Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
STATEMENT OF CLAIM
HKIAC Case No.: [Case No.]
IN THE MATTER OF AN ARBITRATION UNDER THE HKIAC ADMINISTERED ARBITRATION RULES (2024)
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 Matters
Include the following paragraph only if the Claimant elects, pursuant to Article 16.1, to treat the Notice of Arbitration as the Statement of Claim:
The Claimant elects to treat the Notice of Arbitration dated [date of the Notice of Arbitration] as its Statement of Claim.
The Tribunal may, pursuant to Article 16.4, vary the content requirements for this document.
Before filing, confirm that no Procedural Order has varied this structure.
Introduction
This Statement of Claim is submitted pursuant to Article 16, pleading material facts only. A bare pleading of material facts corresponds to the particular at Article 16.2(a).
The Parties
The Claimant is [Claimant's name], [brief description].
The Respondent is [Respondent's name], [brief description].
Jurisdiction
The Tribunal has jurisdiction pursuant to the arbitration agreement at [clause reference], seated at [seat of arbitration]. Dedicated jurisdiction provision: Article 19.
Material Facts
[Fact 1.]
[Fact 2.]
[Fact 3.]
Breaches Alleged
[Bare characterisation of the cause of action, no authorities.]
Loss and Damage
Loss and damage of [amount claimed] [quantified].
Interest claimed at [interest rate] from [date from which interest is claimed].
Relief Sought
The Claimant seeks: (a) [amount claimed]; (b) interest as pleaded; (c) costs; (d) further or other relief.
Reservations
The Claimant reserves the right to amend or supplement this Statement of Claim pursuant to Article 18, and to plead further facts, legal grounds, and evidence at the appropriate stage.
Annexure Schedule
Pursuant to Article 16.3, the Claimant shall annex all supporting materials on which it relies. This obligation applies notwithstanding the otherwise minimal exhibit convention of the pleading archetype.
Confirm scope with the Tribunal if seeking to minimise the exhibit set for this filing.
Exhibit No. | Description | Referenced at ¶ |
C-1 | [Document] | ¶ [ ] |
Respectfully submitted,
[Representative's title and name]
On behalf of the Claimant
Date: [date]
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About this template
What is this template?
This document is a formal pleading used to set out the facts and legal basis for a claim in an HKIAC arbitration. It is not a generic court complaint or a Notice of Arbitration, but rather the subsequent detailed filing required by Article 16. It contains specific sections for quantifying interest and an exhibit table for documentary evidence.
When should you use it?
Use this template when you have already commenced HKIAC arbitration and need to file the formal Statement of Claim following the Notice of Arbitration. If you are just starting the process, use a Notice of Arbitration instead.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 1 | Introduction | Invokes Article 16 of the HKIAC Rules to submit a pleading of material facts. |
| 3 | Jurisdiction | Identifies the arbitration agreement clause reference, the seat of arbitration, and references Article 19 regarding jurisdiction. |
| 6 | Loss and Damage | Specifies the quantified amount claimed and the interest rate applicable from a stated commencement date. |
| 7 | Relief Sought | Lists the specific financial amounts, interest, costs, and other relief the Claimant requires the Tribunal to award. |
| 8 | Reservations | Reserves the Claimant's right under Article 18 to amend or supplement the pleading at a later stage. |
| 9 | Annexure Schedule | Obliges the Claimant to attach all supporting materials pursuant to Article 16.3 for the Tribunal's consideration. |
Who it's for
- a party initiating a claim under the HKIAC Administered Arbitration Rules (2024)
- legal representatives drafting a formal pleading of material facts for a Hong Kong seated arbitration
- claimants electing to treat a Notice of Arbitration as a Statement of Claim under Article 16.1
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; annex supporting materials
Law it's drafted under
Governed by
HKIAC Administered Arbitration Rules (2024)
Refers to
Article 16.1
Refers to
Article 16.2(a)
Refers to
Article 19
Refers to
Article 18
Refers to
Article 16.3
Jurisdiction
Hong Kong
General
Document info
GitLaw document. Document created on Mon Aug 10th, 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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