Once an arbitration has been commenced against a respondent, the respondent has a relatively short period of time in which to file an Answer to the Request for Arbitration, which is also called a Response to the Notice of Arbitration or the Answer to the Notice of Arbitration under certain arbitral rules. Under most arbitration rules the respondent has 30 days to file an Answer / Response to the Notice of Arbitration, although short extensions of time are often granted following a reasoned request and there are variations (the LCIA Arbitration Rules, for instance, provide for 28 days to respond).
Answers to Requests for Arbitration or Responses to Notices of Arbitration must include information which is provided for under the rules that are applicable to the dispute. Under most arbitration rules, an Answer or Response to a Request for Arbitration must include the respondent’s name and contact details, the name and contact details of its representative, its preliminary comments on the dispute, its response to the relief sought by the claimant, its observations and proposals concerning the choice of arbitrators, comments on the applicable rules of law and the language of the arbitration and a description of any counterclaims the respondent may have against the claimant. The respondent’s Answer is not a full reply to all particulars of a case, and it generally includes few, if any, supporting documents.
The Aceris International Arbitration Law Firm has provided model Answers to Requests for Arbitration and Responses to Notices of Arbitration under the ICC, LCIA, DIAC, SIAC, HKIAC and UNCITRAL arbitration rules, which are freely available below in both PDF and Word format. Please feel free to make use of these model templates, which make reference to the relevant rules of each arbitral institution, while adjusting them to the particularities of a given case.
Model ICC Answer to the Request for Arbitration
Article 5 of the ICC Rules of Arbitration specifies the required elements of an Answer to an ICC Request for Arbitration. The model Answer to Request for Arbitration, prepared by Aceris Law, is freely available below. It references the relevant ICC Rules of Arbitration in the model text.
Model LCIA Response to the Request for Arbitration
Article 2 of the LCIA Rules of Arbitration sets forth the requirements of the Response to Request for Arbitration. The model LCIA Response to Request for Arbitration available below was prepared by the arbitration law firm Aceris Law and makes reference to the relevant rules and requirements in the model text.
Model DIAC Answer to the Request for Arbitration
Article 5 of the DIAC Arbitration Rules sets forth the information required in a DIAC Answer to Request for Arbitration. The model DIAC Answer to Request for Arbitration was prepared by Aceris Law and makes reference to the relevant provisions in the DIAC Arbitration Rules.
Model SIAC Response to the Notice of Arbitration
The rules concerning a respondent’s Response to a Notice of Arbitration are found in Rule 4 of the SIAC Rules of Arbitration, last updated in 2016. The model SIAC Response to Notice of Arbitration below was prepared by Aceris Law. It references the various Rules which must be respected in the model text.
Model UNCITRAL Response to the Notice of Arbitration
A Response to the Notice of Arbitration must include the elements in Article 4 of the UNCITRAL Arbitration Rules. The model UNCITRAL Response to Notice of Arbitration below was prepared by Aceris Law, making reference to the relevant requirements of the UNCITRAL Arbitration Rules in the model text.
Model HKIAC Answer to the Notice of Arbitration
Article 5 of the HKIAC Administered Arbitration Rules provides the main rules that must be satisfied by a respondent’s Answer to the Notice of Arbitration. The model HKIAC Answer to the Notice of Arbitration below was prepared by Aceris Law. It includes references to the relevant requirements of the 2013 Administered Arbitration Rules in the model text.