This twenty-seven-page practical guide deals with arbitration in Singapore from the standpoint of a French company, from drafting the arbitration clause to enforcing the award against assets located in France. It starts from a simple observation: in most contracts, the Singapore seat is not chosen, it is accepted, and the consequences of that acceptance are discovered when the dispute arises.
Twelve parts follow the life of the contract: what choosing Singapore really entails, the six decisions the clause takes on your behalf, the procedures the 2025 SIAC Rules trigger without you, the emergency measure obtained before the tribunal is constituted, joinder and consolidation where several contracts are involved, the possibility of having an issue decided or a claim dismissed before the hearing, funding the case and the real cost of the proceedings, confidentiality and its gaps, challenges before the Singapore court, enforcement in France under articles 1514 et seq. of the French Code of Civil Procedure, the maritime case and the choice between the Singapore maritime chamber and the international centre, and finally negotiating the clause when it comes from the other side.
The guide ends with a roadmap of fifteen decisions to make before signing, model clauses with commentary and a glossary. It is written for legal departments, managers of exporting companies, traders, shipowners and charterers, and advisers who draft international contracts without practising Asian arbitration on a daily basis.
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Frequently asked questions
Who is this guide for?
For the legal departments and executives of French companies whose contracts designate Singapore as the seat of arbitration, or who are offered such a clause by an Asian partner. Commodity trading, chartering and maritime transport, distribution, industrial joint ventures, technology licences and equity investments are the most common configurations. The guide assumes familiarity with business life, not experience of international arbitration.
What exactly does the guide contain?
Twenty-seven pages organised in twelve parts, following the contract from the negotiation of the clause to attachment in France. They cover the choice of seat and its consequences, the six decisions the clause takes on your behalf, the 2025 SIAC Rules and their automatic procedures, emergency relief, joinder of multiple contracts, early dismissal of claims, funding of the case, confidentiality, challenges before the Singapore court, enforcement in France, the maritime case and the negotiation of an imposed clause.
Why do so many French companies accept a seat in Singapore?
Because the partner insists on it, and because the Singapore framework is predictable. The International Arbitration Act 1994 incorporates the UNCITRAL Model Law, judicial review is narrow, and the New York Convention allows the award to circulate in more than one hundred and sixty States. The guide explains what this predictability costs in return, in particular as regards the law applicable to the clause itself, a question decided by the Singapore Court of Appeal in the Anupam Mittal case in 2023.
How long does a SIAC arbitration take?
It depends on the applicable procedure, and that procedure is often triggered without the parties having chosen it. The 2025 Rules provide for an expedited route below a certain threshold, an even shorter streamlined procedure, and mechanisms for deciding an issue or dismissing a claim before the hearing. The guide describes each of these routes, their time limits and how the drafting of the clause can open or close them.
Can emergency relief be obtained before the tribunal is constituted?
Yes. The SIAC Rules allow an application to an emergency arbitrator, who is appointed within a very short time, before the arbitral tribunal is even formed. The guide sets out the conditions for the application, what the emergency arbitrator can order, what he or she cannot, and how this fits with the conservatory attachment that the French judge may authorise over assets located in France while the arbitration continues.
Is an award made in Singapore enforceable in France?
Not automatically. It must be granted exequatur by the Paris Judicial Court, under the procedure in articles 1514 et seq. of the French Code of Civil Procedure. The French judge’s review covers a limited number of grounds and does not retry the merits. The guide details the documents to be produced, how the application proceeds, the remedies open to the opponent and the enforcement measures that follow.
Does the guide make it unnecessary to consult a lawyer?
No, and it does not try to. It provides the vocabulary, the chronology and the questions to ask, so that one arrives prepared for the negotiation or the dispute. At least three decisions cannot be settled by any template: the choice of institution, the drafting of the clause when it comes from the other side, and the choice between a challenge in Singapore and resisting exequatur in France. They depend on the case.
On related questions, the firm has published an analysis of the enforcement in France of a Singapore judgment, a study of the application for exequatur of an arbitral award, the documents to be produced and the remedies, and an overview of conservatory attachments of the debtor’s assets in France before exequatur.
While the guide is on its way, the related analyses are freely available: Arbitration in Singapore, SIAC, SCMA or ad hoc, on the choice of seat and institution; SIAC arbitration clause, on the six decisions to make before signing; SIAC Rules 2025, on the streamlined procedure that applies without you; SIAC emergency arbitrator, on relief obtained within twenty-four hours; Enforcing in France an award made in Singapore, on exequatur and attachments; Challenging an award made in Singapore, on annulment, the SICC and the reform under way.