Model SIAC Response to Notice of Arbitration
Updated 5 August 2026
This template provides a structured format for a respondent to answer a Notice of Arbitration under the SIAC Rules. It includes sections for addressing jurisdiction, the nature of the dispute, arbitrator nominations, and any potential counterclaims. Use this to ensure all procedural requirements of the Singapore International Arbitration Centre are met within the required 14-day response window.
ARBITRATION NO. [INSERT CASE NUMBER AS PROVIDED BY THE SIAC REGISTRAR]
IN THE MATTER OF AN ARBITRATION UNDER THE ARBITRATION RULES OF THE SINGAPORE
INTERNATIONAL ARBITRATION CENTRE
BETWEEN:
[NAME OF CLAIMANT]
(CLAIMANT)
-AND-
[NAME OF RESPONDENT]
(RESPONDENT)
RESPONSE TO THE NOTICE OF ARBITRATION
[NOTE: OR RESPONSE TO THE NOTICE OF ARBITRATION AND COUNTERCLAIMS, IF APPLICABLE]
[Respondent’s representative’s law firm]
[Respondent’s representative’s law firm]
[Respondent’s representative’s address]
[Respondent’s representative’s telephone]
[Respondent’s representative’s facsimile number]
Legal representative for Respondent [Date of the Response]
NOTE: Respondent’s Response must be sent to the Claimant within 14 days of receipt of the Notice of Arbitration pursuant to Article 4.1 of the SIAC Rules
I. INTRODUCTION
1. This Response to Claimant’s Notice of Arbitration (hereinafter the “Response”), OPTIONAL: together with its Exhibits numbered R-1 to R-[•], is submitted on behalf of [Name of Respondent] (hereinafter “Respondent”) pursuant to Article 4.1 of the Arbitration Rules of the Singapore International Arbitration Centre in force as from 1 August 2016 (the “SIAC Rules”).
2. In this Response, 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.
NOTE: Article 4.1(a)
5. Pursuant to Article 4.1 of SIAC Rules, this Response 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) (VII);
NOTE: if applicable
vii. Relief sought (VIII); and
viii. Respondent’s payment of requisite filing fee (IX)
II. THE PARTIES
A. Respondent
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 representative, to whom all correspondence should be sent in this arbitration, are:
[Respondent’s representative’s Law Firm]
[Name of the Partner in charge of representing Respondent]
[Names of other lawyers]
[Respondent’s representative’s address]
[Respondent’s representative’s Telephone number]
[Respondent’s representative’s Facsimile number]
[Respondent’s representative’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
10. [Arguments] As a result, the 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 4(1)(B) SIAC 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
(a) Respondent Has Suffered Losses of [amount] for Which Claimant Is Liable
13.
Provide preliminary estimate of Respondent’s losses
V. RESPONDENT’S COMMENTS CONCERNING THE COMPOSITION OF THE ARBITRAL TRIBUNAL
[NOTE: ARTICLE 4(1)(C) AND (D) SIAC RULES]
14. In its Notice of Arbitration, Claimant nominated [name of arbitrator] as [Co- Arbitrator / Sole Arbitrator], whose contact information is [insert contact information of arbitrator].
15. Respondent contests the nomination of [name of arbitrator] on the grounds that [arguments].
NOTE: if Respondent contests the Arbitrator nominated by Claimant
16. 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
[NOTE: ARTICLE 4.1(C) SIAC RULES]
[NOTE: ability of Respondent to comment on any procedural matter upon which the parties have agreed in writing or in respect of which the Respondent makes any proposal]
(a) The Seat of Arbitration
17.
[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
18.
[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
19.
[Insert Respondent’s comments as to the language of the arbitration] [Respondent may confirm the statement made by Claimant in the Request. In case of non- confirmation, Respondent should state its choice and reasons.]
VII. [OPTIONAL] RESPONDENT’S COUNTERCLAIMS
NOTE: ARTICLE 4.1(B) SIAC RULES
(b) Factual Background to Counterclaims
20.
Explain Claimant’s conduct which gives rise to the counterclaims.
(c) Claimant’s Violations of Its Legal Obligations
21.
[Explain basis of Claimant’s liability]
(d) Respondent Has Suffered Losses of [amount] for Which Claimant Is Liable
22.
[Provide preliminary estimate of Respondent’s losses]
VIII. RELIEF SOUGHT
NOTE: ARTICLES 4.1(B) SIAC RULES
23. Respondent rejects Claimant’s claims as set out in its Notice and rejects the relief sought.
24. Claimant 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: Article 4(1)(b) SIAC RULES
NOTE: if there are counterclaims
v. order Claimant to pay all arbitration costs, including Respondent’s representative’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.
25. Respondent reserves its right to further develop its arguments and the amount of relief it is seeking.
IX. PAYMENT OF REQUISITE FILLING FEE
26. [OPTIONAL: if Respondent files any counterclaim] Pursuant to SIAC Schedule fees and Article 4.3 of the SIAC Rules, Claimant is sending an advance payment of with the current Response to the Notice of Arbitration. Respondent acknowledges that this payment is non-refundable and shall be credited to its portion of the advance on costs.
NOTE: for Singapore Parties S$2,140, for Overseas Parties S$2,000
Respectfully submitted,
[Signature of Respondent’s representative]
[Name of lawyer representing Respondent]
Legal representative for Respondent
[Respondent’s representative’s address]
[Respondent’s representative’s Telephone]
[Respondent’s representative’s Facsimile]
[Respondent’s representative’s Email]
[Date of the Request]
[OPTIONAL] Exhibits submitted with the Response to the Notice of Arbitration [and Counterclaim(s)]
Exhibit | Exhibit number | |
1. | [•] | R-1 |
About this template
What is this template?
Model SIAC Response to Notice of Arbitration is a free, ready-to-use Arbitration 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?
Reach for this Arbitration template whenever you need a reliable agreement quickly and want to be sure the essentials are covered. It suits individuals, freelancers, startups, and established businesses alike. Instead of paying for a document drafted from scratch, you can start here, tailor the details to your arrangement, and have a polished draft ready in minutes. This version is drafted with Singapore in mind, though you should always review the final wording against the laws that apply to you.
What's typically included?
A well-drafted Arbitration usually sets out the parties involved, the scope of the agreement, and each side's rights and responsibilities. Expect sections covering key terms and definitions, how long the agreement lasts, how it can be ended, and what happens if something goes wrong. This template brings those building blocks together in a sensible order, so you can focus on the specifics rather than worrying about what to include. Open it to read the full document, then sign up to edit, negotiate, and e-sign it directly in GitLaw.