{"id":38868,"date":"2025-10-30T13:22:26","date_gmt":"2025-10-30T13:22:26","guid":{"rendered":"https:\/\/www.cdr-news.com\/?post_type=product&#038;p=38868"},"modified":"2025-10-30T14:41:17","modified_gmt":"2025-10-30T14:41:17","slug":"multi-party-and-multi-contract-bri-disputes-at-hkiac","status":"publish","type":"product","link":"https:\/\/www.cdr-news.com\/cdr-essential-intelligence\/belt-and-road-initiative\/multi-party-and-multi-contract-bri-disputes-at-hkiac\/","title":{"rendered":"Multi-party and multi-contract BRI disputes at HKIAC"},"content":{"rendered":"<h1><strong>Introduction<\/strong><\/h1>\n<p>The Belt and Road Initiative (<strong>BRI<\/strong>), launched by the PRC government in 2013, is an initiative spanning the land-based \u201cSilk Road Economic Belt\u201d and the seafaring \u201c21<sup>st<\/sup> Century Silk Road\u201d.\u00a0 It is aimed at promoting connectivity and international co-operation across Asia, Europe and Africa, covering over 150 jurisdictions, collectively home to over 65% of the world\u2019s population.<\/p>\n<p>BRI projects create trade and economic opportunities but, inevitably, they are also exposed to a spectrum of political, financial and legal risks, which give rise to disputes from time to time.\u00a0 Over the last 10 years, the Hong Kong International Arbitration Centre (<strong>HKIAC<\/strong>) has accumulated extensive experience in administering BRI disputes.\u00a0 Given the complexity and scale of BRI projects, many of these disputes involve multiple contracts and\/or multiple parties, which is the focus of this chapter.<\/p>\n<p>This chapter will first provide an overview of HKIAC\u2019s caseload on BRI disputes generally and a commentary on the unique features of Hong Kong as a seat of arbitration and HKIAC as the administering arbitral institution for resolving such disputes.\u00a0 This will be followed by a deeper dive into the types of issues that commonly arise in multi-contract and\/or multi-party scenarios, and how the HKIAC rules can address these issues.\u00a0 An anonymised case study is provided in the last section to illustrate how HKIAC analyses such issues in practice.\u00a0 This chapter is an update of HKIAC\u2019s publication of the same title in 2024 and includes references to HKIAC\u2019s latest Practice Note on Compatibility of Arbitration Clauses under the HKIAC Administered Arbitration Rules (<strong>Practice Note on Compatibility of Arbitration Clauses<\/strong>), which was published in January 2025.<\/p>\n<h1><strong>HKIAC\u2019s caseload involving BRI participants<\/strong><\/h1>\n<p>BRI projects and BRI disputes are not easy to define.\u00a0 At a high level, BRI projects are Chinese outbound investments, often in the form of construction and infrastructure projects led by major state-owned enterprises, into one of the BRI jurisdictions.\u00a0 Common areas of investment include energy, transport and logistics, maritime and telecommunications.<\/p>\n<p>The types of disputes that may arise from BRI projects are varied.\u00a0 By way of example, they could arise out of construction contracts between contractors and sub-contractors, concession agreements entered into with governments, joint venture or shareholder agreements between foreign investors and local partners, and finance agreements between project companies and lenders.<\/p>\n<p>In analysing HKIAC\u2019s caseload on BRI disputes, we have looked at HKIAC\u2019s statistics on arbitrations registered by HKIAC which involve: (i) at least one party from Mainland China; and (ii) one party from another BRI jurisdiction.\u00a0 From 1 January 2014 to 21 July 2025, HKIAC registered a total of 254 of such arbitrations.\u00a0 Where a single arbitration is commenced under multiple contracts, they have been counted as one arbitration.<\/p>\n<p>These 254 arbitrations do not represent all disputes submitted to HKIAC that have a BRI element, since in many cases, Mainland Chinese entities choose to structure their investment through offshore entities or locally incorporated entities.\u00a0 Further, even if a Mainland Chinese entity is involved in the investment structure of a BRI project, the Mainland Chinese entity may not necessarily be involved in the arbitration.<\/p>\n<p>In respect of the selected 254 arbitrations, further details are provided below.<\/p>\n<ul>\n<li><strong> Amount in dispute<\/strong>: The total amount in dispute (to the extent the amount was quantified at the time of submission) is USD 7.5 billion.<\/li>\n<li><strong> Geographical origins of parties<\/strong>: Excluding Mainland China and Hong Kong, parties come from 34 other jurisdictions with the following breakdown:<\/li>\n<\/ul>\n<table>\n<tbody>\n<tr>\n<td width=\"179\"><strong>Region <\/strong>(based on World Bank\u2019s regional classifications)<\/td>\n<td width=\"82\"><strong>Number of Parties<\/strong><\/td>\n<\/tr>\n<tr>\n<td width=\"179\">East Asia and Pacific<\/td>\n<td width=\"82\">217<\/td>\n<\/tr>\n<tr>\n<td width=\"179\">Europe and Central Asia<\/td>\n<td width=\"82\">23<\/td>\n<\/tr>\n<tr>\n<td width=\"179\">Latin America and Caribbean<\/td>\n<td width=\"82\">6<\/td>\n<\/tr>\n<tr>\n<td width=\"179\">Middle East and North Africa<\/td>\n<td width=\"82\">20<\/td>\n<\/tr>\n<tr>\n<td width=\"179\">South Asia<\/td>\n<td width=\"82\">1<\/td>\n<\/tr>\n<tr>\n<td width=\"179\">Sub-Sahara Africa<\/td>\n<td width=\"82\">31<\/td>\n<\/tr>\n<tr>\n<td width=\"179\">Total<\/td>\n<td width=\"82\">298<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<ul>\n<li><strong> Role of Mainland Chinese parties<\/strong>: In 101 arbitrations (i.e. around 40% of cases), the claimant(s) include(s) a Mainland Chinese party. In 163 arbitrations (i.e. around 64% of cases), the respondent(s) include(s) a Mainland Chinese party. In 10 arbitrations (i.e. around 4% of cases), both the claimant and respondent sides included a Mainland Chinese party.<\/li>\n<li><strong> Applicable rules<\/strong>: Of these 254 arbitrations, 222 were administered by HKIAC under the HKIAC Administered Arbitration Rules (87%) and the UNCITRAL Arbitration Rules (13%).<\/li>\n<li><strong> Seat of arbitration<\/strong>: All arbitrations were seated in Hong Kong.<\/li>\n<li><strong> Governing law<\/strong>: Around 43% of the 254 arbitrations are governed by Hong Kong law. English law and PRC law are the next most popular governing laws. Around 23% of the 254 cases were governed by English law, another 18% by PRC law, 14% were governed by other laws, and 2% were cases where the governing laws were unspecified.<\/li>\n<li><strong> Nationality of arbitrators<\/strong>: The top 10 nationalities or geographical origins of the arbitrators appointed or confirmed by HKIAC are as follows:<\/li>\n<\/ul>\n<table>\n<tbody>\n<tr>\n<td width=\"162\"><strong>Nationality\/Geographical Origin<\/strong><\/td>\n<td width=\"131\"><strong>Number of Appointed or Confirmed Arbitrators<\/strong><\/td>\n<\/tr>\n<tr>\n<td width=\"162\">1.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 United Kingdom<\/td>\n<td width=\"131\">87<\/td>\n<\/tr>\n<tr>\n<td width=\"162\">2.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Hong Kong<\/td>\n<td width=\"131\">50<\/td>\n<\/tr>\n<tr>\n<td width=\"162\">3.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Australia<\/td>\n<td width=\"131\">34<\/td>\n<\/tr>\n<tr>\n<td width=\"162\">4.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Mainland China<\/td>\n<td width=\"131\">25<\/td>\n<\/tr>\n<tr>\n<td width=\"162\">5.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 New Zealand<\/td>\n<td width=\"131\">17<\/td>\n<\/tr>\n<tr>\n<td width=\"162\">6.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Canada<\/td>\n<td width=\"131\">15<\/td>\n<\/tr>\n<tr>\n<td width=\"162\">7.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Malaysia<\/td>\n<td width=\"131\">15<\/td>\n<\/tr>\n<tr>\n<td width=\"162\">8.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 United States<\/td>\n<td width=\"131\">14<\/td>\n<\/tr>\n<tr>\n<td width=\"162\">9.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 France<\/td>\n<td width=\"131\">13<\/td>\n<\/tr>\n<tr>\n<td width=\"162\">10.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0 Singapore<\/td>\n<td width=\"131\">10<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<ul>\n<li><strong> Complex arbitrations<\/strong>: Relevant to this chapter\u2019s topic, 97 of these 254 arbitrations involve multiple parties and 44 are single arbitrations commenced under multiple contracts.<\/li>\n<\/ul>\n<h1><strong>Features of Hong Kong seat and HKIAC arbitrations in BRI disputes<\/strong><\/h1>\n<p>Choosing Hong Kong as a seat of arbitration can help mitigate risk for parties to BRI projects.\u00a0 Hong Kong enjoys a unique status as a Special Administrative Region of the PRC under the \u201cOne Country, Two Systems\u201d constitutional framework.<\/p>\n<p>What this means is that <em>first<\/em>, being a distinct legal jurisdiction to Mainland China, Hong Kong has a common law legal system whilst Mainland China practises civil law.\u00a0 <em>Secondly<\/em>, Hong Kong maintains its own laws.\u00a0 For example, the Arbitration Ordinance (Cap. 609 of the Laws of Hong Kong) is the relevant arbitration law in Hong Kong (and not the Arbitration Law of the PRC, which applies in Mainland China).\u00a0 <em>Thirdly<\/em>, Hong Kong has its own courts and independent judiciary with the power of final adjudication, i.e., the Hong Kong Court of Final Appeal is the final appellate court.\u00a0 <em>Fourthly, <\/em>Hong Kong has its own legal profession \u2013 solicitors and barristers \u2013 which are self-regulated by independent regulatory bodies.\u00a0 There is a deep, bilingual legal talent pool, with 80 registered foreign law firms from 19 overseas jurisdictions and over 1,500 registered foreign lawyers from 31 overseas jurisdictions.<\/p>\n<p>As an arbitration seat, Hong Kong is attractive to both Chinese and non-Chinese parties.\u00a0 The Hong Kong Arbitration Ordinance (Cap. 609 of the Laws of Hong Kong) is based on the UNCITRAL Model Law, which has international recognisability, predictability and acceptability.\u00a0 The Hong Kong Arbitration Ordinance is also constantly modernised and refined.\u00a0 Notable amendments in the past decade include the introduction of specific provisions on the enforcement of emergency arbitrator orders (2013), arbitrability of intellectual property rights (2017), third-party funding (2017) and outcome-related fee structures (2022).<\/p>\n<p>There are specialist arbitration judges in the Hong Kong courts, who have consistently demonstrated their respect for party autonomy and minimal court intervention through their robust, pro-arbitration judgments.\u00a0 In the case of <em>CNG v G &amp; G <\/em>[2024] HKCFI 575, the court reiterated the following:<\/p>\n<blockquote><p>\u201c<em>Lest it should be unclear, parties should be reminded that arbitration is a consensual process of final dispute resolution to which they voluntarily agree, with whatever inherent defects and risks there may be, and there are only limited avenues of appeal and challenge to the award.\u00a0 The limited recourse parties have under the Arbitration Ordinance is not intended to afford them with an opportunity to ask the Court after the event to go through the award with a fine-tooth comb, to look for defects and imperfections under the guise that the tribunal had failed to act in accordance with its remit or the agreed procedure.\u00a0 Nor is any party entitled to rehearse once again before the Court arguments already made before the tribunal, or to have different counsel reargue its case with a different focus, in the hope that the Court may be persuaded to come to a different conclusion.\u00a0 First and foremost, the Court does not sit on appeal against the tribunal\u2019s findings of fact or law.\u00a0 Further, the Court must not only respect the autonomy of the tribunal, but also leave the tribunal free to decide the dispute with the proper exercise of its case-management powers, when the tribunal is clearly in the best position to manage its own proceedings and procedure in the light of the issues put before it, the complexities of the case, and the time-table which best suits the tribunal, the parties and their legal representatives, with the aim of achieving a speedy resolution without unnecessary legal expense.<\/em>\u201d<\/p><\/blockquote>\n<p>Hong Kong awards have a strong track record of successful enforcement.\u00a0 Based on public reports in the past few months, at the time of writing there are already many examples of successful enforcement of Hong Kong awards in jurisdictions including California, Florida, Cayman Islands and England &amp; Wales.\u00a0 Notably, Hong Kong awards also enjoy a strong track record of successful enforcement in Mainland China under the Arrangement Concerning Mutual Enforcement of Arbitral Awards between the Mainland and the Hong Kong Special Administrative Region, which was supplemented and amended in 2020 (collectively, the <strong>Mutual<\/strong> <strong>Enforcement Arrangements<\/strong>).\u00a0 The grounds for refusal of enforcement under the Mutual Enforcement Arrangements mirror those under the New York Convention.\u00a0 HKIAC is aware of at least 99 applications for recognition and enforcement of arbitral awards before Mainland Chinese courts under the Mutual Enforcement Arrangement, with 65% of these being HKIAC awards.\u00a0 In the past 20 years, based on public data, there have only been three known cases of refusal of enforcement of HKIAC awards.<\/p>\n<p>In addition to the Mutual Enforcement Arrangements, the Arrangement Concerning Mutual Assistance in Court-Ordered Interim Measures in Aid of Arbitral Proceedings by the Courts of the Mainland and the Hong Kong Special Administrative Region (<strong>Interim Measures Arrangement<\/strong>) is another critically important arrangement to consider for BRI transactions.\u00a0 The Interim Measures Arrangement provides parties to arbitration with access to Mainland Chinese courts for interim relief in support of arbitrations seated in Hong Kong and administered by HKIAC.\u00a0 This is a unique advantage that allows parties to have their arbitration conducted offshore in an UNCITRAL Model Law jurisdiction, without losing the ability to seek onshore interim relief in Mainland China.<\/p>\n<p>It is important to note that the Interim Measures Arrangement has been used effectively by both Chinese and non-Chinese parties.\u00a0 Since the Interim Measures Arrangement entered into force on 1 October 2019 and as of 31 July 2025, HKIAC has issued Letters of Acceptance in respect of 160 applications, of which 153 applications were made for the preservation of assets.\u00a0 HKIAC is aware of 121 decisions issued by the Mainland Chinese courts.\u00a0 Of these 121 decisions, 116 granted the applications, all of which being applications for preservation of assets.\u00a0 The total value of assets preserved by the 116 decisions amounted to RMB 27.7 billion or approximately USD 3.5 billion.<\/p>\n<p>On 28 June 2022, HKIAC became the first arbitral institution outside Mainland China to be included in the \u201cOne-Stop\u201d Platform for Diversified International Commercial Dispute Resolution (<strong>One-Stop Platform<\/strong>) of the China International Commercial Court (<strong>CICC<\/strong>), which comprises judges from the Supreme People\u2019s Court of the PRC.\u00a0 This means that parties to cases administered by HKIAC with an amount in dispute over RMB 300 million or with a significant impact may file an application for interim relief and\/or the enforcement of arbitral awards directly to the CICC, without necessarily having to start their application at the lower level of the Intermediate People\u2019s Courts.\u00a0 This provides parties to HKIAC arbitrations with an even more efficient route to interim measures and enforcement.<\/p>\n<p>As an arbitral institution, HKIAC has been uniquely positioned in handling complicated disputes arising under the BRI.\u00a0 Founded in 1985, HKIAC is one of the oldest arbitral institutions established in Asia to handle international cross-border disputes, particularly disputes involving both Mainland Chinese and non-Mainland Chinese parties.\u00a0 In recent years, around 40% to 50% of arbitrations administered by HKIAC have involved at least one Mainland Chinese party.\u00a0 Chinese state-owned entities, which are prominent participants in BRI projects, regularly appear in HKIAC\u2019s caseload, whether as claimants or respondents.\u00a0 This requires HKIAC\u2019s long-term commitment in demonstrating its independence, neutrality and efficiency in administering high-stakes and politically sensitive disputes.<\/p>\n<p>In addition to offering concrete advantages on seeking interim measures and enforcement in BRI disputes as illustrated above, HKIAC has systems in place to ensure its independence and neutrality; for example, Article 11.2 of the HKIAC Administered Arbitration Rules provides that where the parties to an arbitration are of different nationalities, a sole or presiding arbitrator shall not have the same nationality as any party unless specifically agreed otherwise by all parties.\u00a0 Moreover, HKIAC\u2019s decision-making bodies (i.e. HKIAC Council and standing committees) all comprise external leading professionals with diverse backgrounds.\u00a0 At the time of writing, the HKIAC Council comprises 28 private practitioners, arbitrators and in-house counsel of 20 different nationalities.<\/p>\n<p>Other distinct offerings of HKIAC include, <em>first<\/em>, its light-touch approach to case administration with a focus on user-friendliness and efficiency.\u00a0 <em>Secondly<\/em>, the multilingualism of the HKIAC legal staff, many of whom are fully bilingual in English and Chinese, which puts HKIAC in a unique position in handling BRI disputes. <em>\u00a0Thirdly<\/em>, a strong commitment to staying innovative and modern, including continuous refinement of its administered arbitration rules, most recently in 2018 and 2024.\u00a0 The HKIAC rules are well-suited for resolving BRI disputes.\u00a0 As will be elaborated below, among other features, the HKIAC rules provide sophisticated mechanisms for the resolution of multi-party and multi-contract arbitrations.<\/p>\n<p>On top of that, HKIAC issues practice notes from time to time.\u00a0 HKIAC\u2019s practice notes aim to provide practical guidance to HKIAC\u2019s users, assist them in understanding the nuances underlying some of HKIAC\u2019s most innovative rules, as well as provide insights into how HKIAC exercises its procedural discretions.<\/p>\n<p>For instance, the most recent practice note issued by HKIAC in January 2025, the Practice Note on Compatibility of Arbitration Clauses (<a href=\"https:\/\/www.hkiac.org\/sites\/default\/files\/ck_filebrowser\/Practice%20Note%20on%20Compatibility%20of%20Arbitration%20Clauses_EN.pdf\">https:\/\/www.hkiac.org\/sites\/default\/files\/ck_filebrowser\/Practice%20Note%20on%20Compatibility%20of%20Arbitration%20Clauses_EN.pdf<\/a>), sets out HKIAC\u2019s general practice in assessing the compatibility of arbitration clauses in multi-party, multi-contract scenarios under the 2018 HKIAC Administered Arbitration Rules (<strong>2018 Rules<\/strong>), and 2024 HKIAC Administered Arbitration Rules (<strong>2024 Rules<\/strong>).\u00a0 The practice note includes, <em>inter alia<\/em>, examples of arbitration clauses that have been considered compatible or incompatible and offers recommendations for drafting arbitration clauses in related contracts to increase their compatibility.\u00a0 Further details of this practice note will be discussed below.<\/p>\n<h1><strong>Multi-party and multi-contract issues and relevant provisions under HKIAC rules<\/strong><\/h1>\n<p>It is unsurprising that BRI disputes regularly feature multiple parties and\/or multiple contracts.\u00a0 A typical BRI project often requires the involvement of a range of commercial parties.\u00a0 Examples include: chains of contractors and sub-contractors who may or may not agree on a single construction contract; multiple layers of investors forming joint venture and shareholder structures; the participation of multiple banks, insurance companies, and other financial institutions providing financial assistance and risk mitigation; involvement of different subsidiaries or affiliates in providing guarantees or security; and commercial parties may also structure their investments and enter into contracts through other group entities or investment vehicles for investment protection or tax reasons.\u00a0 When disputes arise, claimants often seek to assert their claims against as many parties as possible.<\/p>\n<p>Multi-party and multi-contract scenarios present a unique set of complexities to the commencement and conduct of arbitrations.\u00a0 As Professor Hanotiau explained in 1998, at which point most institutional rules had not yet introduced provisions dealing with complex arbitrations, \u201c<em>[t]he problems are accentuated when the parties have provided for submission to arbitration rather than to ordinary courts. <\/em>\u00a0<em>Arbitration is effectively consensual by nature, with the consequence that the principle of privity of contract applies to the arbitration clause, limiting its effect to the contracting parties alone.<\/em> <em>\u00a0Joining third parties to the agreement often proves difficult, if not impossible<\/em>\u201d.<\/p>\n<p>Professor Hanotiau gave a few examples of the problems raised by arbitration and complex contracts, such as:<\/p>\n<ul>\n<li>To what extent can one bring to one single arbitration proceeding the various parties who have participated in one economic transaction through several contracts?<\/li>\n<li>If separate arbitration proceedings need to be started, can these different proceedings be consolidated and under what conditions?<\/li>\n<li>Who can act as claimant and against which respondents? Can a respondent join other respondents, be they privy to the arbitration agreement or third parties?<\/li>\n<\/ul>\n<p>Over the years, HKIAC has introduced new provisions to its administered arbitration rules to address the commercial realities of multi-party and multi-contract scenarios.\u00a0 The latest version is the 2024 Rules, which is a refinement of the 2018 Rules.\u00a0 The key features relevant to multi-party and multi-contract scenarios are set out below.<\/p>\n<h2><strong>Single arbitration under multiple contracts<\/strong><\/h2>\n<p>Article 29.1 of the 2024 Rules permits a claimant to commence a single arbitration to resolve claims that arise under more than one contract provided that the following criteria are fulfilled, namely: (a) a common question of law or fact arises under each arbitration agreement giving rise to the arbitration; (b) the rights to relief claimed are in respect of, or arise out of, the same transaction or a series of related transactions; and (c) the arbitration agreements under which those claims are made are compatible.<\/p>\n<p>Importantly, the three criteria are cumulative and must all be satisfied.\u00a0 It is also worth noting that following the introduction of the 2018 Rules, it is no longer a prerequisite for the commencement of a single arbitration that all parties to the arbitration are bound by each arbitration agreement giving rise to the arbitration.\u00a0 Thus, claims arising out of multiple contracts which were not entered into by identical parties may also be brought in a single arbitration, provided that all three criteria are met.<\/p>\n<p>The requirement of the existence of a common question of law or fact reflects the rationale that the commencement of a single arbitration should produce cost and time efficiencies.\u00a0 For example, in a BRI dispute, even if the contracts have identical arbitration agreements and all relate to the BRI project, it may not make much practical sense for claims to be heard in a single arbitration if there are no overlapping issues for determination at all.<\/p>\n<p>As to the requirement that the rights to relief claimed arise out of the same or related transactions, it acts as an important safeguard in that, even if arbitration agreements are entirely identical, the parties are unlikely to have expected or agreed to have their claims heard in an arbitration alongside parties to unrelated transactions.<\/p>\n<p>As to the third criterion, the compatibility of arbitration clauses, the arbitration agreements need not be identical, but any differences must be surmountable by the parties, the tribunal and\/or HKIAC.\u00a0 In light of the complexity of the case-by-case analysis of compatibility of arbitration clauses where they are not identical, the Practice Note on the Compatibility of Arbitration Clauses explains in detail and illustrates through examples how HKIAC assesses this criterion in various real-life scenarios and provides arbitration clauses drafting recommendations.<\/p>\n<p>As outlined in paragraph 4.2 of the Practice Note on Compatibility of Arbitration Clauses, HKIAC adopts a pragmatic approach when assessing compatibility of arbitration agreements, bearing in mind its objective of facilitating fair and speedy resolution of the dispute without unnecessary expense.\u00a0 HKIAC considers all relevant factors, including but not limited to: (i) whether, given the differences in the arbitration agreements, it is practically feasible and procedurally efficient for the claims to be heard in a single arbitration; (ii) whether the differences undermine the consent of the parties, through their agreement to adopt the HKIAC Rules, to the possibility of determining claims under multiple contracts in a single arbitration; and (iii) whether permitting a single arbitration would change the parties\u2019 agreement with respect to the arbitral procedure in a way that might leave the award open to challenge in the future.\u00a0 For illustration purposes, section 5 of the practice note provides three examples of situations in which HKIAC has determined the arbitration agreements to be compatible and another three examples where the arbitration agreements were deemed to be incompatible.<\/p>\n<p>As outlined at section 3 of the Practice Note on Compatibility of Arbitration Clauses, where there are multiple related contracts, parties are recommended to use HKIAC\u2019s model arbitration clause in each contract and to provide for the same seat, number of arbitrators, law governing the arbitration agreement and language of arbitration in these arbitration clauses, as this maximises the chances that the clauses will be found compatible.\u00a0 If parties choose not to adopt the model clause, it is important to draft the arbitration clauses carefully.\u00a0 In particular, users should pay particular attention to any bespoke mechanisms for appointing the arbitrators, as these may present a higher risk that the arbitration clauses will be deemed incompatible.<\/p>\n<p>Notably, Article 29.1 is subject to Article 19.5, which provides that \u201c<em>the arbitration shall proceed only if and to the extent that HKIAC is satisfied, prima facie, that [\u2026] the arbitration has been properly commenced under Article 29<\/em>\u201d.<\/p>\n<p>Thus, HKIAC\u2019s decision regarding whether to proceed with a single arbitration under multiple contracts is merely a <em>prima facie<\/em> assessment.\u00a0 Article 19.5 makes it clear that \u201c<em>[a]ny question as to the jurisdiction of the arbitral tribunal shall be decided by the arbitral tribunal once constituted, pursuant to Article 19.1<\/em>\u201d.<\/p>\n<p>Article 29.2 is a new provision introduced under the 2024 Rules.\u00a0 Where HKIAC decides pursuant to Article 19.5 that the arbitration has been properly commenced under Article 29, \u201c<em>the parties shall be deemed to have waived their rights to designate an arbitrator<\/em>\u201d.\u00a0 This mirrors the provision in Article 28.8.\u00a0 HKIAC\u2019s approach in exercising power to appoint arbitrators under these provisions will be further discussed below.<\/p>\n<h2><strong>Consolidation of arbitrations<\/strong><\/h2>\n<p>Article 28 sets out the mechanism for consolidation of arbitrations.\u00a0 Article 28.1 empowers HKIAC, at the request of a party and after consulting with the parties and any confirmed or appointed arbitrators, to order a consolidation in three circumstances, namely: (a) the parties all agree to consolidate; (b) all of the claims in the arbitration are made under the same arbitration agreement; or (c) where the claims are made under more than one arbitration agreement, then similar to the requirements under Article 29.1, all of the following three criteria need to be satisfied: (i) a common question of law or fact arises in all of the arbitrations; (ii) the rights to relief claimed are in respect of, or arise out of, the same transaction or a series of related transactions; and (iii) the arbitration agreements are compatible.\u00a0 For consolidation under Article 28.1(c), there is no requirement that the parties to the multiple arbitrations be identical, provided that all criteria under Article 28.1(c) are met.<\/p>\n<p>As mentioned above, where consolidation is ordered, all parties to the consolidated proceedings are deemed to have waived their rights to designate an arbitrator pursuant to Article 7 or 8 of the 2024 Rules, or the terms of their arbitration agreement.\u00a0 However, as will be discussed further below, in practice, HKIAC will take into account the views of all parties on prospective arbitrators, including any designations or appointments made before consolidation was ordered.<\/p>\n<p>Article 28 is regularly invoked by parties, including in BRI disputes, and occasionally, all parties expressly agree to consolidation.<\/p>\n<h2><strong>Joinder of parties <\/strong><\/h2>\n<p>In some cases, a party to the arbitration only decides after the arbitration has been commenced that it wishes to join an additional party, or the additional party itself may wish to be joined.\u00a0 Article 27.1 of the 2024 Rules provides that the arbitral tribunal or, where the arbitral tribunal is not yet constituted, HKIAC shall have the power to allow the joinder if the additional party is <em>prima facie<\/em> bound by an arbitration agreement giving rise to the arbitration, or if all parties, including the additional party, expressly agree.<\/p>\n<p>The 2024 Rules expressly allow joinder of an additional party to arbitrations conducted under Article 28 or Article 29.\u00a0 It is therefore necessary to consider if the additional party is a party to one or more\u00a0 arbitration agreement(s) giving rise to the consolidated arbitrations or the single arbitration under multiple contracts.<\/p>\n<p>Even if a joinder is allowed by HKIAC before the constitution of the arbitral tribunal, Article 27.2 makes it clear that the final power of decision lies with the tribunal, which determines its own jurisdiction according to Article 19.1 of the 2024 Rules.<\/p>\n<p>A joinder request must be submitted no later than in the Statement of Defence, except in exceptional circumstances.\u00a0 This time limit seeks to avoid unwarranted disruptions and delays to arbitration when the proceedings are well under way.<\/p>\n<h2><strong>Concurrent arbitrations<\/strong><\/h2>\n<p>Finally, even if parties do not, or cannot, make use of the single arbitration or consolidated arbitration mechanisms, the arbitral tribunal still has case management powers to maximise procedural efficiency with respect to parallel arbitrations under the HKIAC rules.\u00a0 Article 30.1 provides that the arbitral tribunal may, after consulting with the parties, conduct two or more arbitrations under the HKIAC rules at the same time, or one immediately after another, or suspend any of those arbitrations until after the determination of any other of them, where: (a) the same arbitral tribunal is constituted in each arbitration; and (b) a common question of law or fact arises in all the arbitrations.<\/p>\n<h2><strong>General approach and procedure<\/strong><\/h2>\n<p>The Proceedings Committee (<a href=\"https:\/\/www.hkiac.org\/about-us\/council-members-and-committees\/proceedings-committee\">https:\/\/www.hkiac.org\/about-us\/council-members-and-committees\/proceedings-committee<\/a>) is mandated by the HKIAC Council (<a href=\"https:\/\/www.hkiac.org\/about-us\/council-members-and-committees\/hkiac-council\">https:\/\/www.hkiac.org\/about-us\/council-members-and-committees\/hkiac-council<\/a>) to exercise powers vested in HKIAC by the arbitration rules issued by HKIAC to the extent that such powers are not exercised by the Appointments Committee or the Secretariat.\u00a0 This includes making decisions on (i) whether to join an additional party to an arbitration before the constitution of the arbitral tribunal under Article 27.1, (ii) whether to consolidate two or more arbitrations under Article 28.1(c), and (iii) whether an arbitration shall proceed as a single arbitration under multiple contracts under Articles 19.5 and 29.\u00a0 The current Proceedings Committee consists of 12 members of diverse jurisdictions and backgrounds, including leading practitioners at law firms and barristers\u2019 chambers, academia, in-house counsel and independent arbitrators.<\/p>\n<p>In exercising its functions, the Proceedings Committee aims to achieve maximum procedural and costs efficiency while ensuring that the HKIAC rules are interpreted correctly, consistently and in accordance with the applicable laws.<\/p>\n<p>In relation to BRI-related matters, in addition to its standing committees, i.e. the Appointments Committee, the Proceedings Committee and the Finance &amp; Administration Committee, HKIAC has also formed a special advisory committee.\u00a0 In response to the growing complexity and scope of BRI projects, HKIAC took a proactive step in 2018 by forming the Belt and Road Advisory Committee.\u00a0 This committee brings together a wealth of legal and commercial expertise across various BRI industry sectors, including finance, infrastructure, construction and maritime sectors.\u00a0 The committee\u2019s diverse composition ensures that HKIAC is well-equipped to handle the multifaceted nature of BRI disputes.<\/p>\n<h2><strong>Appointment of arbitrators in multi-party, multi-contract scenarios<\/strong><\/h2>\n<p>Article 8.2(a) of the 2024 Rules provides that where there are more than two parties to the arbitration and the dispute is to be referred to three arbitrators, unless the parties have agreed otherwise, the \u201c<em>Claimant or group of Claimants<\/em>\u201d shall designate an arbitrator and the \u201c<em>Respondent or group of Respondents<\/em>\u201d shall designate an arbitrator in accordance with the procedure in Article 8.1(a), (b) or (c), as applicable.<\/p>\n<p>This is in recognition of the fact that, at the time of entering into a contract, parties may not know yet whether they are going to be parties on the same side if a dispute arises.\u00a0 This is true for BRI projects, as commercial interests may evolve during the lifetime of the project, particularly in the case of BRI projects, which typically are long-term commercial endeavours.<\/p>\n<p>There are situations when a group of claimants, or a group of respondents, are unable to agree on a designation, or they may not all agree that they represent two separate sides for the purposes of designating arbitrators.\u00a0 Article 8.2(c) provides a solution in such situations by providing that HKIAC may appoint all members of the arbitral tribunal with or without regard to any party\u2019s designation.<\/p>\n<p>Similarly, Article 29.2 and Article 28.8 provide HKIAC with the power to appoint the entire arbitral tribunal with or without regard to any party\u2019s designation in a single arbitration conducted under multiple contracts and consolidated arbitrations, which frequently involve multiple parties.\u00a0 Section 6 of the Practice Note on Compatibility of Arbitration Clauses provides a detailed explanation of HKIAC\u2019s approach to the appointment of arbitrators in such scenarios, which provides guidance to users as to when and how HKIAC exercises its power to appoint arbitrators under the foregoing provisions.<\/p>\n<p>As a general default approach in practice, observing the primacy of party autonomy, unless there are justifiable exceptions (e.g. concerning the integrity of the proceedings and\/or equal treatment of the parties), HKIAC will appoint the arbitrator(s) that the parties designate.<\/p>\n<p>As further illustrated in the practice note, absent justifiable exceptions, where all the parties on the same side (i.e. Claimant side or Respondent side) make a joint designation, HKIAC\u2019s default approach is to appoint the jointly designated candidate.<\/p>\n<p>In cases where there are non-participating parties, such that there is no express agreement by the entire group of Claimants or Respondents on a designation, HKIAC will make the appointment, taking into account participating parties\u2019 comments, proposed criteria and proposed candidates for appointment.\u00a0 In most cases, this will result in HKIAC appointing the candidate designated by the participating parties.<\/p>\n<p>Nevertheless, as mentioned above, Articles 8.2(c), 28.8 and 29.2 remain important in that they empower HKIAC to \u201c<em>wipe the slate clean<\/em>\u201d and appoint the entire arbitral tribunal without regard to any party\u2019s designation in appropriate circumstances, such as when there is a reasonable apprehension of unequal treatment of the parties in the appointment process.<\/p>\n<h1><strong>Case study<\/strong><\/h1>\n<p>In this section, we illustrate the above with a case study in respect of a BRI dispute administered by HKIAC which involved a multi-contract scenario.\u00a0 All identifying and confidential information has been removed.<\/p>\n<p>In this case, the claimant was a subsidiary of a Chinese state-owned enterprise and the respondent was an oil and gas company incorporated in an African state.\u00a0 The parties executed two contracts which were two years apart.\u00a0 Pursuant to the two contracts, the claimant agreed to provide certain types of data analysis services to facilitate the respondent\u2019s oil and gas exploration projects in the African state.\u00a0 The dispute concerned the alleged failure by the respondent in making payment to the claimant for its data analysis services.<\/p>\n<p>Each contract included an arbitration clause, which provides that all disputes arising out of or in connection with the contract shall be resolved in accordance with the HKIAC administered arbitration rules.\u00a0 Differences between the two arbitration clauses include:<\/p>\n<ul>\n<li>The first arbitration clause did not specify the seat of arbitration. The second arbitration clause provided for the seat of arbitration to be Hong Kong.<\/li>\n<li>The first arbitration clause provided for the arbitration to be finally settled by three arbitrators but was silent on the appointment mechanism. The second arbitration clause also provided for three arbitrators, but further specified that \u201c<em>each party shall appoint one arbitrator within 30 days of receipt of the notice of arbitration, and the two arbitrators so appointed shall appoint the presiding arbitrator within 30 days of their nomination. If either does not appoint an arbitrator as specified in the preceding sentence or if the co-arbitrators fail to agree on the presiding arbitrator within 30 days of their nomination, then HKIAC shall appoint such arbitrator<\/em>\u201d.<\/li>\n<\/ul>\n<p>The claimant commenced a single arbitration under the two contracts pursuant to Article 29 of the 2018 HKIAC Administered Arbitration Rules (<strong>2018 Rules<\/strong>), which were the applicable HKIAC administered arbitration rules at the time of commencement.<\/p>\n<p>In accordance with Article 19.5 of the 2018 Rules, HKIAC had to consider whether it was \u201c<em>satisfied, prima facie\u2026the arbitration has been properly commenced under Article 29<\/em>\u201d and examined each of the three criteria under Article 29.<\/p>\n<p>In relation to Article 29(a) (common question of law or fact), it was recognised that common questions of law or fact exist under both contracts, as the underlying disputes both involve the respondent\u2019s alleged failure to pay the sums due under the contracts for services provided by the claimant.\u00a0 The Secretariat was therefore of the view that the criterion under Article 29(a) of the 2018 Rules was satisfied.<\/p>\n<p>In relation to Article 29(b) (claims arising out of the same transaction or series of related transactions), it was noted that both contracts concerned the provision by the claimant of similar data analysis services in relation to the same oil and gas exploration projects.\u00a0 The Secretariat was therefore of the view that the claims arose from related transactions, such that the criterion under Article 29(b) of the 2018 Rules was also satisfied.<\/p>\n<p>In relation to Article 29(c) (compatibility of arbitration agreements), the Secretariat noted with respect to the two arbitration clauses that: (i) the parties are the same; (ii) the 2018 Rules apply under both clauses; and (iii) the number of arbitrators provided are the same (i.e. three).<\/p>\n<p>Under the arbitration clause, which is silent on the appointment mechanism of the tribunal, the default appointment mechanism under Articles 8.1 and 8.2 of the 2018 Rules apply, i.e. the claimant shall designate the first co-arbitrator in its Notice of Arbitration, the respondent shall designate the second co-arbitrator in its Answer to the Notice of Arbitration (i.e. within 30 days from receipt of the Notice of Arbitration), and the two co-arbitrators shall designate the presiding arbitrator within 30 days from the confirmation or appointment of the second co-arbitrator.<\/p>\n<p>The Secretariat noted that the only discrepancy between the appointment mechanisms under the two arbitration clauses was the time limit for the claimant to designate the first co-arbitrator.\u00a0 Under the first arbitration clause, the designation should be made in the Notice of Arbitration, whereas under the second arbitration clause, the designation should be made within 30 days from the receipt of the Notice of Arbitration.<\/p>\n<p>In this case, the claimant nominated the first co-arbitrator 28 days after its commencement of the arbitration, which was within the time limit set out in the second arbitration clause.\u00a0 Although the designation was not in strict compliance with Article 8.1(a) of the 2018 Rules, which is applicable under the first arbitration clause, it could be remedied by virtue of Article 3.6 of the 2018 Rules, which provides that \u201c<em>HKIAC may amend the time limits provided for in these Rules [\u2026] whether any such time limits have expired\u2026<\/em>\u201d.\u00a0 In light of this, HKIAC considered that the discrepancy in the time limit for designating the first co-arbitrator could be surmounted by HKIAC\u2019s exercising of its power under Article 3.6 and thus, the mechanisms for designating the first co-arbitrator under the two arbitration clauses were compatible.<\/p>\n<p>The Secretariat also examined the appointment mechanisms with respect to the second co-arbitrator and the presiding arbitrator under the two arbitration clauses and concluded that they were compatible.\u00a0 The time limit for the respondent to designate the second co-arbitrator under Article 8.1(a) of the 2018 Rules (as applicable to the first contract) was the same as that provided for in the second arbitration clause, and the time limit for the two co-arbitrators to select a presiding arbitrator under Article 8.1(d) of the 2018 Rules (as applicable to the first contract) was also the same as that provided for in the second arbitration clause.<\/p>\n<p>In view of the above, the Secretariat considered that there was no compatibility issue between the arbitration clauses under the two contracts and, thus, the criterion under Article 29(c) of the 2018 was satisfied.\u00a0 The Secretariat made the further observation that Article 29 of the 2018 Rules was intended to facilitate greater efficiency by taking into account commercial realities in as many ways as possible, and proceeding as a single arbitration under the two contracts would improve the efficiency of resolving the disputes between the parties.<\/p>\n<p>The Secretariat therefore recommended to the Proceedings Committee that HKIAC allow this single arbitration to proceed under the two contracts pursuant to Article 29 of the 2018 Rules.\u00a0 The recommendation was unanimously endorsed by the Proceedings Committee.<\/p>\n<p>The above case study is an example of how HKIAC assessed the criteria under Article 29 of the 2018 Rules, especially the compatibility of arbitration agreements requirement under Article 29(c), where the arbitration clauses are not identical.\u00a0 As mentioned above, users are advised to refer to the detailed Practice Note on Compatibility of Arbitration Clauses for a better sense of how HKIAC generally assesses the compatibility of arbitration clauses.<\/p>\n<h1><strong>Conclusion<\/strong><\/h1>\n<p>Scenarios involving multiple parties and multiple contracts are almost unavoidable in BRI projects.\u00a0 Although these were often labelled as \u201ccomplex\u201d arbitrations when disputes arise, there are now sophisticated provisions governing single arbitration under multiple contracts, consolidation, joinder and concurrent proceedings under the HKIAC administered rules to prevent them from becoming legally daunting tasks.<\/p>\n<p>HKIAC undertakes careful analysis in all multi-party and multi-contract arbitrations, recognising that many factors are often at play, including the appreciation that parties have high expectations in conducting related arbitrations in an efficient and pragmatic manner, but also the appreciation that party consent is the cornerstone of arbitration and the parties\u2019 agreement on the arbitral procedure should not be changed in a way that leaves an arbitration award open to challenge.\u00a0 With its tried and tested arbitration rules and extensive experience, HKIAC has stood out as a favourable institution for administering complex BRI disputes.<\/p>\n<p>As illustrated in this chapter, Hong Kong and HKIAC have proven record and experience of handling cross-border disputes involving Mainland Chinese parties and other BRI jurisdictions, which is gained through consistently demonstrating a commitment to independence, neutrality and efficiency, especially in complex, high-stakes disputes.\u00a0 The strong record of enforcement of HKIAC\u2019s arbitral awards in Hong Kong, Mainland China and elsewhere and the effectiveness of the Interim Measures Arrangement reinforce the position of Hong Kong and HKIAC as a preferred forum for BRI disputes.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>Introduction The Belt and Road Initiative (BRI), launched by the PRC government in 2013, is an initiative spanning the land-based \u201cSilk Road Economic Belt\u201d and the seafaring \u201c21st Century Silk Road\u201d.\u00a0 It is aimed at promoting connectivity and international co-operation across Asia, Europe and Africa, covering over 150 jurisdictions, collectively home to over 65% of [&hellip;]<\/p>\n","protected":false},"featured_media":0,"parent":38827,"template":"","meta":{"inline_featured_image":false},"product_brand":[],"product_cat":[3224],"product_tag":[],"class_list":{"0":"post-38868","1":"product","2":"type-product","3":"status-publish","5":"product_cat-belt-and-road-initiative","7":"first","8":"instock","9":"downloadable","10":"virtual","11":"taxable","12":"purchasable","13":"product-type-simple"},"yoast_head":"<!-- This site is optimized with the Yoast SEO plugin v26.6 - https:\/\/yoast.com\/wordpress\/plugins\/seo\/ -->\n<title>Multi-party and multi-contract BRI disputes at HKIAC<\/title>\n<meta name=\"description\" content=\"This article discusses HKIAC&#039;s caseload involving BRI participants, features of Hong Kong seat and HKIAC arbitrations in BRI disputes, and more.\" \/>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, 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