ICC, SIAC, and LCIA are
excellent institutions.
They are also incomplete.
The world's leading arbitration institutions were designed for a different era. They are excellent at producing awards. None of them is designed to prevent disputes before they arise, review awards for enforceability before they are issued, or provide institutional support after the award. UNIONE™ was built to close those gaps - not to replace them, but to go further.
The complete institutional scorecard.
Every material dimension across which arbitration institutions can be compared - assessed honestly and specifically. Gold cells indicate the strongest position on each dimension.
| Dimension | ICC | SIAC | LCIA | UNIONE™ |
|---|---|---|---|---|
| Before the Dispute | ||||
| Contract-stage engagementDoes the institution engage before any dispute arises? | ✗ | ✗ | ✗ | ✓ Transaction Lifecycle Framework |
| Dispute Prevention CertificateFormal institutional record of dispute-ready contract | None | None | None | Only Institution |
| Dispute Risk AssessmentStructured pre-dispute risk analysis service | ✗ | ✗ | ✗ | ✓ |
| Standing Neutral for long-term relationshipsPermanent appointed neutral for JVs, infrastructure, supply chains | ✗ | ✗ | ✗ | ✓ |
| The Arbitration Proceedings | ||||
| Award timeline - standard trackTypical duration from commencement to final award | 12–20 months | 12–18 months | 14–24 months | 6 months (bound) |
| Expedited / SME trackDedicated fast-track for lower-value disputes | Expedited (below $3M) | Expedited (below $6M) | Limited | ✓ SME Protocol · 60-day award · Capped fees |
| Cost certainty commitmentWritten pledge not to materially exceed initial estimate | ✗ | ✗ | ✗ | ✓ 20% cap · Written pledge |
| AI evidence protocol in RulesCodified rules for AI-generated evidence and AI tool use | ✗ | ✗ | ✗ | ✓ Rules v3.0, Article 28 |
| Virtual hearings - native supportLegally equivalent virtual hearings, native to the institution | Supported (COVID-era) | Supported | Supported | ✓ Virtual-native · Hearing Intelligence AI |
| Tribunal Secretary rulesExplicit rules governing use, approval, and limits of tribunal secretaries | Guidance note only | Limited | Limited | ✓ Rules v3.0, Article 18 - full codification |
| Early determination procedureFormal mechanism to dispose of manifestly unmeritorious claims | Article 22(i) 2021 Rules | Rule 29A, 2025 Rules | ✗ | ✓ Article 29 - 4 grounds, 30-day decision |
| Third-party funding disclosure rulesCodified obligation to disclose funders at commencement | Partial | ✓ | Partial | ✓ Article 13 - identity, nature, terms disclosure |
| Relationship Preservation WindowFormal built-in settlement window before award is rendered | ✗ | ✗ | ✗ | ✓ Article 45 - 14-day window, without prejudice |
| After the Award - Enforcement | ||||
| Pre-finalisation award reviewInternal institutional review of draft award before it is issued | Scrutiny (form only) | ✗ | ✗ | ✓ ERR - enforceability + procedural + form |
| Enforceability CertificateFormal rated certificate of enforceability issued with every award | None | None | None | Only Institution |
| Post-award compliance monitoringInstitutional documentation of award satisfaction / non-compliance | ✗ | ✗ | ✗ | ✓ 90-day monitoring · Compliance Certificate |
| Enforcement cooperation clause in RulesParty obligation to facilitate enforcement; bad-faith resistance = costs | ✗ | ✗ | ✗ | ✓ Article 38 - costs liability for bad faith |
| Post-award enforcement support serviceLocal counsel identification, certified copies, apostille, jurisdiction strategy | ✗ | ✗ | ✗ | ✓ Article 51 |
| Technology & AI | ||||
| AI clause generatorAI tool to generate arbitration clauses for specific transaction types | ✗ | ✗ | ✗ | ✓ |
| Document Review IntelligenceAI-assisted review of arbitration documents for gaps, risks, inconsistencies | ✗ | ✗ | ✗ | ✓ |
| Hearing Intelligence - live transcription + AI flagsReal-time AI monitoring, transcription and issue flagging during hearings | ✗ | ✗ | ✗ | ✓ |
| Enforceability Predictor toolJurisdiction-by-jurisdiction enforceability assessment pre-filing | ✗ | ✗ | ✗ | ✓ 170+ jurisdictions |
| Institutional Transparency | ||||
| Annual performance data publicationCase stats, duration, enforcement rates published annually | Statistics report | Annual report | Limited | ✓ Full performance report incl. ERR distribution |
| Arbitrator performance metricsPublished anonymised performance data for panel members | ✗ | ✗ | ✗ | ✓ Anonymised · Article 62 |
Eight things ICC, SIAC, and LCIA
do not currently provide.
These are not aspirational features. They are specific, codified services with named articles in UNIONE™ Rules v3.0, available in every case from day one.
The commercial reality of
legacy arbitration.
Cost and duration are not secondary considerations. They are the primary reason mid-market parties avoid international arbitration entirely - and choose worse alternatives.
An award that cannot be enforced
is not a resolution. It is a document.
The enforcement gap is the most consequential unsolved problem in international arbitration. ICC, SIAC, and LCIA produce excellent awards. None of them takes institutional responsibility for what happens after.
Who should choose which institution.
A direct and honest assessment. ICC, SIAC, and LCIA are excellent institutions. The choice depends on what you specifically need.
- The most globally recognised institutional name - where the counterparty's country will respond to that name specifically
- French law as governing law and Paris as the natural seat
- Very large, complex, multi-jurisdictional disputes with significant political sensitivity
- The ICC scrutiny process for your award (though limited to form, not enforcement)
- Asia-Pacific disputes where Singapore is the natural seat and counterparty familiarity with SIAC is strong
- The 2025 SIAC Rules and Singapore's established arbitration-friendly judiciary
- A well-tested expedited procedure for disputes under USD 6 million
- Strong panel across construction, shipping, energy, and technology sectors in Asia
- An award that comes with an Enforceability Certificate - particularly where enforcement jurisdiction is uncertain or contested
- A mid-market or SME dispute under USD 750,000 that the major institutions do not serve well
- A long-term relationship where prevention matters - JV, infrastructure, supply chain
- Cost certainty from day one - with a written pledge not to exceed the initial estimate by more than 20%
- The most current rules - AI evidence protocol, enforcement cooperation clause, performance transparency
built the foundations.
UNIONE™ built what comes next.