Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
Request and Statement of Claim (HEAP Track, Memorial) (ICC Rules) by OLL
Open Legal LibraryUpdated 11 Aug 2026
REQUEST AND STATEMENT OF CLAIM
ICC Case No.: [Case No.]
IN THE MATTER OF AN ARBITRATION UNDER THE ICC RULES OF ARBITRATION (2026) (HIGHLY EXPEDITED ARBITRATION — APPENDIX VI)
BETWEEN
[Claimant's name]
[Claimant's address]
("Claimant")
— and —
[Respondent's name]
[Respondent's address]
("Respondent")
Submitted on behalf of the Claimant by: [Representative's title and name]
Date: [date]
This template numbers every paragraph, including optional ones, as though included. Delete any paragraph or clause that does not apply to this filing and renumber sequentially before submission.
Preliminary Notes
"HEAP" is ICC's own shorthand for the Highly Expedited Arbitration Provisions (Appendix VI), also referred to as "Highly Expedited Arbitration" in Article 33 of the main Rules.
Availability. HEAP is opt-in only, with no monetary threshold restricting its application — unlike the Expedited Procedure's default-application threshold under the Standard track (see Appendix V). Under HEAP, the Tribunal is a sole arbitrator, the award is due within 3 months of the initial CMC, the Tribunal may refuse document production requests entirely, and the Tribunal may decide the case on the documents alone, without an oral hearing.
Merged Filing. This single document constitutes both the Request for Arbitration and the Statement of Claim, filed together as one filing event. There is no separate, later-filed Statement of Claim under this track. Because Appendix VI requires the full legal and factual basis — and, to the extent possible, the evidence relied on — to be filed with the Request, this document is necessarily drafted in full-argument form; there is no abbreviated facts-only variant under HEAP.
Confirm the Parties have opted into Highly Expedited Arbitration pursuant to Appendix VI/Article 33 before using this template — HEAP is never the default track.
Introduction
This Request and Statement of Claim is submitted together, pursuant to Appendix VI/Article 33, given the Parties' opt-in to HEAP.
This document includes the full legal and factual basis and, to the extent possible, the evidence relied on — not a bare Request.
Section index: (I) the Parties; (II) Jurisdiction and HEAP Eligibility; (III) Factual Background; (IV) Legal Grounds; (V) Loss and Quantum; (VI) Relief Sought; (VII) Evidence Relied On; (VIII) Exhibit Schedule.
The Parties
The Claimant is [Claimant's name], [description].
The Respondent is [Respondent's name], [description].
Jurisdiction and HEAP Eligibility
The Tribunal has jurisdiction pursuant to the arbitration agreement at [clause reference], seated at [seat of arbitration].
HEAP eligibility is confirmed: there is no monetary threshold restricting opt-in, and the Parties have elected sole-arbitrator determination with a 3-month award deadline from the initial CMC.
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About this template
What is this template?
This document is a combined legal filing for ICC arbitration that serves simultaneously as a Request for Arbitration and a Statement of Claim. It is not an abbreviated facts-only request; it contains the full legal and factual basis and all evidence relied on as required by the HEAP track. It explicitly excludes the default monetary thresholds associated with the standard Expedited Procedure track.
When should you use it?
Use this when the parties have explicitly opted into the Highly Expedited Arbitration Provisions under Appendix VI and require a sole-arbitrator award within 3 months. Use a standard ICC Request for Arbitration if the parties have not opted into HEAP or if they are following the default Expedited Procedure under Appendix V.
What's inside
| Clause | Name | What it does |
|---|---|---|
| III | Jurisdiction and HEAP Eligibility | Confirms the Tribunal's jurisdiction via a specific arbitration clause and establishes eligibility for HEAP's sole-arbitrator determination and three-month award deadline. |
| VII | Relief Sought | Requests the sole arbitrator to issue a declaration, order payment of a specific amount, and award interest and costs within 3 months. |
| VIII | Evidence Relied On | Submits all legal and factual evidence at the filing stage because the Tribunal may refuse document production entirely under HEAP rules. |
Who it's for
- a party opting into the ICC Highly Expedited Arbitration Provisions (Appendix VI) regardless of monetary threshold
- a claimant filing a merged Request and Statement of Claim to meet a three-month award deadline
How long it runs and how it's signed
How long
Used once
Signed by
Representative for the Claimant
Witness
Not required
Notarisation
Not required
Also needed
renumber sequentially before submission; attach exhibit schedule
Law it's drafted under
Governed by
ICC Rules of Arbitration (2026)
Governed by
Appendix VI, ICC Rules
Governed by
Article 33, ICC Rules
Jurisdiction
General
Document info
GitLaw document. Document created on Sun Aug 9th, 2026. Last updated on Tue Aug 11th, 2026.
This document is public
Licensed under CC BY-SA 4.0 (Attribution-ShareAlike).
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