SIAC Arbitration for Bangladeshi Parties 2026: SIAC Rules 2025, Fees, Interim Relief and Enforcement

SIAC arbitration Bangladesh parties face in 2026: the new rules and the Dhaka reality

SIAC arbitration Bangladesh businesses agree to in their cross-border contracts now runs on a new rulebook. The seventh edition of the SIAC Rules came into force on 1 January 2025 and applies, unless the parties agree otherwise, to every SIAC arbitration commenced on or after that date, including those under older contracts that refer to the rules "for the time being in force".[1] A revised Schedule of Fees took effect on the same day.[3] For a Bangladeshi party the rules are only half the picture. What happens in Dhaka before and after the award, from interim relief to enforcement under section 45 of the Arbitration Act 2001, decides whether a Singapore arbitration actually delivers.

This guide is written for Bangladeshi claimants, respondents and in-house teams. It covers the 2025 changes, filing and tribunal constitution, the fee schedule, the fast-track procedures, the emergency arbitrator, the Singapore seat, the interim relief gap in Dhaka and enforcement of SIAC awards in Bangladesh.

Summary: SIAC Rules 2025 apply to SIAC arbitrations commenced from 1 January 2025. They add a Streamlined Procedure for disputes up to S$1 million, an ex parte protective preliminary order before an emergency arbitrator, preliminary determinations and mandatory disclosure of third-party funding. A Bangladeshi party pays the overseas filing fee of S$3,000, and administration and arbitrator fees are capped by the amount in dispute. Bangladeshi courts currently refuse section 7A interim relief for Singapore-seated arbitrations, but a SIAC award is enforced as a decree of the District Judge's court in Dhaka under section 45, subject only to the section 46 grounds and a three-year filing period.

Key point: Plan interim protection inside the arbitration, not in Dhaka. On 12 July 2026, in a SIAC case commenced in August 2025 in which the tribunal still had not been constituted, the High Court Division recalled its own interim order over 107 tank containers and dismissed the section 7A application, because the Larger Bench decision in Accom Travels v Oman Air bars such relief where the seat is outside Bangladesh. The judge doubted Accom but held himself bound by it.

At a glance

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Table of Contents

Why SIAC arbitration Bangladesh contracts so often specify

Singapore is the foreign seat Bangladeshi parties meet most often in Asian trade, shipping, energy and supply contracts. The leading practice guide to Bangladesh names the SIAC, alongside the ICC and ICSID, among the institutions commonly chosen by Bangladeshi parties.[7] SIAC itself reported 886 new cases in 2025, its second-highest annual caseload, with 89 per cent international and parties drawn from 79 jurisdictions.[4]

The appeal is practical: Singapore is close to Dhaka, works in English, has supportive courts, and its awards are enforceable in Bangladesh under the New York Convention. Bangladesh acceded to the Convention on 6 May 1992 and Singapore on 21 August 1986.[12]

The trade-off is that a Singapore seat takes the arbitration outside most of the Arbitration Act 2001. Section 3(1) applies the Act where the place of arbitration is in Bangladesh, and section 3(2) extends only sections 45, 46 and 47, the foreign award provisions, to arbitrations seated abroad.[6] Every SIAC arbitration Bangladesh parties sign up to should be assessed with that limit in mind. Our wider guide to international commercial arbitration in Bangladesh compares SIAC with BIAC, the ICC and the LCIA; this article goes deeper into SIAC alone.

What changed in the SIAC Rules 2025

The seventh edition was published on 9 December 2024. Rajah & Tann summarises the headline changes as three new procedures (the Streamlined Procedure, Preliminary Determination and Coordinated Proceedings), revisions to the Expedited Procedure and emergency arbitrator procedure, updated appointment provisions, integration of the SIAC Gateway case management system and provisions encouraging mediation.[3]

New procedural tools

Rule 13 creates the Streamlined Procedure, which applies by default where the amount in dispute does not exceed S$1 million before the tribunal is constituted.[1] Rule 46 allows a party to apply for a final and binding preliminary determination of any issue, and an accepted application must be decided within 90 days of filing unless the Registrar extends time.[1] Rule 47 keeps the early dismissal of claims or defences that are manifestly without legal merit or manifestly outside jurisdiction, with a decision due within 45 days.[1] Rule 17 lets the same tribunal hearing two or more arbitrations run them concurrently, in sequence or with one suspended.[3]

Transparency and case management

Rule 38 requires each party to disclose the existence of any third-party funding agreement and the funder's identity and contact details in its Notice or Response, or as soon as a funding agreement is concluded. The tribunal may take the funding into account when apportioning costs and may sanction non-disclosure.[1] Rule 6.1 allows filing through SIAC Gateway, and Rule 53 requires the draft award to be submitted for scrutiny within 90 days of the last submission unless the Registrar determines otherwise; no award issues until the Registrar approves its form.[1]

Security and mediation

The tribunal may order security for costs under Rule 48 and, under Rule 49, security against the claim itself from the party responding to it.[1] For a Bangladeshi claimant facing a counterparty that is moving assets, Rule 49 is a significant tool, because Bangladeshi courts will not grant equivalent relief while a foreign-seated arbitration is pending. At the first case management conference the tribunal may also raise mediation under the SIAC-SIMC Arb-Med-Arb Protocol.[1]

Starting a SIAC arbitration: filing and the first weeks

A SIAC arbitration begins when the Registrar receives the Notice of Arbitration; that date is the date of commencement.[1] Under Rule 6.3 the Notice must include a demand for arbitration, the parties' details, the date and mode of delivery to the respondent, the arbitration agreement and underlying contract, a statement of the dispute with the relief sought and an initial estimate of the claim, comments on the applicable law, seat, language and number of arbitrators, the third-party funding statement and payment of the filing fee.[1] The Registrar may set a time to cure deficiencies and may terminate the arbitration if they are not cured.[1]

The Response and its timetable

The respondent must deliver its Response within 14 days of commencement or of its receipt of the Notice, whichever is later. The Response states its position on the claims, any jurisdictional objection, any counterclaim, cross-claim or set-off with an initial estimate, and its own funding disclosure.[1] Failure to respond does not stop SIAC or the Registrar from proceeding with the case.[1] A Bangladeshi respondent that treats a SIAC notice as a negotiating letter loses the chance to shape the tribunal.

Constituting the tribunal

If the parties have not agreed on the number of arbitrators, a sole arbitrator is appointed unless the Registrar decides the dispute warrants three.[1] The parties have 21 days from commencement to nominate a sole arbitrator jointly, failing which the President of the SIAC Court appoints.[1] For a three-member tribunal, the claimant nominates within 14 days of commencement and the respondent within 14 days of receiving that nomination; the President appoints for a party that fails to nominate and appoints the presiding arbitrator unless another procedure is agreed.[1] Where the parties are of different nationalities, the sole or presiding arbitrator will ordinarily be of a third nationality.[1]

Every nomination is subject to appointment by the President.[1] Constitution can take far longer than the rule periods suggest. In Legend World Tank v Multinational Shipping, the claimant commenced SIAC Arbitration No 465 of 2025 on 18 August 2025, and the respondent's Response filed on 6 April 2026 was still offering to discuss a joint nomination of a sole arbitrator.[8] The sequence below is the one we use for a Bangladeshi claimant.

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Representation

Rule 10.1 allows a party to be represented by any person of its choice, including legal counsel, advocates or other authorised representatives, subject to any applicable law.[1] The Registrar may call for proof of each representative's authority before the tribunal is constituted, so a board resolution and power of attorney should be ready at filing.[1]

SIAC fees in 2025: filing, administration and arbitrators

The 2025 Schedule of Fees applies to arbitrations commenced on or after 1 January 2025, and Rajah & Tann notes that fees have generally risen across the board.[3] A Bangladeshi party is an overseas party for SIAC's purposes. The non-refundable case filing fee is S$3,000 for overseas parties and S$3,270 for Singapore parties, whose figure includes 9 per cent GST.[2]

Administration fees

SIAC's administration fee is a maximum calculated on the sum in dispute. It is S$5,000 up to S$100,000, rising through bands to S$24,000 plus 0.4 per cent of the excess at S$2 million to S$5 million, S$48,000 plus 0.08 per cent of the excess at S$10 million to S$50 million, and a flat S$150,000 above S$1 billion.[2] The minimum is S$5,000 in regular cases and S$2,500 in streamlined cases, unless the Registrar determines otherwise. The fee does not cover the tribunal's fees and expenses, hearing facilities, SIAC's administrative expenses, GST, the emergency arbitrator or a tribunal secretary.[2]

Arbitrators' fees

The arbitrator's fee scale is also a maximum, applied to each arbitrator. It runs from S$5,000 for sums up to S$50,000, to S$85,000 plus 1.5 per cent of the excess at S$2 million to S$5 million, S$170,000 plus 0.3 per cent of the excess at S$10 million to S$50 million, and S$820,000 plus 0.04 per cent of the excess above S$1 billion, subject to a S$2 million ceiling.[2] The figures exclude GST where applicable, and withholding tax applies to income of non-resident arbitrators from arbitration work in Singapore from 1 April 2023, subject to any double tax agreement.[2]

The maxima at four sample values are set out below. They are ceilings, not estimates; legal fees, experts and hearing costs come on top.

Deposits and who pays

The Registrar fixes deposits towards the estimated costs on the basis of the amount in dispute, payable 50 per cent by the claimant side and 50 per cent by the respondent side unless directed otherwise, and may fix separate deposits for counterclaims.[1] The parties are jointly and severally liable for the costs of the arbitration. If one side does not pay, the other may be directed to pay its share, and the Registrar may suspend the case or treat an unfunded claim or counterclaim as withdrawn.[1] A Bangladeshi claimant should budget for the whole deposit.

At the end of the case the Registrar determines the costs of the arbitration, which include the tribunal's and SIAC's fees, the emergency arbitrator's fees, any tribunal secretary and tribunal expert, and the filing fees.[1] The tribunal may order one party to pay all or part of another's legal and other costs, taking account of conduct.[1] For how these figures compare with BIAC and ad hoc arbitration at home, see our analysis of the cost of arbitration in Bangladesh.

Streamlined and Expedited Procedures under the SIAC Rules 2025

The two fast-track procedures are the main cost controls for a mid-sized SIAC arbitration Bangladesh exporters and importers are likely to face.

The Streamlined Procedure: up to S$1 million

Under Rule 13.1 the Streamlined Procedure applies where the parties agree to it before the tribunal is constituted, or where the amount in dispute does not exceed S$1 million at that point, unless the President decides otherwise on a party's application. The parties may exclude it in writing.[1] Schedule 2 overrides any contrary term in the arbitration agreement, including a clause providing for three arbitrators: a sole arbitrator is appointed, with only three days for a joint nomination after SIAC notifies the parties that the procedure applies.[1]

The tribunal must hold a case management conference within five days of its constitution. Unless it decides otherwise, the case is decided on written submissions and documents, with no document production requests and no fact or expert witness evidence, and any hearing is held remotely.[1] The final award is due within three months of constitution unless the Registrar extends time.[1] Preliminary determination and early dismissal applications are not available.[1]

The Streamlined Procedure is also cheaper. The tribunal's fees and SIAC's fees may not exceed 50 per cent of the maximum scale, unless the Registrar determines otherwise.[1] SIAC reported that 60 cases proceeded under the Streamlined Procedure in its first year.[4]

The Expedited Procedure: up to S$10 million

The Expedited Procedure applies where the parties have agreed to it, or on a party's application before constitution where the amount in dispute is above S$1 million but not more than S$10 million, where the President has disapplied the Streamlined Procedure in a smaller case, or where the circumstances warrant it.[1] The ceiling was previously S$6 million.[3] By default the case is decided on documents, any hearing is virtual, and the final award is due within six months of the tribunal's constitution, unless the Registrar extends time.[1] [3] In 2025 SIAC accepted 55 of 130 applications for the Expedited Procedure, so an application must be argued, not assumed.[4]

Choosing between them

The choice is usually made at the drafting stage. A party expecting complex technical evidence below S$1 million should consider excluding the Streamlined Procedure in writing, because Schedule 2 restricts witness and expert evidence by default.[1] Under either timetable, SIAC arbitration Bangladesh parties need their documents assembled in Dhaka before filing, not after.

The emergency arbitrator under the SIAC Rules 2025

Under Rule 12.1 and Schedule 1, a party may apply for an emergency arbitrator at any time before the tribunal is constituted, including before the Notice of Arbitration; if the application comes first, the Notice must follow within seven days of the Registrar's receipt of the application or the application is treated as withdrawn.[1] The application must explain why relief cannot await the tribunal.[1]

Speed and cost

The President seeks to make the appointment within 24 hours of the later of receipt of the application and receipt of payment, and a schedule must be set within 24 hours of appointment.[1] The order or award is due within 14 days of appointment unless the Registrar extends time, and must be approved by the Registrar as to form.[1] An overseas applicant pays a non-refundable S$5,000 administration fee and a S$30,000 deposit towards the emergency arbitrator's fees and expenses; the emergency arbitrator's fee is fixed at S$25,000, in each case unless the Registrar determines otherwise.[2]

Protective preliminary orders

The most significant change for parties worried about dissipation is the protective preliminary order. Unless the parties agree otherwise, an applicant may apply without notice to the other side for an order directing a party not to frustrate the purpose of the emergency relief sought. The emergency arbitrator must decide it within 24 hours of appointment.[1] The applicant must then serve the full case papers on every party within 12 hours of SIAC transmitting the order, failing which the order expires three days after issue; in any event it lapses 14 days after issue unless adopted or modified after both sides are heard.[1] SIAC received four such applications in 2025 and accepted one.[4]

How binding the relief is

The parties are deemed to agree that an emergency order or award binds them from the date it is made and must be carried out immediately, and they waive recourse to any court against it so far as such a waiver can validly be made.[1] It ceases to bind if the tribunal is not constituted within 90 days of the order, unless the Registrar extends time, and the tribunal may affirm, modify or vacate it.[1] If the parties have not agreed a seat, the seat of the emergency proceedings is Singapore.[1]

Will Bangladesh enforce an emergency award?

Singapore law treats an emergency arbitrator as part of the arbitral tribunal: the International Arbitration Act 1994 defines "arbitral tribunal" to include an emergency arbitrator appointed under institutional rules.[5] Bangladeshi law does not. The Arbitration Act 2001 defines an arbitral tribunal as a sole arbitrator or a panel of arbitrators and an arbitral award as a decision on the issue in dispute, and it contains no provisions on emergency arbitrators.[6] [7] We are not aware of a reported Bangladeshi decision enforcing a foreign emergency award under section 45. For SIAC arbitration Bangladesh counterparties, treat an emergency award as leverage and as enforceable where assets sit abroad, not as a Dhaka enforcement tool.

The Singapore seat and the International Arbitration Act

The SIAC Rules do not themselves put the seat in Singapore. Rule 36.1 lets the parties agree the seat and, failing agreement, the tribunal determines it.[1] The SIAC model clause leaves the seat as a blank defaulting to "[Singapore]" and recommends that parties also state the law governing the arbitration agreement.[1] A clause that names SIAC but not the seat invites an early fight, so state the seat expressly.

What the International Arbitration Act provides

Where Singapore is the seat of an international arbitration, the International Arbitration Act 1994 applies. Section 19B makes the award final and binding on the parties and those claiming through them.[5] The award can be challenged only in the Singapore courts: on the Model Law grounds in Article 34(2), and under section 24 where the award was induced or affected by fraud or corruption or where a breach of natural justice prejudiced a party's rights.[5] Article 34(3) bars an application made more than three months after the applicant received the award.[5]

The SIAC model clause offers optional wording sending Singapore court proceedings to the Singapore International Commercial Court.[1] Section 12A gives the Singapore High Court power to make certain interim orders in support of an arbitration whether or not the seat is in Singapore, though it may decline where the foreign seat makes an order inappropriate.[5]

Bangladeshi courts cannot set aside a Singapore award

The corollary for a Bangladeshi award debtor is stark. A Bangladeshi court has no power to annul an award made at a foreign seat. In South Express v Madina Enterprise, decided on 9 July 2026, the High Court Division held that the power of annulment belongs exclusively to the courts of the seat and that a District Judge's order purporting to set aside a London award was without jurisdiction.[10] A Bangladeshi party that wants to attack a SIAC award must do so in Singapore within three months, or resist enforcement later on the narrow section 46 grounds. Our guide to setting aside an arbitral award in Bangladesh covers only Dhaka-seated awards for this reason.

The Accom Travels gap: interim relief in Bangladesh

Section 7A of the Arbitration Act 2001 allows the High Court Division, in an international commercial arbitration, to order interim protection of property and other measures before or during the proceedings or until the award is enforced under section 44 or 45.[6] On its face that could support a Singapore arbitration over assets in Bangladesh. The courts have held otherwise.

What Accom Travels decided

In Accom Travels and Tours v Oman Air SAOC, reported at 27 BLC 596, a Larger Bench of the High Court Division held by a 2:1 majority that sections 7, 7A and 10 of the Act do not apply to foreign-seated arbitrations, except that section 7A interim measures may be granted at the stage of enforcing a foreign award.[8] Chambers summarises the result: Bangladeshi courts cannot grant interim relief under section 7A before or during a foreign arbitration.[7]

The two judgments of 12 July 2026

Legend World Tank Pte v Multinational Shipping is the clearest SIAC illustration. A Singapore principal alleged that its former Bangladeshi agent had failed to return 107 tank containers. The agency agreement provided for SIAC arbitration in Singapore, and the claimant had commenced SIAC Arbitration No 465 of 2025. At admission the High Court Division ordered disclosure of the containers' location and restrained any dealing with them for three months.[8]

At the final hearing the judge said he was unable to subscribe to Accom. In his view sections 7, 7A and 10 can operate in aid of a foreign-seated arbitration, and Accom had not considered the Appellate Division's decisions in the ECOM litigation. He nonetheless held that a single bench is bound by a Larger Bench, dismissed the application as not maintainable and vacated the interim order, leaving the claimant to seek relief from the arbitral tribunal or another competent forum.[8] The same day, in SVC Jhilmil Residential BD v RAJUK, an application to restrain encashment of a Tk 100 crore performance guarantee under a Singapore-seated PPP arbitration failed for the same reason.[9]

Whether the gap may close

The question is open at the top. Legend World Tank records that in the Italian-Thai case, Civil Petition for Leave to Appeal No 1828 of 2024, the Appellate Division continued interim protection until the first session of the Singapore tribunal and then disposed of the petition as infructuous, without ruling on whether the High Court Division's reading of section 7A was correct.[8] Until the Appellate Division or a bench of equal or greater strength revisits Accom, the High Court Division will follow it.

Protecting your position in practice

For SIAC arbitration Bangladesh parties should therefore build interim protection into the arbitration itself:

• Use the emergency arbitrator early: file the emergency application with, or even before, the Notice, and consider a protective preliminary order where notice would prompt dissipation.[1]
• Ask the tribunal for security: Rule 45 empowers the tribunal to grant interim or conservatory relief, and Rule 49 allows security for the claim.[1]
• Press for fast constitution: the emergency arbitrator cannot act once the tribunal is constituted, but slow constitution is the period of greatest exposure, as Legend World Tank shows.[1] [8]
• Reconsider the seat for asset-heavy deals: where the counterparty's only assets are in Bangladesh, a Dhaka seat with SIAC or BIAC administration keeps section 7A available.[6]

Rule 45.2 confirms that a court application for interim relief, in Singapore or another asset jurisdiction, is not incompatible with the Rules if promptly notified.[1]

Enforcing a SIAC award in Bangladesh under section 45

A SIAC award made at a Singapore seat is a "foreign arbitral award" within section 2(k), because it is made in the territory of a state other than Bangladesh.[6] Section 45(1) makes it binding for all purposes and, on application by any party, enforceable by execution under the Code of Civil Procedure "in the same manner as if it were a decree of the Court", meaning the District Judge's court exercising jurisdiction in the district of Dhaka.[6] Chambers confirms that every foreign award is enforced by the District Court in Dhaka.[7]

What the application needs

Section 45(2) requires the original award or a copy authenticated as required by the law of the country where it was made, the original arbitration agreement or a certified copy, and evidence that the award is a foreign award; section 45(3) deals with certified English translations.[6] Under Rule 52.6 the Registrar can authenticate an award or arbitration agreement on request.[1] Rule 59.3(a) permits disclosure to a court enforcing the award.[1]

One proceeding, narrow defences

In South Express the High Court Division held that the Act does not require two separate proceedings, one for recognition and another for execution, and that the grounds for refusal must be construed narrowly; unless a section 46 ground is affirmatively proved, the court must recognise and enforce the award.[10] Section 46 tracks Article V of the New York Convention: incapacity, an invalid arbitration agreement, lack of proper notice or inability to present a case, excess of the submission, irregular composition or procedure, an award not yet binding or set aside at the seat, non-arbitrability and public policy.[6] A refusal can be appealed to the High Court Division under section 48(c).[6]

The three-year clock

Time is the trap most award creditors miss. In Jess Smith & Sons Cotton v Patriot Spinning Mills, decided on 26 February 2026, the High Court Division held that an application to execute a foreign award under section 45 must be filed within three years of the award under article 182 of the Limitation Act 1908, and that section 5 of that Act cannot be used to condone delay.[11] A creditor that spends two years in settlement talks after a SIAC award may lose the right to enforce in Bangladesh. Diary the date the award is made, not the date talks fail.

Detailed enforcement practice, including authentication and the Apostille Convention, asset tracing and state debtors, is covered in our guide to foreign arbitral award enforcement in Bangladesh.

Bangladeshi respondents in SIAC arbitration

Many Bangladeshi companies meet SIAC as respondents, and the worst response to a Notice is silence. The arbitration proceeds without a Response, the President will appoint an arbitrator for a party that fails to nominate, and Rule 44 allows the tribunal to proceed where a party fails to participate.[1] Any award will then be enforceable against assets in Bangladesh under section 45, subject only to section 46.[6]

What to do in the first 14 days

Calendar the 14-day Response period from the later of commencement and receipt.[1] Raise every jurisdictional objection in the Response: Rule 7.1(d) calls for it, Rule 31.2 makes the Statement of Defence the outer limit, and Rule 64 deems a procedural objection waived if it is not made in writing within the applicable time limit or, absent one, within 15 days of knowledge.[1] Plead any counterclaim or set-off with an estimate of its value, nominate an arbitrator in time if the tribunal is to have three members, and pay the respondent's share of the deposit if the case is worth defending.

Objections that will not work later

A losing respondent cannot reopen in Dhaka what it did not challenge in Singapore. In South Express the High Court Division rejected composition and jurisdiction objections from a debtor that had received notice and failed to appoint its arbitrator, holding that it could not ask the enforcing court to reopen jurisdictional questions already determined by the tribunal.[10] Real objections belong in the arbitration and in the Singapore court within three months of the award.[5]

Drafting a SIAC clause for Bangladesh contracts

Most problems in SIAC arbitration Bangladesh businesses later face start with the clause. The SIAC model clause refers disputes, including questions of existence, validity or termination, to SIAC arbitration under the rules in force, and leaves blanks for the seat, the number of arbitrators, the language and the law governing the arbitration agreement.[1] Each blank matters for a Bangladeshi party:

• Seat: state Singapore expressly, or Dhaka if section 7A relief over local assets is a priority; Rule 36 otherwise leaves the choice to the tribunal.[1]
• Number of arbitrators: choose one or three; for lower-value contracts, remember the Streamlined Procedure will override a three-member clause unless it is excluded in writing.[1]
• Language: English is the norm; Bangla documents will need translation in the arbitration and at enforcement.[6]
• Law of the arbitration agreement: the model clause recommends stating it, because it may govern formation, validity, scope and arbitrability.[1]
• Fast-track options: SIAC publishes separate model clauses for the Expedited Procedure and the Streamlined Procedure.[1]

The institutions and courts a Bangladeshi party deals with in a Singapore-seated SIAC case are set out below.

Common clause defects are discussed with sample wording in our guide to the arbitration clause in Bangladesh contracts. Parties weighing a domestic alternative should read our analysis of BIAC arbitration in Bangladesh.

Choosing counsel for SIAC arbitration Bangladesh matters

A Singapore arbitration with a Bangladeshi party is fought on two fronts: the arbitration itself, often led by Singapore or international counsel, and Bangladesh, where evidence is gathered, assets are protected and the section 45 case is prepared. Weakness on the second front turns a good award into an uncollectable one.

Bangladeshi counsel should be involved from the Notice, not only at enforcement. They can test whether section 7A relief is available, prepare authenticated papers in the form the Dhaka court expects, monitor the three-year limitation period and anticipate a local debtor's public policy arguments.[6] [11] Rule 10.1 places no restriction on mixing counsel from different jurisdictions.[1]

What to watch in 2026

Three developments will shape SIAC arbitration Bangladesh practice over the coming year. First, whether the Appellate Division or a larger bench revisits Accom Travels after the doubts expressed in Legend World Tank.[8] Second, how the High Court Division treats limitation for foreign awards after Jess Smith.[11] Third, how widely the Streamlined Procedure and protective preliminary orders are used as SIAC publishes further data on the 2025 Rules.[4]

TRW advises Bangladeshi and foreign parties on SIAC clauses, filings and defence strategy, interim protection and the enforcement of Singapore awards in Dhaka. Our international arbitration practice can review a clause, a Notice of Arbitration or an award, or you can contact TRW directly.

Frequently asked questions

Do the SIAC Rules 2025 apply to contracts signed before 2025?

Usually yes. The 2025 Rules apply to any SIAC arbitration commenced on or after 1 January 2025 unless the parties have agreed otherwise, so a clause referring to the rules in force will bring in the seventh edition.[1]

What is the SIAC filing fee for a Bangladeshi company?

A Bangladeshi party is an overseas party and pays a non-refundable case filing fee of S$3,000. Singapore parties pay S$3,270, including 9 per cent GST.[2]

How much does a SIAC arbitration cost?

SIAC's administration fee and each arbitrator's fee are capped by the sum in dispute. At S$5 million the maxima are S$36,000 and S$130,000 per arbitrator, before legal fees, experts, hearing costs and GST.[2]

When does the Streamlined Procedure apply?

By default where the amount in dispute is S$1 million or less before the tribunal is constituted, or where the parties agree. A sole arbitrator decides on documents, and the award is due within three months of constitution.[1]

How quickly can a SIAC emergency arbitrator act?

The President seeks to appoint one within 24 hours of the application and payment, a protective preliminary order must be decided within 24 hours of appointment, and the emergency order or award is due within 14 days.[1]

Can a Bangladeshi court grant an injunction in support of a SIAC arbitration seated in Singapore?

Not at present. Following the Larger Bench decision in Accom Travels, the High Court Division dismissed section 7A applications in two Singapore-seated cases on 12 July 2026, although the judge doubted Accom.[8] [9]

Is Singapore the default seat under the SIAC Rules?

No. Rule 36.1 leaves the seat to the parties and, failing agreement, to the tribunal; only emergency proceedings default to a Singapore seat. State the seat in the clause.[1]

Where is a SIAC award enforced in Bangladesh?

In the District Judge's court in Dhaka, by execution under section 45 of the Arbitration Act 2001 as if the award were a decree of that court.[6]

Is there a time limit to enforce a SIAC award in Bangladesh?

Yes. The High Court Division held in February 2026 that the execution application must be filed within three years of the award and that delay cannot be condoned under section 5 of the Limitation Act.[11]

Can a SIAC award be set aside in Bangladesh?

No. Only the courts of the seat can annul it; for a Singapore seat that means the Singapore courts within three months of receipt. In Bangladesh the debtor can only resist enforcement on the section 46 grounds.[5] [10]