What this guide covers
A SIAC arbitration clause in a UAE contract requires more thought than simply copying the SIAC model clause. The seat, governing law, number of arbitrators, language, and interaction with mandatory UAE law provisions all require deliberate choices — especially where one party is a UAE entity or the contract performance is in the UAE.
SIAC model clause
The SIAC recommended model clause is: "Any dispute arising out of or in connection with this contract, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (SIAC) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (SIAC Rules) for the time being in force, which rules are deemed to be incorporated by reference in this clause. The seat of the arbitration shall be [Singapore*]. The Tribunal shall consist of [one/three] arbitrator(s). The language of the arbitration shall be [English]."
*For UAE parties, the seat selection requires separate analysis (see below).
Seat selection for UAE contracts
Singapore seat: Most neutral; deepest SIAC case law; Singapore IAA governs; Singapore High Court supervises. Enforcement in UAE via NYC (3–12 months for UAE assets). Best choice where counterparty resists UAE supervisory jurisdiction or where assets are globally dispersed.
DIFC seat + SIAC administration: DIFC Arbitration Law 2013 governs; DIFC Courts supervise; English common-law supervisory court in Dubai. Enforcement against Dubai onshore assets via conduit mechanism (4–12 weeks). Combines SIAC's international brand with faster UAE enforcement. Requires express clause: "The seat of the arbitration shall be the Dubai International Financial Centre (DIFC), United Arab Emirates."
UAE onshore seat + SIAC: Possible but unusual. FDL 6/2018 governs; UAE Courts supervise. The combination of SIAC rules and UAE onshore supervisory jurisdiction is workable but creates potential friction — some SIAC procedural provisions may conflict with UAE mandatory procedural law (e.g., Arabic translation requirements for court proceedings).
Governing law clause
Always include a separate governing law clause in the contract. The most common combinations for UAE contracts: (i) UAE law governing + Singapore seat; (ii) DIFC law governing + DIFC seat + SIAC administration; (iii) English law governing + Singapore seat. The seat determines the procedural law; the governing law clause determines what substantive law the tribunal applies to the merits. They can differ.
For UAE law-governed contracts with a Singapore seat: the tribunal applies UAE Civil Code, UAE Commercial Code, and applicable UAE regulations to the merits; Singapore IAA governs the procedure. This is a legally coherent and frequently used combination.
Pathological clause traps
Common drafting errors to avoid: (i) specifying SIAC for disputes "except for urgent relief" — this creates uncertainty about whether emergency arbitrator orders are covered by the clause; (ii) specifying Singapore as the seat but then also specifying "UAE law shall govern all proceedings" — this creates ambiguity between substantive and procedural law; (iii) specifying "SIAC or DIAC at the claimant's election" — unilateral optional clauses are valid under English and Singapore law but their enforceability in UAE courts is uncertain; (iv) specifying a non-existent institution name (e.g., "Singapore Arbitration Centre" instead of "Singapore International Arbitration Centre SIAC") — courts have saved such clauses but the risk is real.
Practical checklist
- Use the SIAC model clause verbatim, then add seat, number of arbitrators, and language
- Seat: choose Singapore (most neutral), DIFC (faster UAE enforcement), or agree to disagree and submit seat selection to SIAC
- Add separate governing law clause: "This Agreement is governed by the laws of [UAE/Singapore/England & Wales]"
- Language: specify English or English and Arabic; Arabic-only proceedings are unusual in SIAC but not prohibited
- Number of arbitrators: sole arbitrator for claims likely under SGD 10M (SIAC expedited threshold); three for larger/complex disputes
- Multi-tier: if you want pre-arbitration mediation, use the SIAC-SIMC Arb-Med-Arb Protocol clause instead of a standalone SIAC clause
What we'd typically advise
For contracts between a UAE company and an international counterparty in technology, finance, or trade, our standard recommendation is the SIAC model clause with Singapore as seat and English as language. Add a governing law clause specifying the relevant law. For contracts with Abu Dhabi government entities or large UAE construction projects, negotiate for DIAC or arbitrateAD with a UAE seat — the government entity will resist Singapore supervision over UAE public contracts.
Frequently asked questions
What happens if the SIAC clause does not specify a seat?
If the clause does not specify a seat, the SIAC Registrar may suggest Singapore as the default seat. Rule 21.1 provides that where parties have not agreed on the seat, the SIAC Court shall determine the seat having regard to all the circumstances of the case. In practice, Singapore is almost always chosen as the default.
Can a SIAC arbitration clause be included in a UAE-law governed standard form contract?
Yes. UAE FDL 6/2018 Art 1 allows arbitration of commercial disputes "regardless of the law governing the agreement." A SIAC clause in a UAE-law governed contract is valid and enforceable in UAE and Singapore courts.
Is an arbitration clause in an Arabic-language contract valid for SIAC arbitration?
Yes. FDL 6/2018 Art 10 requires the arbitration agreement to be in writing. An Arabic-language contract with a SIAC clause is valid. The arbitration itself will be conducted in the language specified in the clause (typically English), or determined by the tribunal if not specified.
Can a SIAC clause specify UAE Federal Courts as the supervisory court?
No — supervisory jurisdiction over SIAC arbitrations follows the seat, not the parties' agreement. The courts at the seat are the supervisory courts by operation of law. If the seat is Singapore, Singapore courts supervise; if DIFC, DIFC Courts supervise. You cannot contractually assign supervisory jurisdiction to a different court.
What is the SIAC filing fee for a contract claim of AED 10 million?
The SIAC filing fee for the Notice of Arbitration is SGD 3,500 regardless of claim value. AED 10 million is approximately SGD 3.7 million — well within the SIAC expedited threshold of SGD 10 million, so the expedited procedure applies by default (unless parties opt out).
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Published 20 May 2026. General information only — not legal advice. Contact us for matter-specific advice.