Statement of Counterclaim (Pleading) (ICC Rules) by OLL
Statement of Counterclaim under the ICC Rules of Arbitration (2026), Article 6 — Pleading archetype. Bare-facts counterclaim pleading elaborating the initial counterclaim raised with the Answer, without argument or authorities.
This document comes from OLL's library of vetted legal templates.
STATEMENT OF COUNTERCLAIM
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," "Counter-Respondent")
— and —
[Respondent's name]
[Respondent's address]
("Respondent," "Counter-Claimant")
Submitted on behalf of the Respondent 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 Counterclaim pleads material facts only, elaborating the counterclaim first raised with the Respondent's Answer under Article 6(4) of the ICC Rules of Arbitration (2026). No Rules-level article prescribes this document's content requirements; its content and section order follow the Procedural Order. What the Rules do directly govern: Article 6(4) (counterclaim must be raised with the Answer), Article 6(5) (Claimant's 30-day reply), and Article 25 (new-claims cut-off, applying equally to counterclaims).
There is no elective merge of the Article 6(4) initial counterclaim with this fuller document; they are two distinct filings, as with the Statement of Claim/Request split. The deadline for this document is set by the Procedural Order; no rule-based default applies. The Claimant's reply to the underlying counterclaim is fixed at 30 days from receipt under Article 6(5), running from the Answer stage, not from this document.
Confirm that a counterclaim was in fact raised with the Answer under Article 6(4) before using this template. Without one, this would be a new claim requiring Tribunal authorisation under Article 25.
Introduction
This Statement of Counterclaim is submitted pursuant to the Procedural Order governing this arbitration, pleading material facts only, elaborating the counterclaim first raised with the Answer under Article 6(4).
The Claimant's reply is due within 30 days of receipt under Article 6(5).
The Parties
The Respondent/Counter-Claimant is [Respondent's name], [brief description].
The Claimant/Counter-Respondent is [Claimant's name], [brief description].
Jurisdiction
The Tribunal has jurisdiction over this counterclaim pursuant to the arbitration agreement at [clause reference], seated at [seat of arbitration]. Per Article 25, the initial CMC is the new-claims cut-off, applying equally to counterclaims.
Material Facts
[Fact 1.]
[Fact 2.]
[Fact 3.]
Counterclaims Alleged
[Bare characterisation of the counterclaim, no authorities.]
Loss and Damage
Loss and damage of [amount] [quantified].
Interest claimed at [interest rate] from [date].
Relief Sought
The Respondent/Counter-Claimant seeks: (a) [amount]; (b) interest as pleaded; (c) costs of the counterclaim; and (d) further or other relief.
Reservations
The Respondent/Counter-Claimant reserves the right to amend or supplement this Statement of Counterclaim, subject to the Article 25 new-claims cut-off and any directions in the Procedural Order.
Annexure Schedule
Annexure directions are determined by the Procedural Order rather than by a rule-based default; annexure content is minimal or deferred under this pleading archetype.
Respectfully submitted,
[Representative's title and name]
On behalf of the Respondent/Counter-Claimant
Date: [date]
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