This Practice Note considers the procedure of an arbitration conducted pursuant to the United Nations Commission on International Trade Law Arbitration Rules (the UNCITRAL Rules). For an introduction to the UNCITRAL Rules, see Practice Note: UNCITRAL Rules—background and introduction. The UNCITRAL Rules are intended to offer a flexible ad hoc solution to parties wishing to use arbitration as a dispute resolution mechanism and can be adapted and tailored to the specific needs of the parties. In this sense 'procedure' under the UNCITRAL Rules will always be unique depending on the particular needs of the parties and the discretion of the arbitral tribunal in place. However, some general rules do apply which are examined below. UNCITRAL model arbitration clause The UNCITRAL Rules provide that where parties agree to refer their dispute to UNCITRAL arbitration, it will be decided in accordance with the UNCITRAL Rules (UNCITRAL Rules, Article 1(1)). A model UNCITRAL arbitration clause is annexed to the UNCITRAL Rules and reads as follows: ‘Any dispute, controversy or claim arising out of or relating to this contract, or the breach, termination or invalidity

This Practice Note considers how to respond to a notice of arbitration (Notice) communicated pursuant to the United Nations Commission on International Trade Law Arbitration Rules (the UNCITRAL Rules). For an introduction to the UNCITRAL Rules, see Practice Note: UNCITRAL Rules—background and introduction. In order to commence an arbitration under the UNCITRAL Rules, the claimant must communicate a Notice to the respondent—see Practice Note: UNCITRAL Rules—starting an arbitration. What to do on receiving the Notice of Arbitration The respondent has 30 days from receipt of the Notice to send a response to the claimant setting out (UNCITRAL Rules, Article 4): • the name and contact details of each respondent • a response to the Notice on: ◦ the identification of the arbitration agreement invoked ◦ the identification of any contract or other legal instrument out of or in relation to which the dispute arises or, in the absence of such contract or instrument, a brief description of the relevant relationship ◦ the brief description given of the claim

This Practice Note considers how to commence arbitration proceedings pursuant to the United Nations Commission on International Trade Law Arbitration Rules (the UNCITRAL Rules). For an introduction to the UNCITRAL Rules, see Practice Note: UNCITRAL Rules—background and introduction. For guidance on responding to an UNCITRAL arbitration claim, see Practice Note: UNCITRAL Rules—responding to a Notice of Arbitration. When a dispute arises, it is essential for parties and their advisors to review the dispute resolution clause in the relevant contract. Assuming that the clause provides for arbitration, they should check for: • any limitation period (either contractual or statutory) within which the arbitration must be started • any pre-arbitration processes (in particular any form of ADR) that must be conducted prior to commencing arbitration • what institutional rules or other procedures will govern the arbitration In this last case, parties must be aware that the method of starting an arbitration differs between institutional and ad hoc procedures. It is, therefore, important to check how the arbitration is to be commenced in order to ensure that it is started

Arbitration analysis: In this interesting case that has raised thorny issues about parallel proceedings, the doctrine of kompetenz-kompetenz, and the limits of anti-arbitration injunctions, an International Criminal Court tribunal (ICC tribunal) in a commercial arbitration granted an anti-arbitration injunction over a parallel UNCITRAL treaty proceedings under the India–Mozambique BIT. On 2 December 2022, the UNCITRAL tribunal in an unprecedented decision refused to stay the arbitration proceedings pursuant to ICC tribunal’s anti-arbitration injunction on the basis that: (a) the arbitrations were based on different agreements, involved different causes of action and the parties appeared in different roles (claimant in one, respondent in the other); and (b) neither tribunal can interfere with the other’s mandate. Written by Joseph Siyaidon, MCIArb, senior counsel at Dentons Acas–Law, Lagos, Nigeria.

The United Nations Commission on International Trade Law (UNCITRAL) Working Group II has published its 82nd session Report, approving amendments to key arbitration instruments to facilitate the issuance of electronic arbitral awards. The group endorsed a recommendation that the New York Convention be interpreted so that awards in electronic form cannot be denied recognition or enforcement solely on that basis. The approved amendments to the UNCITRAL Model Law on International Commercial Arbitration introduce new provisions that allow tribunals to issue electronic awards where the parties agree or do not object. Additionally, the amendments include updated definitions covering electronic communications and electronic awards.

The United Nations Commission on International Trade Law (UNCITRAL) Working Group II has published a note by the Secretariat titled 'technology-related dispute resolution and adjudication: model clauses and guidance text' for consideration at the Working Group's 79th session. The Working Group's 79th session is to take place in New York between 12—16 February 2023. The note contains model clauses and annotations on highly expedited arbitration, adjudication, technical advisors and confidentiality. Additionally, the note contains guidance texts on confidentiality within proceedings, guidance text on evidence and an introductory text.

The United Nations Commission on International Trade Law (UNCITRAL) Working Group II: Arbitration and Conciliation/Dispute Settlement (Working Group II) has published a report on the work of its 79th session which took place in New York between 12 and 16 February 2024. The session focused on the consideration of technology-related dispute resolution and adjudication, looking at model clauses on highly expedited arbitration, adjudication, technical advisors and confidentiality as well as guidance text on evidence.

The United Nations Commission on International Trade Law (UNCITRAL) Working Group II: Dispute Settlement (Working Group II) has published a report on the work of its 83rd session, which took place in New York between 16 and 20 February 2026. The session focused on enhancing reliance on arbitral awards and notices in electronic form, including proposed amendments to the UNCITRAL Model Law on International Commercial Arbitration, and also included a colloquium on the use of artificial intelligence in dispute resolution and remote hearings in arbitration and mediation.

The United Nations Commission on International Trade Law (UNCITRAL) Working Group III convened its 50th session in Vienna from 20-24 January 2025, continuing its work on investor-State dispute settlement (ISDS) reform. The session focused on refining draft provisions for procedural and cross-cutting issues, as well as a draft statute for a standing mechanism to resolve international investment disputes. Key discussions centred on the selection and appointment of tribunal members, terms of office, and the jurisdiction and functions of an Appeals Tribunal. The Working Group also outlined plans for advancing reform elements and operationalising the Advisory Centre on International Investment Dispute Resolution.

The United Nations Commission on International Trade Law (UNCITRAL) Working Group III: Investor-State Dispute Settlement Reform​ has announced that it has completed its work on a draft statute relating to an advisory centre in investor-state dispute settlement (ISDS). The proposed advisory centre will provide training, support and assistance regarding international investment dispute resolution and enhance capacity in the prevention, and handling, of international investment disputes. The draft statute will be presented to UNCITRAL at its next session from 2–5 July 2024 in New York.

The United Nations Commission on International Trade Law (UNCITRAL) Working Group III: Investor-State Dispute Settlement Reform​ has released an annotated provisional agenda for its 48th session to be held in New York on 1–15 April 2024.

This Practice Notes provides information on the work of the United Nations Commission on International Trade Law (UNCITRAL) Working Group III: Investor-State Dispute Settlement (ISDS) Reform and links to their reports. UNCITRAL Working Group III: ISDS Reform (Working Group III) typically meets twice a year to: discuss concerns regarding ISDS; consider whether reform is desirable; and, if so, develop solutions to be recommended to UNCITRAL. This Practice Note makes available the published reports of Working Group III. Note: For information on UNCITRAL Working Group II: Arbitration and Conciliation/Dispute Settlement, see Practice Note: UNCITRAL Working Group II—reports. Working Group III session Report Subjects covered 54th session, 23–27 March 2026 Reform of ISDS—see provisional agenda and any other documents available here 53rd session, 12–16 January 2026 Reform of ISDS—see provisional agenda and any other documents available here 52nd session, 22–26 September 2025 Reform of ISDS—see provisional agenda and any other documents