
[6] J. Fry, S. Greenberg, F. Mazza, The Secretariat’s Guide to ICC Arbitration (2012), paras. 3-139 to 3-143.
[7] Article 37(2) of the ICC Rules.
[8] Article 37(2) of the ICC Rules; J. Fry, S. Greenberg, F. Mazza, The Secretariat’s Guide to ICC Arbitration (2012), paras. 3-1407 to 3-1406.
[9] For more tips on how to decide between the single arbitrator and a three-member tribunal, refer to Aceris Law’s website: The Choice Between One and Three Arbitrators.
[10] J. Fry, S. Greenberg, F. Mazza, The Secretariat’s Guide to ICC Arbitration (2012), paras. 3-431. 3-435 to 3-442.
[11] Article 12(4) of the ICC Rules.
[12] Article 12(2) of the ICC Rules.
[13] G. Born, Chapter 8: Procedural Issues in International Arbitration (Updated November 2023), in International Commercial Arbitration (3rd edn., 2021), §8.06[K].
[14] ICC Note to Parties and Arbitral Tribunals (2021), Section VII(F), para. 126(a).
[15] Article 24 of the ICC Rules; see also ICC Note to Parties and Arbitral Tribunals (2021), Section VII(F), para. 126(b).
[16] Tribunals are encouraged to use case management tools such as Redfern Schedules for document production and to limit such requests to those that are strictly necessary. See Appendix IV to the ICC Rules and ICC Note to Parties and Arbitral Tribunals (2021), Section VII(B).
[17] For more information on what to expect from the Arbitration Hearing, visit the Aceris Law website: What to Expect from an Arbitration Hearing.
[18] Appendix IV to the ICC Rules identifies various case management techniques aimed at improving efficiency. One such technique includes organizing a pre-hearing conference with the arbitral tribunal, during which arrangements for the hearing can be discussed and agreed upon, and the tribunal may indicate specific issues it wishes the parties to focus on during the hearing.
[19] Article 38(5) of the ICC Rules.
[20] J. Fry, S. Greenberg, F. Mazza, The Secretariat’s Guide to ICC Arbitration (2012), para. 3-1018.
[21] Id. para. 3-1022.
[22] Id. paras. 3-1181 to 3-1182.
[23] Id. para. 3-1107.
[24] G. Born, Chapter 24: Correction, Interpretation and Supplementation of International Arbitral Awards (Updated November 2023), in International Commercial Arbitration (3rd edn., 2021), §24.03[C]; see also Correction of Arbitral Awards in ICC Arbitration.
[25] B.W. Daly, Correction and Interpretation of Arbitral Awards under the ICC Rules of Arbitration (Vol. 13, No. 1), ICC Bull. 61, pp. 62-63.
[26] Article 36(2) of the ICC Rules.
[27] See Recognition, Enforcement and Execution in International Arbitration.