HKIAC

Hong Kong

English

Chinese

ICC

English (~15%)

New York (~10%)

Swiss / French / German / Brazil (~10% each)

LCIA

English (90%+)

Swiss

New York

SIAC

Singapore (60%+)

English (~20%)

India (~5%)

The chart above has been colour-coded to show the take up of common laws and civil laws before these institutions. 

Some further observations:

  • The HKIAC and SIAC only publish their top three governing laws. 
  • That SIAC's third most common governing law is Indian law provides context to Indian parties' use of SIAC, as noted in earlier charts. 
  • The ICC and LCIA have the same top three governing laws: English, US (New York law) and Swiss laws.  Where they differ: these governing law choices make up a relatively small proportion of the ICC's case load, whereas almost 90% of the cases before the LCIA are governed by English law, and its second and third top choices trail far behind (chosen up to 2% of the time).  The ICC, in that regard, sees a greater diversity of matters as compared to other international institutions, consistent with the way it sees more diverse arbitrators as well (see next chart).  
  • When the ICC's top five governing laws are considered together, we see a 60-40 divide between common law and civil law systems, even though four of its five top users come from civil law jurisdictions. 
     
Powered by Ceros