STATEMENT OF CLAIM
ICC Case No.: [Case No.] Filed pursuant to: [Procedural Order No.]
IN THE MATTER OF AN ARBITRATION UNDER THE ICC RULES OF ARBITRATION (2026)
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
This Statement of Claim is drafted for the Standard track. Where the parties have opted into Highly Expedited Arbitration (Article 33; Appendix VI), a merged Request for Arbitration and Statement of Claim applies instead, filed as a single document. There is no elective mechanism under the Standard track for the Claimant to treat its Request for Arbitration as this Statement of Claim; they are always two distinct documents filed at two distinct procedural stages.
The filing deadline for this Statement of Claim is fixed by the Tribunal's Procedural Order No. 1, issued following the initial case management conference (which Article 24 requires to take place within 30 days of transmission of the file to the Tribunal). No default filing deadline is prescribed by the Rules themselves.
Confirm the applicable filing deadline under the governing Procedural Order before filing.
Expedited Procedure. The Expedited Procedure (Article 32; Appendix V) applies automatically where the amount in dispute does not exceed the EPP Threshold Amount fixed by Appendix V, Article 1(3): US$2,000,000 for arbitration agreements concluded on or after 1 March 2017 and before 1 January 2021; US$3,000,000 for agreements concluded on or after 1 January 2021 and before 1 June 2026; and US$4,000,000 for agreements concluded on or after 1 June 2026. It also applies where the parties agree to opt in (Article 1(2)(b)), and does not apply where the arbitration agreement predates 1 March 2017, the parties opt out, or the Court considers it inappropriate (Article 1(4)).
Confirm the date the arbitration agreement was concluded, not only the amount in dispute, before assuming the Expedited Procedure applies.
Case Management Conference. Per the ICC Note to Parties and Arbitral Tribunals (2026), the initial case management conference addresses matters including: identification of contested issues in light of submissions filed to date; guidance on further submissions and evidence; narrowing of disputed issues by agreement; reassessment of settlement or mediation; bifurcation; outstanding document production requests; and whether post-hearing briefs or closing statements will be required. This Statement of Claim should be drafted with these matters in view.
Introduction
This Statement of Claim is submitted pursuant to the Procedural Order governing this arbitration, following the initial case management conference held under Article 24 of the ICC Rules of Arbitration (2026 Edition, in force 1 June 2026). The Rules do not contain a standalone article prescribing the content of a Statement of Claim; the content and section order of this document instead follow the Procedural Order governing this arbitration. Article 24 governs only the timing of that conference and is not itself a content or filing-deadline provision for this document. Under the 2026 Rules, Terms of Reference are opt-in rather than mandatory (Article 23).
The section order below follows a default sequence — the Parties; Jurisdiction; Factual Background; Legal Grounds; Loss and Quantum; Relief Sought; Annexure Schedule — which should be reordered, retitled, or supplemented to match the Procedural Order actually governing this arbitration.
The Parties
The Claimant is [Claimant's name], [description].
The Respondent is [Respondent's name], [description].
Jurisdiction
The Tribunal has jurisdiction pursuant to the arbitration agreement at [clause reference], seated at [seat of arbitration].
Per Article 25 ("New Claims"): "After the initial CMC, no party may make new claims, unless authorised by the arbitral tribunal. In determining whether to allow such new claims, the arbitral tribunal shall consider the nature of the new claims, the stage of the arbitration, any cost implications and any other relevant circumstances." Because Terms of Reference are now opt-in rather than mandatory (Article 23), the initial CMC (Article 24) — rather than the signing of Terms of Reference — is the operative cut-off for new claims. This Statement of Claim does not raise any claim beyond what was identified before that cut-off.
Factual Background
Chronology. [Insert.]
Dramatis Personae. [Insert.]
Contractual Matrix. [Insert.]
Narrative. [Insert, cross-referenced to exhibits.]
Legal Grounds
Cause of Action 1. [State the legal basis, with authorities.]
Cause of Action 2. [If applicable.]
Loss, Damage and Quantum
The Claimant has suffered loss and damage in the amount of [amount], particularised as follows: [quantum breakdown].
Interest is claimed at [interest rate] from [date].
Relief Sought
The Claimant respectfully requests that the Tribunal: (a) DECLARE that [declaratory relief sought]; (b) ORDER the Respondent to pay [amount]; (c) AWARD interest as pleaded above; (d) ORDER the Respondent to pay the costs of this arbitration; and (e) GRANT such further or other relief as the Tribunal considers just, having regard to whether early determination under Article 30 is sought for any manifestly unmeritorious defence the Respondent may raise.
Annexure Schedule
Annexure and exhibit directions for this arbitration are determined by the Procedural Order rather than by a general rule-based default.
Confirm the Procedural Order's specific annexure directions before relying on any practice assumed here.
Exhibit No. | Description | Referenced at ¶ |
[Document] | ¶ [ ] |
Respectfully submitted,
[Representative's title and name]
On behalf of the Claimant
Date: [date]
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