What this guide covers
The SIAC-SIMC Arb-Med-Arb (AMA) Protocol is a unique hybrid — arbitration begins, the parties pause for SIMC mediation, and if settlement is reached, the mediator's outcome is recorded as a SIAC consent award enforceable under the NYC Convention. No other international protocol offers this seamless combination.
How the AMA Protocol works
The AMA Protocol was developed jointly by SIAC and the Singapore International Mediation Centre (SIMC). It operates in three stages:
Stage 1 — Arbitration commencement: Parties file with SIAC under standard SIAC Rules. The arbitration is constituted. This preserves all procedural rights and limitation periods.
Stage 2 — Suspension for SIMC mediation: At any point before the final award (usually before the main evidentiary hearing), parties agree to suspend the SIAC arbitration and refer the dispute to SIMC mediation. A SIMC mediator is appointed. The mediation is confidential — nothing said in mediation is admissible in the arbitration.
Stage 3 — Resumption or consent award: If mediation succeeds: the settlement agreement is returned to the SIAC tribunal, which records it as a SIAC consent award (Rule 34 SIAC Rules 2024). The consent award is then enforceable as a SIAC arbitral award under the NYC Convention in 172 states. If mediation fails: the SIAC arbitration resumes from where it was suspended, with no information from mediation used.
Advantages of the AMA Protocol
Enforceability of settlement: The critical advantage over standalone mediation. A private settlement agreement is not directly enforceable under the NYC Convention. A consent award IS a NYC Convention award — instantly enforceable in 172 states. The AMA Protocol provides this enforcement upgrade at minimal procedural cost.
Singapore Convention on Mediation (2019): Singapore has ratified the UN Convention on International Settlement Agreements Resulting from Mediation (Singapore Convention, UNCITRAL) which provides a framework for enforcing mediated settlement agreements directly (without converting to an award). The UAE has not yet acceded to the Singapore Convention (as of May 2026) — making the consent award route under AMA more valuable for UAE parties.
Confidentiality: Mediation is strictly confidential. The SIAC arbitration is stayed while mediation occurs — parties can explore settlement without prejudicing their arbitration position.
AMA Protocol for UAE disputes
For UAE parties, the AMA Protocol is particularly attractive because: (i) the UAE has not yet acceded to the Singapore Convention, so mediated settlements without conversion to an arbitral award are harder to enforce cross-border; (ii) UAE parties often prefer mediation in confidential, structured proceedings before committing to full arbitration costs; (iii) a SIAC consent award enforces in UAE via the NYC route (3–6 months onshore, 6–10 weeks via DIFC conduit).
The AMA Protocol clause to include in UAE contracts: "Any dispute [shall be] referred to arbitration administered by SIAC in accordance with SIAC Rules. If the Parties agree, the arbitration shall be suspended, and the dispute shall be submitted to mediation in accordance with the SIAC-SIMC Arb-Med-Arb Protocol."
Practical checklist
- Include AMA Protocol language in the contract clause — SIAC provides a model AMA clause
- SIMC mediation fee: budget approximately SGD 8,000–15,000 for SIMC mediator fees per day
- Mediation timing: initiate mediation request early — before significant arbitration costs accumulate and before positions harden
- Consent award: ensure the settlement agreement is comprehensive and signed before asking SIAC tribunal to record it as a consent award
- Confidentiality: instruct your team that nothing from mediation is to be used or referred to in any arbitration submissions
- Singapore Convention watch: the UAE may accede to the Singapore Convention — when it does, standalone mediated settlements will become directly enforceable, reducing the AMA Protocol advantage
What we'd typically advise
We recommend including AMA Protocol language in all SIAC clauses for commercial contracts above USD 1M where the relationship between the parties has any ongoing value. The Protocol costs nothing to include in the contract and provides a valuable off-ramp from full arbitration if commercial sense prevails. In practice, we initiate mediation discussions with the opposing party's counsel at the 30% stage of arbitration proceedings — after enough procedural investment to make the strength of each party's case clear, but before the relationship is destroyed by a full evidentiary hearing.
Frequently asked questions
Can parties use AMA Protocol if they do not have an AMA clause in their contract?
Yes — parties can agree to use the AMA Protocol after a dispute arises, even without a pre-dispute AMA clause. They file SIAC arbitration, then agree jointly to suspend it for SIMC mediation. The SIAC tribunal must consent to the suspension.
What happens to arbitrator fees during the mediation suspension?
Arbitrators do not charge fees during the suspension period unless they perform work (e.g., reviewing documents, issuing procedural orders). Suspension preserves the arbitration without incurring the daily fees of a hearing.
Is the consent award subject to the same set-aside grounds as a final award?
Yes. A consent award recording a settlement is a SIAC arbitral award for all purposes. It can be set aside in Singapore courts on the same grounds as any other award (Singapore IAA s.24, Model Law Art 34). In practice, consent awards are rarely challenged — parties who voluntarily settled have limited grounds to resile from the settlement.
Does the SIMC mediator later become the tribunal's expert or adviser?
No — strict information barrier. The SIMC mediator has no role in the SIAC arbitration. Nothing communicated in mediation is disclosed to the tribunal. The mediator cannot be called as a witness.
How does AMA Protocol compare to med-arb (mediation first, then arbitration)?
AMA (arbitration first, mediation in the middle) is significantly preferable to med-arb (mediation first, then arbitration if mediation fails) because: in AMA, the same person does not perform both roles — there is no risk of the mediator knowing confidential information from mediation and using it as arbitrator. In traditional med-arb, the same neutral performs both roles, creating a serious due process risk that has led courts in some jurisdictions to refuse enforcement of med-arb awards.
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Published 20 May 2026. General information only — not legal advice. Contact us for matter-specific advice.