HKIAC
Hong Kong
ICC
English (~15%)
LCIA
English (90%+)
SIAC
Singapore (60%+)
Swiss / French / German / Brazil (~10% each)
New York (~10%)
English
Chinese
Swiss
New York
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.