In January 2026, a Grenoble software publisher claimed from a Shenzhen electronics manufacturer 7.7 million yuan, a little over one million euros, of unpaid royalties under a technology licence signed in 2022. The clause referred to CIETAC in Beijing, and said nothing about the number of arbitrators or the language. The Chinese manufacturer, as respondent, obtained a three member tribunal and proceedings in Mandarin, because the rules so provide above 5 million yuan and the clause did not displace them. The arbitration fee itself did not move: 200,125 yuan, that is 26,073 euros, institution and tribunal included. What moved was the translation bill, the duration, and the position of the licensor before a panel of which it had appointed only one member. A reference to WIPO in Geneva would have cost 5,236 euros of institutional fees and an arbitrator paid by the hour, and produced an award to be recognised in China under the New York Convention. A different matter altogether.
This page examines three institutions: the Swiss Arbitration Centre, for a neutral seat and a readable schedule; the WIPO Arbitration and Mediation Center, for intellectual property and technology disputes; and CIETAC, for contracts with a Chinese counterparty and enforcement in mainland China. It costs each one on the common hypothesis, a dispute of roughly one million euros before a sole arbitrator, then deals with the price of neutrality, enforcement in China and the stipulations to be added to the model clauses. Schedules checked on 20 September 2026, conversions at European Central Bank rates of 18 September 2026.
1. Swiss Arbitration Centre: the Appendix B schedule and an expedited procedure that applies automatically
The Swiss Arbitration Centre applies the Swiss Rules 2021, in force since 1 June 2021, whose Appendix B contains the schedule. First peculiarity, the registration fee is payable per party, not per case: 4,500 Swiss francs (4,756 euros) for a dispute up to 2 million francs, 6,000 francs from 2 to 10 million, 8,000 francs above that, the respondent who brings a counterclaim paying its own. The amount is neither refundable nor credited against the advance. A case with a counterclaim therefore costs 9,000 francs before anyone has read a document.
Second peculiarity, the administrative fees are the lowest of the schedule institutions in the table. For 946,000 Swiss francs in dispute, the band of 600,001 to 1 million francs gives 3,000 francs (3,171 euros). Nothing below 300,000 francs, a cap at 75,000 francs, 10 per cent more per additional party beyond two. The Centre does not make its money on administration; it makes it on confidence in its seat.
The fees of the sole arbitrator are read on the same grid. For 946,000 francs, the minimum is 22,152 francs (23,412 euros), the maximum 70,608 francs (74,623 euros), and the average, the one shown by the official calculator on swissarbitration.org, 46,380 francs (49,017 euros). Administrative fees and arbitrator together, the dispute costs between 25,152 and 73,608 francs, average 49,380 francs, that is 26,582, 52,188 and 77,793 euros. A three member tribunal receives 250 per cent of the sole arbitrator fees.
That question is often settled without the parties. Article 42 subjects automatically to the expedited procedure any dispute whose amount does not exceed 1 million Swiss francs, unless the Arbitration Court decides otherwise: sole arbitrator, a single exchange of submissions, award within six months. Our hypothesis falls within it. If the parties refuse a sole arbitrator where the rules impose one, Appendix B provides that the arbitrators are paid at least 350 francs an hour, which is the Swiss way of charging for obstinacy. The counterclaim is added to the claim for the purposes of the threshold, and a counterclaim of any size takes the dispute out of the expedited procedure without anyone having intended it.
2. WIPO: a modest schedule, an arbitrator by the hour, a flat fee under the expedited rules
The WIPO Arbitration and Mediation Center in Geneva administers arbitrations under Arbitration Rules and Expedited Arbitration Rules dated 2021, with a schedule in dollars in force since 1 July 2021. In ordinary arbitration the registration fee is 2,000 dollars (1,745 euros), non refundable under article 69, and the administration fee 4,000 dollars (3,490 euros) for any dispute up to 2.5 million dollars, under article 70. The institution therefore costs 6,000 dollars (5,236 euros). A business with fewer than 250 employees obtains a 25 per cent reduction on both items.
The arbitrator, by contrast, is not on a schedule. Article 71 provides that the Center fixes his hourly rate before the tribunal is constituted, within an indicative band of 300 to 600 dollars an hour (262 to 524 euros) up to 2.5 million dollars. The arbitrator keeps a time record, and article 72 organises equal deposits from the parties. The final cost depends on the number of hours, and the Center publishes no average cost statistics: an uncertainty the clause does not remove.
The Expedited Arbitration Rules work on a different logic. No registration fee, 2,000 dollars of administration, and above all a sole arbitrator paid a flat 20,000 dollars (17,450 euros) up to 2.5 million dollars, adjustable for complexity. The total comes to around 22,000 dollars (19,197 euros). The quid pro quo is strict: a hearing of three days at most, closure of the proceedings within three months, award within the following month. No threshold triggers this regime; it is chosen in the clause. I know of no better ratio of cost to quality of tribunal for a licence agreement.
What justifies WIPO is not read in the schedule. The Center keeps a list of arbitrators specialising in patents, trade marks, software and data, and its rules contain confidentiality provisions wider than those of generalist rules: confidentiality of the very existence of the arbitration, protection of sensitive information produced during the proceedings, confidentiality of the award. For a dispute over know how or source code, that is the point that decides.
3. CIETAC: a global fee, three arbitrators by default, and a Hong Kong branch
The China International Economic and Trade Arbitration Commission applies its Arbitration Rules 2024, in force since 1 January 2024, whose Appendix II fixes the fees. For international and foreign related cases, Schedule I applies, in yuan. The registration fee is 10,000 yuan (1,303 euros), non refundable. The arbitration fee, for our dispute of 7,675,000 yuan, is calculated in the band of 5 to 10 million: 150,000 yuan plus 1.5 per cent of the fraction above 5 million, that is 190,125 yuan (24,770 euros). Total: 200,125 yuan, 26,073 euros, with the actual expenses of the tribunal in addition under note 5 of the schedule, a figure confirmed by the official calculator on cietac.org.
This fee is global. It covers both the institution and the tribunal, with no distinction between a sole arbitrator and a panel of three, which places CIETAC just behind the CAMP in the table. That ranking should be read with care. Article 85 of the rules allows special remuneration of arbitrators, possibly hourly, by agreement of the parties or on the arbitrator proposal with the consent of the party appointing him, and the global fee then ceases to be global. The mechanism is rare, but it exists.
The number of arbitrators is fixed by default against the claimant. The summary procedure of article 59 applies automatically up to 5 million yuan, roughly 650,000 euros, with a sole arbitrator and no fee reduction. Above that, article 25(2) provides for three arbitrators unless otherwise agreed. The arbitration fee does not change; the duration, the actual expenses of three arbitrators and the weight of translation do. The Grenoble publisher in the introduction learned this the hard way.
CIETAC also has a centre in Hong Kong, governed by Schedule III of Appendix II: registration fee of 8,000 Hong Kong dollars, separate administrative fees, and arbitrator fees billed hourly up to 7,000 Hong Kong dollars. Cost there is less predictable than in Beijing, but the award is a Hong Kong award, made under an arbitration law of English tradition and enforceable in mainland China through the arrangement between the two legal orders. That choice is often worth the difference in price.
4. Choosing a neutral seat without paying for neutrality
A Bordeaux wine merchant and a Hamburg importer negotiated in 2025 a five year exclusive distribution agreement, with forecast turnover of one million euros a year. Neither wanted to arbitrate on the other home ground. The usual answer is a third seat: Geneva or Zurich under the Swiss Rules, London under the LCIA, or Paris under the ICC. What that neutrality costs can be put in a sentence: in Switzerland, no more than anywhere else, and often less.
On our hypothesis, the Swiss Arbitration Centre charges between 26,582 and 77,793 euros, average 52,188 euros, registration fee excluded. The ICC charges between 34,158 and 81,068 euros, average 57,613 euros. The LCIA, whose reported median for cases of one to ten million dollars is 103,800 euros, costs twice as much. The myth of Swiss expense comes from the fees of Zurich counsel, which appear in no schedule, not from the institution.
Neutrality is also measured by the law of the seat and by what it allows against the award. An award made in Switzerland in an international arbitration falls under chapter 12 of the Federal Act on Private International Law: direct recourse to the Federal Tribunal, grounds exhaustively listed in article 190, a single instance, and the possibility for parties none of whom is domiciled in Switzerland to waive all recourse in advance under article 192. An award made in Paris opens the action to set aside under articles 1518 and following of the Code of Civil Procedure before the Court of Appeal, then an appeal to the Court of Cassation. An award made in London falls under the Arbitration Act 1996, as amended by the Arbitration Act 2025, with an appeal on a point of law that institutional rules generally exclude. The shortest post award litigation is the Swiss one. One trap, though: the article 192 waiver must be expressly stipulated, and it also deprives the winning party of any recourse against an award that gave it less than it claimed.
For the Bordeaux merchant, the sensible clause is therefore Swiss Rules, seat in Geneva, sole arbitrator, and no waiver of recourse. What Switzerland charges for is care in the drafting, not the procedure.
5. Enforcement in mainland China: the seat decides before the institution
A contract with a Chinese party is judged at the end, against assets in Shenzhen or Ningbo. Three routes exist. The first is the New York Convention of 1958, to which the People Republic of China acceded with the reciprocity and commerciality reservations. An award made in Geneva, Paris or London is recognised there by the intermediate people court of the place of the assets, subject to the grounds for refusal in article V, and a Chinese court cannot refuse without referring the matter up to the Supreme People Court. The mechanism works, with a delay, a certified translation, and no interim measures before recognition.
The second route is a CIETAC award seated in mainland China. That is not a foreign award: it is a Chinese award with a foreign element, enforced under the Chinese Civil Procedure Law, with interim measures available during the proceedings through the institution. It is the shortest route to the debtor assets. It has its reverse side: proceedings in Chinese if the clause is silent, review of the award by Chinese courts, and a reduced pool of foreign arbitrators as soon as the language is Mandarin.
The third route is a seat in Hong Kong. An award made in Hong Kong, under the auspices of CIETAC Hong Kong or the HKIAC, is enforced in mainland China under the arrangement concluded between the Special Administrative Region and the mainland on reciprocal enforcement of arbitral awards, supplemented in 2020; a separate arrangement of 2019 also opens to parties to an arbitration seated in Hong Kong and administered by a qualified institution the interim measures of mainland courts before the award.
My position is clear. For a contract with a Chinese partner whose assets are in China, a seat in Hong Kong beats Beijing as soon as the French party may be respondent, and beats Geneva or Paris as soon as it may be claimant. What cannot be costed is how the intermediate courts of a given province will treat a given award; anyone who says otherwise is selling something.
6. The model clauses and what has to be added to them
All three institutions publish a model clause, and all three are incomplete by design. The Swiss Arbitration Centre clause submits to the Swiss Rules in force at the date of the notice of arbitration any dispute arising out of the contract, then leaves three blanks: the number of arbitrators, the seat, the language. For a dispute whose likely amount is close to one million francs, an express stipulation on the expedited procedure has to be added, failing which the size of the counterclaim will decide in the parties place. The article 192 waiver is not presumed; if it is wanted, it is written.
The WIPO clause is more complete. It covers the contract and its amendments, including non contractual claims, and provides blanks for the number of arbitrators, the place, the language and the law governing the merits. The decisive choice is made before the blanks are filled in: the model clause refers either to the Arbitration Rules or to the Expedited Arbitration Rules, and those are two different clauses. Below 2.5 million dollars of likely exposure, the expedited version, with its flat fee of 20,000 dollars, is the one to take, supplemented by a stipulation on the confidentiality of source code or technical data produced.
The CIETAC clause is the shortest and the most dangerous. It submits any dispute arising from or in connection with the contract to CIETAC for arbitration under its rules in force at the date of the application, and declares the award final and binding. Nothing on the number of arbitrators, so three above 5 million yuan. Nothing on the language, so Chinese. Nothing on the seat, so that of the commission administering the case. The sole arbitrator has to be written in, together with English or French as the language and, if Hong Kong is wanted, an express designation of the CIETAC Hong Kong Arbitration Center and of Hong Kong as the seat. One precaution specific to Chinese law: the agreement must designate an identified arbitral institution, and a clause referring to ad hoc arbitration in mainland China risks being held invalid by a Chinese court. In all three cases, the number of arbitrators is the line that pays best. One word in the clause. Tens of thousands of euros when the dispute comes.
The full document, with the table of twelve institutions, the calculations in the original currencies, the expedited procedure thresholds and the primary sources, is freely available: download the full table as a PDF. The firm drafts arbitration clauses for licence, distribution and supply contracts and assists clients before these institutions; the international trade law page describes that practice, and the contact form allows a clause or a draft contract to be submitted.
Frequently asked questions
Why is the Swiss registration fee payable by each party?
Appendix B of the Swiss Rules 2021 puts the registration fee on the party seising the Centre, the claimant for the claim, the respondent for the counterclaim: 4,500 Swiss francs up to 2 million, 6,000 francs up to 10 million, 8,000 above, neither refunded nor credited against the advance. A case with a counterclaim therefore costs more to open than at the ICC or the SCC, but administrative fees of only 3,000 francs for one million francs in dispute make up the difference.
Is WIPO arbitration reserved for intellectual property disputes?
No. The WIPO Arbitration Rules may be chosen for any commercial dispute, and the Center administers distribution and joint venture cases wherever a technological or intangible element is at stake. Its specialisation lies in its list of arbitrators, its confidentiality provisions and the experience of its secretariat in patents, software and data. A trade mark licence, a technology transfer or a software development agreement are natural candidates; a charterparty would make less sense.
Is the CIETAC figure of 200,125 yuan really all inclusive?
The arbitration fee under Schedule I covers administration and the remuneration of the tribunal, whether it has one member or three. Three items are added: the actual expenses of the arbitrators, charged separately under note 5 of the schedule; the special remuneration of article 85, possibly hourly, by agreement of the parties; and, if the case is administered in Hong Kong, Schedule III, which separates registration, administration and hourly fees capped at 7,000 Hong Kong dollars. Outside those cases, the figure is firm.
Is an award made in Geneva enforceable in China?
Yes, under the New York Convention of 1958, to which Switzerland and China are both parties. The application is made to the intermediate people court of the place where the debtor assets are. The grounds for refusal are those of article V, and a Chinese court cannot refuse recognition without referring the matter up to the Supreme People Court. The route is workable, longer than enforcement of a CIETAC or Hong Kong award, and without interim measures in China during the arbitration.
Can recourse against a Swiss award be waived in advance?
Article 192 of the Federal Act on Private International Law allows it where none of the parties has its domicile, habitual residence or seat in Switzerland. The waiver must be express; an ordinary arbitration clause does not carry it. It removes recourse to the Federal Tribunal, already limited to the grounds of article 190. It cuts both ways and deprives a party with a serious grievance as well. The firm recommends it only between parties of equal strength, and for limited exposure.