Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
UNCITRAL Arbitration Rules (2021) — Pleading Archetype
This archetype pleads material facts and a traverse only, with no legal argument and no evidence inline.
STATEMENT OF DEFENCE
If Section 9 (Statement of Counterclaim) below is included, the title above should read: "STATEMENT OF DEFENCE AND STATEMENT OF COUNTERCLAIM".
[Case No.: [Case number, if allocated]]
IN THE MATTER OF AN ARBITRATION UNDER THE UNCITRAL ARBITRATION RULES (2021)
BETWEEN
[Claimant's name] of
[Claimant's address]
("Claimant")
and
[Respondent's name] of
[Respondent's address]
("Respondent")
Submitted on behalf of the Respondent by: [Representative's title, e.g. Counsel for the Respondent] [Name of representative]
Date: [Date of this Statement of Defence]
Introduction
Include the following Election Notice only if the Respondent elects, pursuant to Art. 21(1) (second sentence), to treat its Response to the Notice of Arbitration as its Statement of Defence:
"Pursuant to Art. 21(1), the Respondent elects to treat its Response to the Notice of Arbitration dated [date] as its Statement of Defence, supplemented as set out below."
This Statement of Defence is submitted pursuant to Art. 21 of the UNCITRAL Arbitration Rules (2021), pleading material facts only.
The Parties
[Admit / deny identity of the parties as pleaded.]
Jurisdiction
[If no jurisdictional objection is raised: "No jurisdictional objection is raised." If a jurisdictional objection is raised: "The Respondent objects to jurisdiction on the following basis: [bare factual and legal basis — no argument]." Pursuant to Art. 23(2), any objection must be raised no later than this Statement of Defence, or it is liable to be treated as time-barred.]
General Traverse
Save as expressly admitted below, the Respondent denies each allegation in the Statement of Claim.
Paragraph-by-Paragraph Reply
For each paragraph, the Respondent's response is stated as ADMITTED, DENIED, or NOT ADMITTED.
SoC ¶ | Allegation (summary) | Response |
[summary] | [ADMITTED / DENIED / NOT ADMITTED] | |
[summary] | [ADMITTED / DENIED / NOT ADMITTED] | |
[summary] | [ADMITTED / DENIED / NOT ADMITTED] |
Material Facts (Respondent's Version)
[Bare facts only, no argument.]
Affirmative Defences
Affirmative Defence 1: [bare basis, no argument].
[Include the following paragraph only if the Respondent pleads set-off as a defence: "Set-Off. Set-off pleaded in the amount of [set-off amount], as a defence." Set-off pleaded here is distinct from a counterclaim pleaded under Section 9 below.]
Loss and Damage Response
The Respondent's position on [quantum amount]: [admit / dispute].
Statement of Counterclaim
Include this Section only if the Respondent raises a counterclaim within this Statement of Defence, pursuant to Art. 21(3). Because a counterclaim is a claim, this Section reuses the pleading-archetype Statement of Claim element set. If the counterclaim is instead to be filed as a separate document, omit this Section and use the standalone Counterclaim (Pleading) template.
Material facts supporting the counterclaim. [Insert.]
Breach alleged. [Bare characterisation.]
Relief and quantum sought. [counterclaim quantum amount].
Relief Sought
The Respondent seeks: (a) dismissal of the Statement of Claim; (b) [if Section 9 above is included:] [counterclaim quantum amount] on the Counterclaim; (c) costs; and (d) further or other relief.
Reservations
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About this template
What is this template?
This document is a formal legal pleading used by a respondent to answer a Statement of Claim in an arbitration. It is not a witness statement or an expert report, as it focuses on pleading material facts rather than providing evidence. It contains specific sections for a general traverse and a paragraph-by-paragraph reply table.
When should you use it?
Use this document when you have been served with a Statement of Claim in a UNCITRAL-governed arbitration and need to file a formal response. If the arbitration is under different rules, such as ICC or LCIA, use the specific defence template for those institutions instead.
What's inside
| Clause | Name | What it does |
|---|---|---|
| 3 | Jurisdiction | Allows the Respondent to object to jurisdiction pursuant to Art. 23(2), noting that failure to do so now may result in a time-bar. |
| 4 | General Traverse | Provides a blanket denial of all allegations in the Statement of Claim that are not expressly admitted elsewhere in the document. |
| 5 | Paragraph-by-Paragraph Reply | Utilizes a table format for the Respondent to explicitly ADMIT, DENY, or NOT ADMIT individual allegations from the Statement of Claim. |
| 7 | Affirmative Defences | Permits the Respondent to state the bare factual basis for specific defences, including a dedicated section for pleading set-off. |
| 9 | Statement of Counterclaim | Enables the Respondent to raise a counterclaim within the same document pursuant to Art. 21(3), specifying material facts and relief sought. |
| 11 | Reservations | Expressly reserves the Respondent's right to amend or supplement the pleading under Art. 22 of the UNCITRAL Rules. |
Who it's for
- a respondent defending a claim in an international arbitration under UNCITRAL Rules 2021
- a legal representative filing a response that includes both a defence and a counterclaim
- a party seeking to raise a jurisdictional objection at the earliest procedural stage
How long it runs and how it's signed
How long
Used once
Signed by
Representative of the Respondent
Witness
Not required
Notarisation
Not required
Also needed
Serve on Claimant and Arbitral Tribunal
Law it's drafted under
Governed by
UNCITRAL Arbitration Rules (2021)
Refers to
Art. 21
Refers to
Art. 21(1)
Refers to
Art. 21(3)
Refers to
Art. 22
Refers to
Art. 23(2)
Jurisdiction
United Nations
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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