Model Answer to HKIAC Notice of Arbitration
Updated 5 August 2026
Respondent's formal reply to an HKIAC Notice of Arbitration. Admits/denies the claims, comments on jurisdiction, gives Respondent's account of the dispute, addresses tribunal composition and seat/law/language, and may fold in optional counterclaims and a Statement of Defence
ARBITRATION NO. [INSERT CASE NUMBER AS PROVIDED BY THE HKIAC]
IN THE MATTER OF AN ARBITRATION UNDER THE HONK KONG INTERNATIONAL
ARBITRATION CENTRE ADMINISTERED ARBITRATION RULES
BETWEEN:
[NAME OF CLAIMANT]
(CLAIMANT)
-AND-
[NAME OF RESPONDENT]
(RESPONDENT)
ANSWER TO THE NOTICE OF ARBITRATION
[NOTE: OR ANSWER TO THE NOTICE OF ARBITRATION AND COUNTERCLAIMS, IF APPLICABLE]
[Respondent’s counsel’s law firm]
[Respondent’s counsel’s law firm]
[Respondent’s counsel’s address]
[Respondent’s counsel’s telephone number]
[Respondent’s counsel’s facsimile number]
[Respondent’s counsel’s e-mail]
Counsel for Respondent [Date of the Answer]
[NOTE: Respondent’s Answer must be sent to the Centre within 30 days of receipt of the Notice of Arbitration pursuant to Article 5.1 of the HKIAC Rules]
[NOTE: The Answer to the Notice of Arbitration may include the Statement of Defence referred to in Article 17 if the Notice contained the Statement of Claim referred to in Article 16, pursuant to Article 5.3 HKIAC Rules]
I. INTRODUCTION
1. This Answer to Claimant’s Notice of Arbitration (hereinafter the “Answer”), [OPTIONAL: together with its Exhibits numbered R-1 to R-[•], is submitted on behalf of [Name of Respondent] (hereinafter “Respondent”) pursuant to the Article 5 of the Arbitration Rules of the Hong Kong International Arbitration centre in force as from 1 November 2013 (the “HKIAC Rules”).
2. In this Answer, unless otherwise stated, Respondent adopts the abbreviations used in Claimant’s Notice of Arbitration.
3. Unless otherwise stated, capitalised terms shall have the meanings given to them in the Notice.
4. Unless expressly admitted, each paragraph of the Notice and all of the claims of the Notice are denied by Respondent.
5. Pursuant to Article 5 of the HKIAC Rules, this Answer contains information concerning the following:
i. The name, description and address of each of the Parties (II);
ii. Respondent’s comments as to the Arbitral Tribunal’s jurisdiction (III);
iii. Respondent’s position as regards the nature and circumstances of the dispute (IV);
iv. Respondent’s comments concerning the composition of the Arbitral Tribunal (V);
v. Respondent’s comments as to the place of arbitration, the applicable rules of law and the language of the arbitration (VI);
vi. Respondent’s counterclaim(s) [if applicable] (VII);
vii. Respondent’s position regarding the relief sought by claimant and the relief sought by Respondent (VIII); and
viii. Confirmation of delivery of the Answer to all other parties (IX)
II. THE PARTIES
A. Respondent
NOTE: Article 5.1(a) HKIAC Rules
6. Respondent is [Name of Respondent], a company registered under the laws of [Name of country or jurisdiction], with its registered office located at [Complete address].
Insert brief description of Respondent’s business activity, industry sector, size of business, number of employees, market position, revenue, etc., as relevant.
7. Respondent’s address is:
[Respondent’s name]
[Respondent’s address]
[Attention: name of Respondent’s director]
[Respondent’s telephone number]
[Respondent’s facsimile number]
[Respondent’s e-mail]
8. Respondent’s counsel, to whom all correspondence should be sent in this arbitration, are:
[Respondent’s counsel’s law firm]
[Name of the partner in charge of representing Respondent]
[Names of other lawyers]
[Respondent’s counsel’s address]
[Respondent’s counsel’s telephone number]
[Respondent’s counsel’s facsimile number]
[Respondent’s counsel’s e-mail]
B. Claimant
9. Claimant is [Name of Claimant], a company registered under the laws of [Name of country or jurisdiction], with its registered office located at [Complete address].
Insert brief description of Claimant’s business activity, industry sector, size of business, number of employees, market position, revenue, etc., as relevant.
III. RESPONDENT’S COMMENTS AS TO THE ARBITRAL TRIBUNAL’S JURISDICTION [NOTE: ARTICLE 5.1(B) HKIAC RULES]
10. [Arguments] As a result, an Arbitral Tribunal lacks jurisdiction to hear any dispute between Claimant and [name of Respondent] or any complaints which Claimant purports to have in relation to [name of Respondent].
NOTE: if jurisdiction is contested
IV. THE NATURE AND CIRCUMSTANCES OF THE DISPUTE
NOTE: ARTICLE 5.1(C) OF HKIAC RULES
(a) Factual Background
11.
Explain factual background of the dispute from Respondent’s perspective.
(b) The Parties’ Respective Legal Obligations
12.
Cite and explain relevant contractual or legal provisions
V. RESPONDENT’S COMMENTS CONCERNING THE COMPOSITION OF THE ARBITRAL TRIBUNAL
NOTE: ARTICLE 5.1(E) AND (F) HKIAC RULES
13. In its Notice of Arbitration, Claimant nominated [name of arbitrator] as [Co- Arbitrator / Sole Arbitrator], whose contact information is [insert contact information of arbitrator].
14. Respondent contests the nomination of [name of arbitrator] on the grounds that [arguments].
NOTE: if Respondent contests the Arbitrator nominated by Claimant
15. Respondent nominates [name of arbitrator] to serve as [Co-Arbitrator / Sole Arbitrator], whose details are the following:
[Arbitrator’s name]
[Arbitrator’s address]
[Arbitrator’s telephone number]
[Arbitrator’s facsimile number]
[Arbitrator’s e-mail]
NOTE: ability of Respondent to appoint arbitrator depends on terms of arbitration agreement
VI. RESPONDENT’S COMMENTS AS TO THE PLACE OF ARBITRATION, THE APPLICABLE RULES OF LAW AND THE LANGUAGE OF THE ARBITRATION
(a) The Seat of Arbitration
16.
Insert Respondent’s comments as to the place of arbitration
Respondent may confirm the statement made by Claimant in the Request. In case of non- confirmation, Respondent should state its choice and reasons.
(b) The Applicable Rules of Law
17.
Insert Respondent’s comments as to the governing law
Respondent may confirm the statement made by Claimant in the Request. In case of non-confirmation, Respondent should state its choice and reasons.
(c) The Language of Arbitration
18.
Insert Respondent’s comments as to the language of the arbitration
NOTE: The Answer shall be submitted in the language of the arbitration as agreed by the parties. If no agreement has been reached, the Answer shall be submitted in Chinese or English, pursuant to 5.2 HKIAC Rules
VII. [OPTIONAL] RESPONDENT’S COUNTERCLAIMS
[NOTE: ARTICLE 5.4 HKIAC RULES]
(a) Factual Background to Counterclaims
19.
Explain Claimant’s conduct which gives rise to the counterclaims.
(b) Claimant’s Violations of Its Legal Obligations
20.
Explain basis of Claimant’s liability and include a reference to the relevant contract or legal instruments
(c) Respondent Has Suffered Losses of [amount] for Which Claimant Is Liable
21.
Provide preliminary estimate of Respondent’s losses
VIII. RESPONDENT’S POSITION REGARDING THE RELIEF SOUGHT BY CLAIMANT RELIEF SOUGHT AND RELIEF SOUGHT BY RESPONDENT
NOTE: ARTICLES 5.1(D) HKIAC RULES
NOTE: ARTICLES 5.4(C) HKIAC RULES
22. Respondent rejects Claimant’s claims as set out in its Notice and rejects the relief sought in its Notice.
23. Respondent respectfully requests the Arbitral Tribunal to:
i. dismiss all Claimant’s claims on the ground of an Arbitral Tribunal’s lack of jurisdiction with respect to a dispute between Claimant and [Respondent’s name].
NOTE: in the event that Respondent contests jurisdiction
ii. Dismiss Claimant’s claim in their entirety;
iii. declare that Claimant has violated its obligations under [contract / other basis for liability];
NOTE: if there are counterclaims
iv. order Claimant to compensate Respondent for the damages and losses suffered as a result of Claimant’s conduct, currently estimated to be in the amount of [insert estimation of damages suffered by Respondent];
NOTE: if there are counterclaims
v. order Claimant to pay all arbitration costs, including Respondent’s counsel’s costs and expenses; and
vi. order payment by Claimant of interest at a rate of [insert the interest rate that is arguably applicable] on all of the above amounts as of the date these amounts were due, until the date of their effective payment.
vii. order any further and/or additional relief as the Tribunal may deem appropriate.
24. Respondent reserves its right to further develop its arguments and the amount of relief it is seeking.
IX. CONFIRMATION OF DELIVERY OF THE ANSWER TO ALL OTHER PARTIES
NOTE: ARTICLE 5.1(G) HKIAC RULES
25. Respondent confirms that copies of the Answer and any exhibits have been or are being served simultaneously on the Claimant by [email, in hardcopy or by other means].
Respectfully submitted,
[Signature of Respondent’s Counsel]
[Name of the lawyer representing Respondent]
Counsel for Respondent
[Respondent’s Counsel’s address]
[Respondent’s Counsel’s Telephone]
[Respondent’s Counsel’s Facsimile]
[Respondent’s Counsel’s Email]
[Date of the Answer]
[OPTIONAL] Exhibits submitted with the Answer to the Notice of Arbitration [and Counterclaim(s)]
Exhibit | Exhibit number | |
1. | [•] | R-1 |
About this template
What is this template?
Model Answer to HKIAC Notice of Arbitration is a free, ready-to-use Commercial Contracts template you can open, customize, and download on GitLaw. It gives you a professionally structured starting point, so you never have to draft from a blank page. The wording is plain and modern, organized into clear sections that are easy to read, edit, and adapt to your own situation before you share or sign it.
When should you use it?
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What's typically included?
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