In March 2026, a Marseille charterer and a Greek shipowner fell out over 1.1 million euros of demurrage and cargo damage under a charterparty signed three years earlier. The arbitration clause ran to a single line: “Arbitration in London, LCIA rules”. Nobody, at signature, had looked at what that line would cost. The LCIA secretariat bills its hours, the arbitrators bill theirs, and the median the institution reports for a case of that size exceeds 100,000 euros before the first euro of counsel fees. Before the Paris Maritime Arbitration Chamber, the same dispute, decided by a sole arbitrator, would have cost 27,540 euros excluding tax, arbitrator included. The difference lies in four words of the clause.
This page compares, on one common set of assumptions, what twelve arbitral institutions charge for a commercial dispute of roughly one million euros referred to a sole arbitrator. It sets out what the figures measure and what they leave out, why the ranges are not built the same way, where the real gap between institutions lies, and which eight points an arbitration clause has to settle so that this cost is not discovered on the day the dispute breaks. The amounts were checked on 20 September 2026 against the official schedules and converted at European Central Bank rates of 18 September 2026.
The table in short
Dispute of roughly one million euros (1,146,000 dollars), sole arbitrator, institutional fees and arbitrator fees only, excluding counsel fees, experts, translation, hearing costs and enforcement. Amounts rounded, in euros.
| Institution | Filing fee | Institution and sole arbitrator, for 1 M EUR | Predictability | Expedited procedure at this amount |
|---|---|---|---|---|
| ICC | 4,360 EUR (5,000 USD), credited | 34,200 to 81,100 EUR, average 57,600 EUR; under the expedited procedure, average 50,200 EUR | High | Automatic (4 M USD threshold) |
| LCIA | 2,270 EUR (1,950 GBP) | No schedule; reported median 103,800 EUR between 1 and 10 M USD | Low to moderate | None |
| SIAC | 2,050 EUR (3,000 SGD) | Average 46,500 EUR, ceiling 62,000 EUR | High | On application (1 to 10 M SGD) |
| HKIAC | 1,110 EUR (10,000 HKD) | Up to 61,600 EUR on the schedule; hourly option capped at 830 EUR per hour | Moderate to high | Automatic (50 M HKD threshold) |
| SCC | 3,000 EUR, credited | 40,200 to 72,000 EUR, median 56,100 EUR | High | By agreement of the parties |
| Swiss Arbitration Centre | 4,760 EUR (4,500 CHF) | 26,600 to 77,800 EUR, average 52,200 EUR | High | Automatic (1 M CHF threshold) |
| ICDR | 7,790 EUR (8,925 USD) | Administrative fees 16,200 EUR; arbitrator at his own rate | Moderate | No (500,000 USD threshold) |
| WIPO | 1,745 EUR (2,000 USD) | Institutional fees 5,240 EUR; arbitrator at 260 to 520 EUR per hour; 19,200 EUR all in under expedited arbitration | High | By choice of the parties |
| CIETAC | 1,300 EUR (10,000 RMB) | 26,100 EUR all in (200,125 RMB) | High | No (5 M RMB threshold) |
| SCMA | None; 1,025 EUR for an appointment by the Chairman | Arbitrator fees only, at his rate | Moderate | No (300,000 USD threshold) |
| CAMP | 2,000 EUR excl. tax, credited | 27,540 EUR excl. tax all in (45,900 EUR with three arbitrators) | High | No threshold, as circumstances require |
| ICSID | 21,800 EUR (25,000 USD) | 45,400 EUR per year of administration, arbitrators at 436 EUR per hour | Off the scale | Not applicable |
1. What the table measures, and what it leaves out
The cost of an arbitration falls into three blocks. The first belongs to the institution: a filing fee on registration, then administrative fees that pay for the secretariat, the constitution of the tribunal, the running of the procedure and, under several rules, the scrutiny of the draft award. The second belongs to the tribunal: the fees of the arbitrator or arbitrators, and their travel and subsistence. The third, by far the heaviest, belongs to the parties themselves: their counsel, technical or accounting experts, translation, hearing rooms, transcripts, and then enforcement of the award in the country where the debtor keeps its assets.
The table measures only the first two blocks. It does so on one common hypothesis, a dispute of roughly one million euros decided by a sole arbitrator, because no comparison means anything if a schedule calculated for three arbitrators is set against one calculated for a single arbitrator. The figure chosen is not arbitrary: it is the size of ordinary commercial disputes, of a charterparty, a distribution agreement or a sale of industrial equipment, and it also sits, within a few hundred thousand euros, on the expedited procedure thresholds of several sets of rules. Filing fees are shown separately because they are treated differently: the ICC, the SCC and the CAMP credit them against the advance on costs, while the LCIA, the SIAC, the HKIAC and the Swiss Arbitration Centre collect them on top.
What the table leaves out weighs more than what it contains. On a commercial arbitration of one million euros, the counsel fees of the two sides routinely exceed twice, sometimes three times, the institutional and arbitrator fees combined. A reader who compares two institutions on the strength of the table alone is comparing a third of the bill. It is the third that is decided when the contract is signed, whereas the other two are decided when the dispute arises, and that is why it deserves a look.
2. Three pricing models, and why the ranges are not comparable in shape
The first model is the ad valorem schedule: administrative fees and arbitrator fees are calculated in bands on the amount in dispute, with a floor and a ceiling that the institution adjusts according to the difficulty of the case and the diligence of the tribunal. This is the model of the ICC, the SIAC, the SCC, the Swiss Arbitration Centre, WIPO, CIETAC and the CAMP. It produces a figure before the request is filed, and most of these institutions publish a calculator that confirms it in seconds. Its weakness is well known: a straightforward case on a large amount pays dearly, a difficult case on a small amount is poorly remunerated, and the institution corrects at the margin by moving between the floor and the ceiling.
The second model is time billing. The LCIA is its purest example: its secretariat bills 190 to 300 pounds an hour depending on grade, its arbitrators 250 to 650 pounds, and the institution takes a further 5 per cent of the tribunal fees. ICSID works the same way, at 500 dollars an hour. The HKIAC offers it as an option, capped at 7,500 Hong Kong dollars an hour since 1 January 2026. This model allows no calculation in advance: all one has is the rates and, for the LCIA, medians observed on closed cases, 26,000 dollars below one million dollars in dispute, 119,000 dollars between one and ten million. It pays for the work actually done, which is its justification, and it exposes the parties to a bill they will only know at the end, which is its price.
The third model is mixed. The ICDR sets its administrative fees in bands, 8,925 dollars on filing and 9,675 dollars when the hearing is set for the band of one to ten million dollars, but lets the arbitrator charge his own rate, which the institution fixes “in consultation with the parties”. The SCMA goes further still: it charges nothing, neither filing nor administration, apart from 1,500 Singapore dollars when its Chairman makes an appointment, and the arbitrator is paid on the terms agreed with the party appointing him. The ranges in the table therefore cannot be uniform. For the ICC, the SCC and Switzerland, they run from the floor to the ceiling of the schedule; for the SIAC, from the average to the ceiling, since the rules publish only maxima; for the LCIA, they are medians; for the ICDR and the SCMA, part of the figure is missing by construction.
3. A gap of one to four
For one million euros before a sole arbitrator, CIETAC charges 200,125 yuan, roughly 26,100 euros, as a single global fee covering both the institution and the tribunal. The CAMP charges 27,540 euros excluding tax, arbitrators included, under the schedule of 16 June 2022. The Swiss Arbitration Centre sits between 26,600 and 77,800 euros, with administrative fees of only 3,000 Swiss francs and an average of 52,200 euros. The SCC sits between 40,200 and 72,000 euros, median 56,100 euros. The SIAC is capped at 62,000 euros, with an average calculated by its own tool at 46,500 euros. The ICC, on the Schedule of Fees in force since 1 June 2026, runs from 34,200 to 81,100 euros under the ordinary procedure, average 57,600 euros. The HKIAC, on the schedule option, rises to 61,600 euros. The LCIA, finally, reports a median of 103,800 euros on the band of one to ten million dollars.
Between the CAMP and the LCIA median, the gap is one to four. Between the schedule institutions themselves it remains one to two, depending on whether the floor or the ceiling is taken. At this level of amount, the difference between two institutions often exceeds what the client will agree to pay in fees for drafting the clause. Negotiating the contract is the only moment at which that gap can be settled for nothing.
Two cautions apply to these figures. The first is that the lowest amount says nothing about the quality of the service: an inexpensive institution that cannot replace a challenged arbitrator, consolidate a related proceeding or hold a tribunal to a timetable costs more, in the end, than the ICC. The second is that the schedules do not measure the same thing: the CIETAC global fee cannot be broken down, the CAMP schedule includes the fees, the SCC schedule includes registration, and the SIAC schedule excludes a 9 per cent goods and services tax that falls on Singapore parties. The table gives a reliable order of magnitude; it does not replace reading the schedule that applies to the case.
4. The number of arbitrators weighs more than the name of the institution
The variable that moves the bill most is not the choice of institution but the composition of the tribunal. At the CAMP, the global schedule rises from 27,540 to 45,900 euros excluding tax for one million euros depending on whether the tribunal has one member or three; on a dispute of 100,000 euros, from 7,080 to 11,800 euros. Under the Swiss Rules 2021, a three member tribunal receives 250 per cent of the sole arbitrator fees. At the ICC, the SIAC and the SCC each arbitrator is paid under the schedule, the SCC co-arbitrators at 60 per cent of the chair, which multiplies the fee line by a factor of two to three.
Yet most rules leave the question open where the clause is silent, and several default to three arbitrators above a given threshold. CIETAC appoints three arbitrators above 5 million yuan, roughly 650,000 euros, unless otherwise agreed. The LCIA appoints a sole arbitrator unless the parties have agreed otherwise or the Court considers a three member tribunal appropriate. The ICC and the SIAC leave the institution to decide as circumstances require. In each of these cases, the party that wants a sole arbitrator discovers when the dispute arises that it must persuade the other side, which by then has every reason to prefer three arbitrators if it is the respondent and in no hurry at all.
Hence a simple rule. Below two or three million euros of likely amount, stipulating a sole arbitrator in the clause, rather than leaving it to the institution, is the surest saving in the whole table. Above that, collegiality regains its point: three arbitrators reduce the risk of an aberrant award and let each party appoint an arbitrator familiar with its law or its language. But that insurance has a known price, and it is better to have costed it before taking it out.
5. Expedited procedure thresholds that bite of their own accord
A one million euro dispute sits precisely in the zone where several sets of rules switch by themselves into expedited mode. At the ICC, the expedited procedure provisions of Appendix V apply automatically where the amount in dispute does not exceed 4 million dollars for arbitration agreements concluded since 1 June 2026 (3 million for those concluded between 1 January 2021 and 31 May 2026, 2 million for earlier agreements): sole arbitrator, award within six months of the case management conference, arbitrator fees reduced by 20 per cent, which brings the average down from 57,600 to 50,200 euros. At the Swiss Arbitration Centre, the expedited procedure of article 42 applies below 1 million Swiss francs, unless the Court decides otherwise, with a sole arbitrator and a single exchange of submissions. At the HKIAC, the threshold was raised to 50 million Hong Kong dollars on 1 January 2026, roughly 5.5 million euros.
Elsewhere the regime is optional or closed. The SCC has a separate set of expedited rules, on a reduced schedule (2,500 euros registration, roughly 11,600 euros of administrative fees for one million euros), which applies only if the parties have chosen it. WIPO likewise offers expedited arbitration rules, with a flat arbitrator fee of 20,000 dollars below 2.5 million dollars, and no automatic trigger. The SIAC applies its streamlined procedure automatically below one million Singapore dollars, with fees halved, and its expedited procedure on application between one and ten million, without any fee reduction. The ICDR, below 500,000 dollars, and CIETAC, below 5 million yuan, do not reach our hypothesis. The LCIA has no expedited procedure at all; it knows only the expedited formation of the tribunal in cases of exceptional urgency.
The practical consequence runs both ways. A party that wants three arbitrators and a full procedure for a one million euro dispute before the ICC, in Switzerland or at the HKIAC must say so in the clause, failing which it will get a sole arbitrator and a compressed timetable it did not choose. A party that wants speed must instead make sure the likely amount stays below the threshold, or expressly opt into the expedited rules where they are optional. Either way, a clause drafted in 2024 under the 3 million dollar threshold does not have the same effect as one signed today.
6. The complete clause: eight decisions taken together
The cost of an arbitration is never the product of the institution alone. It follows from eight decisions the clause has to take at the same time, because each one alters the others. The institution first, with the rules that go with it. The seat next, which governs the law of the arbitration, the challenges available against the award and the intervention of the supporting judge: a seat in Paris opens the action to set aside under articles 1518 and following of the Code of Civil Procedure, a seat in London the route of the Arbitration Act 1996 as amended in 2025, a seat in Singapore or Hong Kong different routes again. The language, which fixes the cost of translation and the pool of available arbitrators. The number of arbitrators, whose weight we have seen.
Then whether or not to use the expedited procedure, given the thresholds that apply automatically. The law governing the contract, which is not the same as the law of the seat. The law governing the arbitration agreement itself, a question English and French case law answer differently and which the English reform of 2025 settled in favour of the law of the seat, absent contrary stipulation. And finally the likely place of enforcement, which dictates the choice of a seat and an institution whose awards are recognised there without difficulty: an award made in Hong Kong is enforced in mainland China under a specific arrangement, as is a CIETAC award, while a Paris award is enforced there under the New York Convention with the uncertainties that are familiar enough.
A clause that settles only the first point refers everything else to litigation, and litigation about the clause comes before litigation on the merits. The Marseille charterer in our example spent the first six months of his arbitration arguing about the number of arbitrators and the language of the proceedings. Everything the clause leaves open will be argued, at LCIA hourly rates.
The full document, with the table across nine columns, the detailed calculations in the original currencies, the expedited procedure thresholds institution by institution, guidance according to the subject matter of the contract, six drafting rules for the clause and the list of primary sources, is freely available: download the full table as a PDF (September 2026 edition). The schedules change almost every year; the table is rechecked and republished every 1 January and every 1 July, and anyone who wishes to receive each new edition can leave an address below. The firm advises on the drafting of arbitration clauses and acts in proceedings before these institutions; the international trade law page describes that practice, and the contact form allows a clause or a dispute to be submitted.
Frequently asked questions
What does an ICC arbitration cost for a one million euro dispute?
Under the ICC Schedule of Fees in force since 1 June 2026, a dispute of 1,146,000 dollars (one million euros) before a sole arbitrator generates 23,512 dollars of administrative fees and arbitrator fees of between 15,633 and 69,392 dollars, that is a total of 34,000 to 81,000 euros, average 57,600 euros, excluding the 5,000 dollar filing fee credited against the advance. Because that amount is below 4 million dollars, the expedited procedure applies automatically to clauses concluded since 1 June 2026 and cuts arbitrator fees by 20 per cent, bringing the average down to 50,200 euros.
Which arbitral institution is the cheapest for an international commercial dispute?
On the one million euro hypothesis with a sole arbitrator, the lowest totals are those of CIETAC (roughly 26,100 euros, a global fee covering both the institution and the tribunal, 2024 Rules) and of the Paris Maritime Arbitration Chamber (27,540 euros excluding tax, schedule of 16 June 2022). Next come the Swiss Arbitration Centre (26,600 to 77,800 euros depending on the fees fixed) and the SCC (40,200 to 72,000 euros). The lowest price is not the only criterion: the competence of the institution in the subject matter, its ability to handle a challenge or a consolidation, and enforcement of the award where the assets are, count for more.
What is the expedited procedure and does it apply automatically?
The expedited procedure is a lighter regime, generally before a sole arbitrator, with a compressed timetable and sometimes a reduced schedule. It applies automatically below an amount threshold at the ICC (4 million dollars for clauses concluded since 1 June 2026), the Swiss Arbitration Centre (1 million Swiss francs), the HKIAC (50 million Hong Kong dollars since 1 January 2026), the ICDR (500,000 dollars), CIETAC (5 million yuan) and the SCMA (300,000 dollars). It is optional and requires the agreement of the parties at the SCC and at WIPO, is available on application at the SIAC between one and ten million Singapore dollars, and does not exist at the LCIA.
When were the figures checked and when will they be updated?
All the schedules were reread on the institutions official websites on 20 September 2026: ICC Schedule of Fees of 1 June 2026, SIAC Schedule of Fees 2025, HKIAC rates applicable since 1 January 2026, Appendix IV of the SCC Rules 2023 with the 2024 rates, Appendix B of the Swiss Rules 2021, ICDR schedule of 1 September 2025, WIPO schedule of 1 July 2021, CIETAC Rules 2024, SCMA Schedule of Fees 2022, CAMP schedule of 16 June 2022, ICSID Schedule of Fees 2023. Conversions use European Central Bank rates of 18 September 2026. The table is rechecked and republished every 1 January and every 1 July.
Does the amount in dispute include the counterclaim?
Under most schedules, yes: the ICC, the SCC and the Swiss Arbitration Centre calculate fees on the aggregate of claims and counterclaims, which can move into a higher band a case whose original claim was modest. CIETAC takes the amount claimed by the claimant and applies a separate calculation to the counterclaim. The SCMA, for the purposes of its expedited procedure, adds claim and counterclaim excluding interest and costs. A party contemplating a substantial counterclaim must therefore expect it to increase the advance on both sides, not only its own.
Who advances the costs of the arbitration?
The rules provide for an advance paid in equal shares by each party, the institution being able to ask the claimant to substitute itself for a defaulting respondent, leaving the award to allocate costs afterwards. At the ICC, the 5,000 dollar filing fee is credited against the claimant share; at the CAMP, the initial deposit of 2,000 euros excluding tax and the further deposits of 50 per cent each are credited against the final account. The SIAC also asks for a deposit uplifted by 15 per cent over the estimated maximum. A party that refuses to pay its share does not stop the arbitration going forward, but it obliges the other to fund the proceedings until the award.
Are arbitration costs recoverable against the losing party?
The rules give the tribunal power to allocate the costs of the arbitration and, generally, the reasonable costs of the parties, including their counsel fees. The most widespread principle is that costs follow the event, with a discretion that takes account of how each party has conducted the proceedings. Some procedures cap recovery: the SCMA limits recoverable counsel fees to 15,000 dollars below 200,000 dollars in dispute and to 20,000 dollars up to 300,000 dollars. Recovery then depends on the award being enforced, which brings one back to the question of where the debtor keeps its assets.
Can the clause cap the arbitrator hourly rate?
Yes, in those institutions where the arbitrator is paid for time spent. The HKIAC rules themselves set a cap of 7,500 Hong Kong dollars an hour, which the parties may lower by agreement. At the LCIA the band of 250 to 650 pounds is fixed by the Schedule of Costs and any excess requires the express agreement of all parties. At the ICDR and the SCMA, where the arbitrator sets his own rate, a stipulation in the clause fixing a cap or a method of remuneration binds the institution and the arbitrator who accepts the appointment. The stipulation costs nothing at signature; it is worth a good deal when the dispute arises.
Is a clause naming a non-existent or misnamed institution valid?
So called pathological clauses are common: “Paris Chamber of Commerce”, “Geneva arbitration”, “ICC of Singapore”. The French courts and most institutions try to save them by looking for the common intention of the parties, and the ICC will administer an arbitration where the reference, imperfect though it is, identifies it recognisably. But every pathological clause opens a preliminary dispute about jurisdiction, whose cost is added to those in the table and whose outcome remains uncertain. The model clause published by each institution, copied without amendment, avoids that risk at no cost.
Read next
- ICC, SIAC and SCC: the ad valorem schedules and what they guarantee
- LCIA, ICDR and HKIAC: arbitrating at an hourly rate without losing control of the budget
- Swiss Arbitration Centre, WIPO and CIETAC: three specialised schedules
- Maritime arbitration: CAMP and SCMA against the generalist institutions
- ICSID: what investor state arbitration costs and why it does not compare