Drafting repository

Fillable
templates.

Fillable scaffolds for documents by legal tradition, since drafting differs between common law and civil law seats, then by sector. Each sector template points to a real award in the database as a worked example. Fill the fields and a draft builds as you type. For the authoritative forms and rules, each institution’s own page is linked below.

Take a draft into the workspace

Legal tradition
Sector
Commencing arbitration
Statement of Appeal to the Court of Arbitration for SportThe opening document that starts a CAS appeal against a decision of a federation or anti-doping body. It names the decision under appeal, the grounds, and the relief, within the deadline set by the CAS Code.SportWorked example: Olympiakos FC v. Hellenic Football Federation (CAS 2023/A/10168)
Your draft
STATEMENT OF APPEAL

To: The Court of Arbitration for Sport, Lausanne

1. Appellant
[Appellant (athlete, club or federation)]

2. Respondent
[Respondent (the body whose decision is appealed)]

3. Decision appealed against
This appeal is brought against [The decision appealed against (date and reference)].

4. Grounds of appeal
[Short statement of the grounds of appeal]

5. Relief sought
The Appellant requests that the Panel: [The relief sought from the CAS panel]

6. Arbitrator
The Appellant nominates [The arbitrator the appellant nominates (if any)].

This Statement of Appeal is filed under the Code of Sports-related Arbitration. The Appellant reserves the right to file a fuller Appeal Brief within the time allowed.

Reference: CAS Code (Procedural Rules)

A reference scaffold under the CAS Code, not legal advice. The CAS deadline to appeal is short and strict; confirm the time limit in the decision and the Code before filing.

Request for Arbitration under the ICSID ConventionThe document that registers an investor-state claim with ICSID. It identifies the investor and the host state, the investment, the treaty consent relied on, and the measures complained of.Investment and treatyWorked example: Salini Costruttori v. Morocco (the Salini test for what counts as an investment)
Your draft
REQUEST FOR ARBITRATION

To: The Secretary-General, International Centre for Settlement of Investment Disputes

1. The Claimant
[Claimant investor (name, nationality)]

2. The Respondent
[Respondent state]

3. Consent to ICSID jurisdiction
The Claimant relies on [The treaty or law giving consent to ICSID arbitration] as the basis of the parties' consent to arbitration under the ICSID Convention.

4. The investment
[The investment relied on]

5. The dispute
The dispute arises from the following measures of the Respondent: [The state measures complained of]

6. Relief sought
The Claimant seeks: [The relief and any damages sought]

This Request is submitted under Article 36 of the ICSID Convention and the Institution Rules. The Claimant reserves the right to develop its case in a Memorial.

Reference: ICSID Convention, Rules and Regulations

A reference scaffold under the ICSID Convention, not legal advice. Jurisdiction under Article 25 (investment, nationality, consent) is tested early; confirm each element before filing.

FINRA Statement of Claim (customer dispute)The document a customer or investor files to begin a FINRA arbitration against a brokerage firm or registered representative, with the Submission Agreement. It sets out the account, the conduct complained of, and the damages.Securities and financialCommon lawWorked example: a real FINRA customer award (Morgan Stanley v. an individual, case 26-00151)
Your draft
STATEMENT OF CLAIM

Before the Financial Industry Regulatory Authority (FINRA) Office of Dispute Resolution

1. Claimant
[Claimant (customer or investor)]

2. Respondent
[Respondent (brokerage firm and/or representative)]

3. The account
[The account(s) at issue]

4. The claim
The Claimant alleges the following conduct by the Respondent: [The conduct complained of (e.g. unsuitability, misrepresentation, churning)]

5. Damages
The Claimant seeks: [The damages claimed]

The Claimant submits this dispute to arbitration under the FINRA Code of Arbitration Procedure for Customer Disputes and signs the accompanying Submission Agreement.

Reference: FINRA Code of Arbitration Procedure

A reference scaffold under the FINRA Code, not legal advice or financial advice. The Submission Agreement and the eligibility rule (the six-year limit) should be checked before filing.

Referral of a Grievance to Labour ArbitrationThe document a union or employer uses to refer an unresolved grievance to a single arbitrator under a collective agreement. It identifies the agreement, the grievance, and the remedy sought.Labour and employmentCommon lawWorked example: a real Ontario grievance award (employer and union, on a transfer dispute)
Your draft
REFERRAL TO ARBITRATION

1. Referring party
[Referring party (union or employer)]

2. Other party
[Other party]

3. The collective agreement
The grievance concerns [The collective agreement and the article(s) in dispute].

4. The grievance
[The grievance (what happened, and when)]

5. Remedy sought
[The remedy sought]

6. Arbitrator
The parties refer this grievance to [Proposed or agreed arbitrator] for a binding award under the collective agreement.

This referral is made under the grievance and arbitration provisions of the collective agreement and the applicable labour relations statute.

Reference: Ontario grievance arbitration awards portal

A reference scaffold for grievance arbitration, not legal advice. Time limits in the collective agreement are usually strict; confirm them before referring.

Notice of Arbitration (PCA, UNCITRAL Rules)The opening notice for an arbitration administered by the Permanent Court of Arbitration under the UNCITRAL Rules, used for interstate, investor-state and contract disputes. It identifies the parties, the treaty or contract, and the claim.Investment and treatyWorked example: a real PCA interstate arbitration (Azerbaijan v. Armenia, Energy Charter Treaty)
Your draft
NOTICE OF ARBITRATION

Under the UNCITRAL Arbitration Rules, administered by the Permanent Court of Arbitration

1. Claimant
[Claimant (state, investor or party)]

2. Respondent
[Respondent]

3. The instrument relied on
[The treaty, contract or instrument relied on]

4. The dispute
[The nature of the dispute]

5. Relief sought
[The relief sought]

This Notice is given under Article 3 of the UNCITRAL Arbitration Rules. The Claimant proposes that the Permanent Court of Arbitration act as administering authority.

Reference: PCA and the UNCITRAL Arbitration Rules

A reference scaffold under the UNCITRAL Rules, not legal advice. The constitution of the tribunal and the seat should be addressed early.

Request for Arbitration (generic, institution-agnostic)A clean opening Request that carries the information every set of rules asks for: the parties, the agreement, the dispute, the relief, the seat, the number of arbitrators and the language. Adjust to the chosen institution's rules before filing.
Your draft
REQUEST FOR ARBITRATION

To: The Registrar, [Administering institution (e.g. LCIA, ICC, SIAC)]

1. The Claimant
[Claimant (full name and address)]

2. The Respondent
[Respondent (full name and address)]

3. The arbitration agreement
The Claimant relies on the arbitration agreement contained in [The contract and the arbitration clause relied on], under which the parties agreed to refer disputes to arbitration administered by [Administering institution (e.g. LCIA, ICC, SIAC)].

4. The dispute
[Short description of the dispute]

5. The relief sought
The Claimant seeks: [The relief sought]

6. Seat, tribunal and language
The seat of the arbitration is [Seat of arbitration]. The Claimant proposes a tribunal of [Number of arbitrators]. The language of the arbitration shall be [Language of the arbitration].

This Request is submitted in accordance with the applicable rules of [Administering institution (e.g. LCIA, ICC, SIAC)]. The Claimant reserves the right to supplement and amend it.

Reference: ICC Rules, Article 4 (the Request)

A reference scaffold, not legal advice or a substitute for the institution's own rules. Confirm the current rule requirements before filing.

Notice of Arbitration (ad hoc / UNCITRAL)The opening notice for an ad hoc arbitration under the UNCITRAL Rules, where there is no administering institution: the demand to arbitrate, the agreement relied on, the contract and dispute, the relief, and the proposal on arbitrators.
Your draft
NOTICE OF ARBITRATION

From: [Claimant (name and address)]
To: [Respondent (name and address)]

1. Demand
The Claimant hereby gives notice that the dispute described below is referred to arbitration.

2. The arbitration agreement
The Claimant relies on [The arbitration agreement relied on].

3. The contract and dispute
[The contract and the dispute]

4. Relief sought
[The relief or remedy sought]

5. The tribunal
[Proposal on number and appointment of arbitrators]

6. Seat and language
[Proposed seat and language]

This Notice is given under the UNCITRAL Arbitration Rules. The date of commencement is the date on which this Notice is received by the Respondent.

Reference: UNCITRAL Arbitration Rules, Article 3

Follows the contents required by the UNCITRAL Arbitration Rules for a Notice of Arbitration.

A reference scaffold for ad hoc / UNCITRAL commencement. Confirm the current UNCITRAL Rules requirements. Not legal advice.

Responding
Answer / Response to a Request for ArbitrationA respondent's opening answer: acknowledging the Request, stating the response to the claims, raising any jurisdictional objection, and setting out the respondent's position on the tribunal, seat and language.
Your draft
ANSWER TO REQUEST FOR ARBITRATION

To: The Registrar, [Administering institution]
Case: [Case reference (if assigned)]

1. The Respondent
[Respondent (full name and address)]

2. Response to the Claimant's Request
The Respondent has received the Request for Arbitration filed by [Claimant] and responds as follows.

3. The Respondent's position
[Short statement of the respondent's position on the claims]

4. Jurisdiction
[Any objection to jurisdiction (leave blank if none)]

5. Tribunal
On the constitution of the tribunal, the Respondent's position is: [Respondent's position on the number of arbitrators].

The Respondent reserves all rights, including the right to amend this Answer and to advance further objections and defences.

Reference: ICC Rules, Article 5 (the Answer)

A reference scaffold, not legal advice. Check the response deadline under the relevant rules, which is often short.

Tribunal and procedure
Tribunal secretary: consent and declaration of independenceA short declaration for a proposed tribunal secretary, confirming availability, independence and impartiality, and acceptance of the duty of confidentiality. Many institutions require this before a secretary is appointed.
Your draft
DECLARATION OF THE PROPOSED TRIBUNAL SECRETARY

Case: [Case reference]

I, [Proposed secretary's full name], having been proposed as secretary to the tribunal in the above arbitration, declare that:

1. I am available to carry out the duties of tribunal secretary and to do so diligently.
2. I am and shall remain independent and impartial as between the parties, and I am not aware of any circumstance likely to give rise to justifiable doubts as to my independence or impartiality. I shall disclose any such circumstance that arises.
3. I shall keep confidential all matters relating to the arbitration.
4. I understand that the tribunal remains responsible for all decisions, and that no decision-making function will be delegated to me.

Signed: [Proposed secretary's full name]

Reference: ICC Note on the appointment of administrative secretaries

A reference scaffold. The permitted role of a tribunal secretary varies by institution and by tribunal; check the applicable rules and any secretary guidelines.

Arbitrator's acceptance and statement of independenceAn arbitrator's acceptance of appointment, with the declaration of independence and impartiality and any disclosure, in the form the institutions require before confirmation.
Your draft
ACCEPTANCE AND STATEMENT OF INDEPENDENCE

Case: [Case reference]

I, [Arbitrator's full name], having been [How appointed (party-nominated, institution, chair)], confirm as follows.

1. Acceptance
I accept the appointment and confirm that I am available to devote the time necessary to conduct the arbitration diligently and to its conclusion.

2. Independence and impartiality
I am impartial and independent of each of the parties and intend to remain so. To the best of my knowledge, there are no circumstances, past or present, likely to give rise to justifiable doubts as to my impartiality or independence.

3. Disclosure
[Any matter to disclose (leave blank if none)]

4. Continuing duty
I undertake to disclose promptly any such circumstance that may arise during the arbitration.

Signed: [Arbitrator's full name]

Reference: IBA Guidelines on Conflicts of Interest in International Arbitration

Reflects the acceptance-and-disclosure structure required across the ICC, LCIA, SIAC and ICSID frameworks.

A reference scaffold. Each institution has its own acceptance and disclosure form; use it where one is prescribed. Not legal advice.

Terms of Reference (ICC-style)The Terms of Reference an ICC tribunal draws up at the outset: the parties and representatives, the summary of claims and relief, the issues to be determined, the seat and the procedural rules.
Your draft
TERMS OF REFERENCE

Case: [Case reference]

1. The parties
[The parties and their representatives]

2. Summary of claims and relief
[Summary of the claims and relief sought]

3. Issues to be determined
[The issues to be determined (or how they will be settled)]

4. Seat, language and rules
[Seat, language and applicable rules]

5. The Tribunal will conduct the arbitration in accordance with the applicable rules and this document, which the Parties and the Tribunal sign.

Reference: ICC Rules, Article 23 (Terms of Reference)

Follows ICC Rules Article 23 on the Terms of Reference.

A reference scaffold. The Terms of Reference is a distinctive ICC requirement under its Rules. Not legal advice.

Procedural orders and directions
Procedural Order: hearing organisationA procedural order organising a hearing: the matters in issue, the allocation of time, the sequence of submissions and witnesses, and the practical directions. Follows the structure used in published investment-treaty procedural orders.
Your draft
PROCEDURAL ORDER

Case: [Case reference]
Tribunal: [The tribunal]

1. In preparation for the hearing to be held on [Hearing dates and place], and following consultation with the Parties, the Tribunal issues the following directions.

2. Matters in issue
The following procedural matters remained outstanding and were addressed by the Parties: [The outstanding procedural matters in issue]

3. Allocation of time
[Allocation of time (e.g. each side's total hours)]

4. Sequence
[Sequence of submissions and witnesses]

5. The Tribunal may vary these directions as the efficient conduct of the hearing requires. All other directions previously given remain in force.

Reference: ICSID case database (procedural orders)

Modelled on the structure of published ICSID hearing-organisation orders (e.g. procedural orders in the ICSID case database). Verify against the originals via the Awards board.

A reference scaffold for the structure of a hearing-organisation order. Not legal advice.

Application for bifurcation (preliminary objections)An application asking the tribunal to hear jurisdictional or preliminary objections first, separately from the merits. Sets out the objections, why they are suitable to be heard first, and the efficiency case for bifurcation.
Your draft
APPLICATION FOR BIFURCATION

Case: [Case reference]
Applicant: [The applying party]

1. The Applicant respectfully requests that the Tribunal address the following objections as a preliminary matter, separately from and in advance of the merits.

2. The objections
[The preliminary objections relied on]

3. Why these should be heard first
[Why these are suitable to be decided first]

4. Deciding these objections first is capable of disposing of all or part of the claim, and would save the time and cost of a full merits hearing. The Applicant submits that bifurcation is the efficient course.

5. The Applicant reserves all rights on jurisdiction and the merits.

Reference: ICSID Arbitration Rules

Reflects the structure of bifurcation applications and decisions on jurisdiction in the ICSID and treaty practice. Verify against the originals via the Awards board.

A reference scaffold. Whether to bifurcate is a matter for the tribunal's discretion under the applicable rules. Not legal advice.

Procedural Order No. 1 (the procedural framework)The tribunal's first and foundational order: the procedural rules, the seat and language, the timetable for submissions, the approach to evidence and document production, and the arrangements for hearings. The backbone of every reference.
Your draft
PROCEDURAL ORDER NO. 1

Case: [Case reference]
Tribunal: [The tribunal]

1. Constitution
The Tribunal is duly constituted. No party has raised any objection to its constitution.

2. Rules, seat and language
[Applicable rules, seat and language]

3. Procedural timetable
[The procedural timetable for written submissions]

4. Evidence and document production
[Approach to evidence and document production]

5. Hearing
[Hearing arrangements]

6. General
The Tribunal may vary this Order as the fair and efficient conduct of the arbitration requires, after consulting the Parties. Communications are to be sent to all members of the Tribunal and all Parties simultaneously.

Reference: UNCITRAL Rules, Article 17 (general procedural powers)

Reflects the structure of Procedural Order No. 1 standard across institutional and ad hoc references.

A reference scaffold for the foundational procedural order. The content is settled with the parties at the case management conference. Not legal advice.

Written submissions
Statement of ClaimA full statement of claim: the parties, the jurisdiction and the arbitration agreement, the facts in numbered chronological paragraphs, the legal grounds, and the prayer for relief.
Your draft
STATEMENT OF CLAIM

Case: [Case reference]
Between: [Claimant] (Claimant) and [Respondent] (Respondent)

A. Jurisdiction
[Basis of the tribunal's jurisdiction]

B. The facts
[The material facts (chronological)]

C. Legal grounds
[The legal grounds relied on]

D. Relief sought
The Claimant claims: [The relief claimed]

The Claimant reserves the right to amend or supplement this Statement of Claim and to adduce further evidence.

Reference: UNCITRAL Rules, Article 20 (statement of claim)

Follows the standard structure of a memorial / statement of claim used across commercial and investment arbitration.

A reference scaffold. Pleading requirements differ by seat and rules. Not legal advice.

Statement of Defence (and counterclaim)A respondent's full defence: admissions and denials paragraph by paragraph, the positive defence, any jurisdictional objection, and any counterclaim with its own relief.
Your draft
STATEMENT OF DEFENCE

Case: [Case reference]
Respondent: [Respondent]

A. Jurisdiction
[Any objection to jurisdiction (leave blank if none)]

B. Response to the claim
[What is admitted and what is denied]

C. The Respondent's case
[The positive case in defence]

D. Counterclaim
[Any counterclaim and the relief sought on it (leave blank if none)]

The Respondent reserves all rights, including to amend this Defence and to rely on further evidence.

Reference: UNCITRAL Rules, Article 21 (statement of defence)

Follows the standard structure of a statement of defence / counter-memorial in commercial and investment arbitration.

A reference scaffold. Check the deadline for the defence under the applicable rules. Not legal advice.

Submission on jurisdiction (Kompetenz-Kompetenz)A focused submission on the tribunal's jurisdiction: the objection or affirmation, the arbitration agreement's scope, the principle that the tribunal may rule on its own jurisdiction, and the relief sought on the issue.
Your draft
SUBMISSION ON JURISDICTION

Case: [Case reference]
By: [The party making the submission]

1. The Tribunal is competent to rule on its own jurisdiction (the principle of Kompetenz-Kompetenz), and is invited to do so.

2. Position
[Whether jurisdiction is challenged or affirmed, and why]

3. The arbitration agreement
[The scope of the arbitration agreement relied on]

4. Relief
The party invites the Tribunal to rule accordingly on its jurisdiction before proceeding further.

Reference: UNCITRAL Model Law, Article 16 (competence to rule on jurisdiction)

Reflects the Kompetenz-Kompetenz structure recognised across the major rules and the Model Law.

A reference scaffold. The doctrine and its limits vary by seat and law. Not legal advice.

Reply (responding to the defence)The claimant's reply to the statement of defence: answering the positive defence and any counterclaim, without repeating the statement of claim, and confirming the relief sought.
Your draft
REPLY

Case: [Case reference]
By: [Claimant]

1. This Reply responds to the Statement of Defence. It does not repeat the Statement of Claim, which is maintained in full.

2. Reply to the defence
[The reply to the defence raised]

3. Response to the counterclaim
[The response to any counterclaim (leave blank if none)]

4. The Claimant maintains the relief sought in its Statement of Claim and asks the Tribunal to dismiss the Respondent's case.

Reference: UNCITRAL Rules on written submissions

Reflects the reply / reply memorial structure standard in commercial and investment arbitration.

A reference scaffold. The sequence and scope of reply submissions are set by the procedural timetable. Not legal advice.

Evidence and witnesses
Witness statement (skeleton)A skeleton witness statement in the standard form: numbered paragraphs in the witness's own words, a statement of the source of knowledge, and a statement of truth.
Your draft
WITNESS STATEMENT OF [Witness full name]

Case: [Case reference]
Made on behalf of: [The party calling the witness]

I, [Witness full name], will say as follows.

1. I am [The witness's role / connection to the matter]. The facts in this statement are within my own knowledge except where I indicate otherwise, in which case I give the source of my information and believe it to be true.

2. [Set out the evidence in numbered paragraphs, chronologically, in the witness's own words.]

Statement of truth
I believe that the facts stated in this witness statement are true.

Signed: [Witness full name]
Dated: 

Reference: IBA Rules on the Taking of Evidence

A reference scaffold. Form requirements differ across seats and institutions; some require a specific statement of truth.

Request to produce documents (Redfern-style)A document-production request in the schedule form used in international arbitration: the documents or category sought, their relevance and materiality, and the reasoned basis for the request. Built for the Redfern Schedule columns.
Your draft
REQUEST TO PRODUCE

Case: [Case reference]
Requesting Party: [The requesting party]

1. Documents requested
[The documents or narrow category sought]

2. Relevance and materiality
[Relevance and materiality to the case]

3. Basis
The Requesting Party understands these documents to exist and to be in the possession, custody or control of the other Party, because: [Basis for believing the documents exist and are in the other party's control]

4. The documents are not in the possession of the Requesting Party, and are relevant to the case and material to its outcome.

Reference: IBA Rules on the Taking of Evidence (Redfern Schedule)

Follows the Redfern Schedule structure standard in international arbitration practice.

A reference scaffold built for the Redfern Schedule form widely used under the IBA Rules on the Taking of Evidence. Not legal advice.

Instructions to an expert witnessA letter of instruction to an independent expert: the issues the expert is asked to address, the materials provided, the expert's overriding duty to the tribunal, and the form the report should take.
Your draft
INSTRUCTIONS TO EXPERT

To: [The expert's name and field]
Case: [Case reference]
Instructing party: [The instructing party]

1. You are instructed to provide an independent expert opinion in this arbitration.

2. Issues
You are asked to address: [The issues the expert is asked to address]

3. Materials
The following have been provided to you: [The materials provided to the expert]

4. Your duty
Your overriding duty is to assist the Tribunal on matters within your expertise. That duty overrides any obligation to the party instructing or paying you. Your report must state the facts and assumptions on which your opinions are based, and any matters that detract from your opinions.

5. Your report should set out your qualifications, the issues addressed, your opinions and the reasons for them, and a statement that you understand and have complied with your duty to the Tribunal.

Reference: IBA Rules, Article 5 (party-appointed experts)

Reflects the expert-duty structure common across the IBA Rules and major institutional practice.

A reference scaffold. The form and duty of experts vary by seat, rules and any tribunal directions. Not legal advice.

Interim and emergency relief
Application for emergency / interim reliefAn application for urgent interim measures, before or after the tribunal is constituted: the relief sought, the urgency, the risk of harm, and the case that the threshold for interim relief is met.
Your draft
APPLICATION FOR INTERIM MEASURES

Case: [Case reference (or note pre-constitution)]
Applicant: [The applying party]

1. Relief sought
[The interim relief sought]

2. Urgency
[Why the relief is urgent and cannot await the full hearing]

3. Harm
Unless the relief is granted, the following harm will result: [The harm that will result if relief is not granted]

4. Threshold
The Applicant submits that there is a serious issue to be tried, that the harm is not adequately reparable by an award of damages, and that the balance favours granting the measure. The Applicant offers the usual undertakings.

Reference: ICC Rules, Article 29 and Appendix V (emergency arbitrator)

Reflects the interim-measures and emergency-arbitrator structure across the ICC, LCIA, SIAC and UNCITRAL frameworks.

A reference scaffold. Thresholds for interim and emergency relief differ across rules and seats. Not legal advice.

Clauses
Arbitration clause for a contractA drafting frame for an arbitration clause. The institutions publish their own model wording, which is the safest base; this frame helps you set the variables (seat, number of arbitrators, language, governing law) around it.
Your draft
ARBITRATION CLAUSE

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 [Chosen institution and rules], which rules are deemed to be incorporated by reference into this clause.

The seat of the arbitration shall be [Seat of arbitration].
The tribunal shall consist of [Number of arbitrators].
The language of the arbitration shall be [Language].
The governing law of the contract shall be [Governing law of the contract].

Reference: LCIA recommended clauses

Use the chosen institution's official model clause as the authoritative base (linked below). Careless drafting can render a clause inoperable.

Costs and awards
Final award in a debt-recovery arbitration (English law, CIArb-administered)The structure of a reasoned final award in a documents-only debt-recovery arbitration seated in London: the parties and the arbitration agreement, the tribunal and procedure, the loan or contract and the breach, the sums due, and the operative order for principal, interest, fees and costs. Modelled on a real award on the board.Common lawWorked example: Prodigy Finance v Abhinav Mishra, Award, 25 June 2025 (CIArb-administered, London seat)
Your draft
FINAL AWARD

Seat: London. Governing law: the law of England and Wales.

A. The parties
Claimant: [Claimant (the lender or assignee)]
Respondent: [Respondent (the borrower)]

B. The arbitration agreement and governing law
[The loan or contract, the arbitration clause, any assignment, and the governing law]

C. The tribunal and procedure
[The tribunal, appointment and procedure (e.g. documents-only)]

D. Factual background
[The factual background (drawdown, default, notices)]

E. The issues
Whether the agreement and any assignment are valid and binding; whether the required notices were given; the sum due; interest; and costs.

F. The tribunal's findings
[The tribunal's findings on liability and the sum due]

G. Order
The Tribunal awards and orders: [The operative order (principal, interest, fees, costs)]
This covers the principal, contractual interest, any fixed fee, the costs of the arbitration, and a direction for payment.

Reference: Consumer Credit Act 1974

A reference scaffold modelled on a real award, not legal advice. Debt-recovery awards turn on a valid assignment and on the required statutory notices (for example under the Consumer Credit Act 1974 where it applies). Confirm the governing law and the applicable consumer-credit requirements.

Partial award on jurisdiction and admissibility (ICC, investment claim)The structure of a partial award deciding jurisdiction and admissibility before the merits: the parties and tribunal, the procedural history and relief sought, the applicable legal framework, the jurisdiction objections, the admissibility objections, costs, and the decision. Modelled on a real award on the board.Investment and treatyWorked example: Juvel Ltd and Bithell Holdings Ltd v. Poland, Partial Final Award (ICC-administered investment claim)
Your draft
PARTIAL AWARD ON JURISDICTION AND ADMISSIBILITY

I. The parties
[The parties]

II. The tribunal
[The tribunal]

III. Procedural history
[The procedural history]

IV. Requests for relief
[The requests for relief]

V. The applicable legal framework
[The applicable legal framework (treaty or contract, and applicable law)]

VI. Jurisdiction
The Tribunal addresses the objections to its jurisdiction: [The objections to jurisdiction relied on]

VII. Admissibility
The Tribunal addresses the objections to admissibility: [The objections to admissibility relied on]

VIII. Costs
The Tribunal reserves or determines the costs of this phase as set out below.

IX. Decision
[The decision on jurisdiction and admissibility]

Reference: ICC Rules of Arbitration

A reference scaffold modelled on a real award, not legal advice. In investment claims, jurisdiction objections (consent, investor and investment, treaty scope, intra-EU or Achmea points, MFN) and admissibility objections (abuse of process, unclean hands) are commonly heard first. Confirm the applicable rules and treaty.

Award in an investment-treaty arbitration (ICSID)The structure of a reasoned award in an ICSID investment-treaty arbitration: the parties, the procedural history, the facts and the investor's allegations, the applicable law, the tribunal's decision on liability, the quantification of damages, costs, and the operative award. Modelled on a real award on the board.Investment and treatyWorked example: Metalclad Corporation v. United Mexican States, Award, 30 August 2000 (ICSID, NAFTA Chapter 11)
Your draft
AWARD

I. Introduction
[Introduction (the dispute in one paragraph)]

II. The parties
[The parties (investor and host state)]

III. Procedural history
[The procedural history]

IV. The facts and the Claimant's allegations
[The facts and the Claimant's allegations (the measures complained of)]

V. Applicable law
[The applicable law (the treaty and international law)]

VI. The Tribunal's decision
[The tribunal's decision on liability]

VII. Quantification of damages
[The quantification of damages]

VIII. Costs
The Tribunal determines the costs of the arbitration and their allocation as set out below.

IX. Award
For the reasons given, the Tribunal awards: [The operative award]

Reference: ICSID Convention, Regulations and Rules

A reference scaffold modelled on a real award, not legal advice. Investment-treaty awards turn on the standards in the relevant treaty (for example fair and equitable treatment and protection against expropriation) and on causation and valuation for damages. Confirm the treaty and the ICSID framework.

Appeal award in a sports arbitration (CAS)The structure of a reasoned appeal award under the Code of Sports-related Arbitration, following how CAS awards are actually laid out: a headnote, the parties and panel, a FACTS part, then a LAW part covering jurisdiction (Swiss law and the CAS Code), admissibility, the applicable law and the merits on the sporting regulations, costs, and the operative decision. Modelled on the CAS Code and a real award on the board.SportWorked example: J. v. Udinese Calcio S.p.A., CAS 2008/A/1665
Your draft
ARBITRAL AWARD
delivered by the Court of Arbitration for Sport
seated in Lausanne, Switzerland

Appellant: [Appellant]
Respondent: [Respondent]
Panel: [The Panel (sole arbitrator or three members)]

Headnote
A short statement of the legal principle the award turns on.

I. The parties
The Appellant and the Respondent are identified above.

FACTS

II. Factual background and the decision appealed
[The factual background and the decision appealed]

III. Proceedings before the CAS
The statement of appeal, the appeal brief, the answer, the constitution of the Panel, any hearing, and the parties' requests for relief are recorded here.

LAW

IV. Jurisdiction
The seat of the arbitration is Lausanne, so the award is subject to Chapter 12 of the Swiss Private International Law Act (Article 186 on the tribunal's competence to rule on its own jurisdiction). The CAS has jurisdiction under Article R47 of the Code by virtue of the arbitration clause in [The applicable sporting regulations (e.g. FIFA Statutes, RSTP)] and the parties' agreement.

V. Admissibility
The appeal was filed within the time limit in Article R49 of the Code, or the deadline in the applicable regulations, and is admissible.

VI. Applicable law
[The law applicable to the merits (Article R58)]

VII. Merits
Applying [The applicable sporting regulations (e.g. FIFA Statutes, RSTP)] and exercising its full power of review under Article R57 of the Code, the Panel finds: [The Panel's analysis on the merits]

VIII. Costs
The Panel determines the costs of the arbitration and the parties' legal costs in accordance with Article R64 or Article R65 of the Code.

IX. Decision
[The operative decision]

Reference: Code of Sports-related Arbitration (CAS)

A reference scaffold modelled on the Code of Sports-related Arbitration and on real CAS awards, not legal advice. CAS awards are seated in Lausanne and so fall under Chapter 12 of the Swiss Private International Law Act (Article 186). They turn on the time limit for the appeal (Article R49), the law applicable to the merits (Article R58), the relevant sporting regulations (for football, the FIFA Statutes and the Regulations on the Status and Transfer of Players), and the Panel's full power of review (Article R57). Confirm the version of the Code and the regulations in force.

Submission on costsA submission on costs after the merits: the costs claimed, the basis for recovery, the conduct relied on, and the application for the tribunal to award costs to follow the event.
Your draft
SUBMISSION ON COSTS

Case: [Case reference]
By: [The party claiming costs]

1. The party invites the Tribunal to award its costs of the arbitration.

2. Costs claimed
[The costs claimed (fees, tribunal costs, institution fees)]

3. Basis
[The basis for recovery and any conduct relied on]

4. Costs should follow the event. The party submits that its costs were reasonably incurred and proportionate, and asks the Tribunal to order the other party to bear them, together with the costs of the Tribunal and the institution.

Reference: UNCITRAL Rules, Articles 40 to 43 (costs)

Reflects the structure of costs submissions and the reasoning in published final costs awards.

A reference scaffold. The costs power and its principles vary by rules and seat. Not legal advice.

Final award (skeleton structure)The skeleton of a reasoned final award: the parties and tribunal, the procedural history, the issues, the tribunal's analysis and findings, the decision on costs, and the operative dispositive section.
Your draft
FINAL AWARD

Case: [Case reference]
Tribunal: [The tribunal]

A. Procedural history
[Short procedural history]

B. The issues
[The issues determined]

C. Analysis and findings
[The findings and reasons (summary)]

D. Costs
The Tribunal has determined the costs of the arbitration and their allocation as set out below.

E. Disposition
For the reasons given, the Tribunal awards and orders: [The operative orders (what is awarded)]

This award is final and binding. Made at the seat of arbitration on the date below.

Signed by the Tribunal.

Reference: UNCITRAL Rules, Articles 34 to 36 (form and effect of the award)

Reflects the structure of reasoned final awards published in the ICSID, CAS and commercial collections, viewable on the Awards board.

A reference scaffold for the structure of a reasoned award. Form and signing requirements differ by seat and rules. Not legal advice.

Award on agreed terms (consent award)Where the parties settle during the arbitration, the tribunal can record the settlement as an award on agreed terms, which is enforceable like any other award. This is its skeleton.
Your draft
AWARD ON AGREED TERMS

Case: [Case reference]
Tribunal: [The tribunal]

1. The Parties have settled their dispute and have requested the Tribunal to record their settlement as an award on agreed terms.

2. Agreed terms
[The agreed terms to be recorded]

3. The Tribunal, being satisfied that the Parties have genuinely agreed these terms and seeing no reason to refuse, records them as an award on agreed terms. This award has the same status and effect as any award on the merits.

Made at the seat on the date below. Signed by the Tribunal.

Reference: UNCITRAL Rules, Article 36 (settlement / agreed terms)

Follows the agreed-terms award structure recognised across the UNCITRAL Rules and the Model Law.

A reference scaffold. A consent award lets a settlement be enforced as an award. Not legal advice.

Challenge and enforcement
Challenge to an arbitratorA challenge seeking the removal of an arbitrator: the circumstances said to give rise to justifiable doubts as to independence or impartiality, the timing, and the relief sought.
Your draft
CHALLENGE TO AN ARBITRATOR

Case: [Case reference]
By: [The challenging party]
Arbitrator challenged: [The arbitrator challenged]

1. The party challenges the above arbitrator on the ground that circumstances exist that give rise to justifiable doubts as to his or her independence or impartiality.

2. The circumstances
[The circumstances relied on]

3. Timing
The party learned of these circumstances as follows: [When and how the party learned of them]. The challenge is brought promptly, within the time allowed by the applicable rules.

4. The party asks that the arbitrator be removed and replaced in accordance with the rules.

Reference: LCIA challenge decisions (on the Awards board)

Reflects the structure of arbitrator challenges and the LCIA Court's published challenge decisions, viewable on the Awards board.

A reference scaffold. Challenge grounds, the test and the time limit differ by rules and seat. Not legal advice.

Application to enforce an award (New York Convention)An application to recognise and enforce a foreign arbitral award under the New York Convention: the award, the agreement, and the case that none of the narrow grounds for refusal applies.
Your draft
APPLICATION FOR RECOGNITION AND ENFORCEMENT

Applicant: [The party seeking enforcement]
Respondent: [The party against whom enforcement is sought]
Before: [The court / jurisdiction where enforcement is sought]

1. The Applicant seeks recognition and enforcement of the following arbitral award: [The award (tribunal, seat, date, sum)]

2. The Applicant produces the duly authenticated award and the arbitration agreement, as required by Article IV of the New York Convention.

3. None of the grounds for refusing recognition under Article V of the Convention applies. The award is binding, has not been set aside or suspended, and enforcement is not contrary to public policy.

4. The Applicant asks the court to recognise the award and enter judgment in its terms.

Reference: New York Convention 1958, Articles IV and V

Follows the Article IV and V framework of the 1958 New York Convention.

A reference scaffold. Enforcement procedure and documents differ by jurisdiction. Not legal advice.

Court powers and challenges (England and Wales)
Application to stay court proceedings (Arbitration Act 1996, s.9)Where a party sues in court on a matter the parties agreed to arbitrate, the other party can apply to stay those proceedings so the dispute goes to arbitration. The stay is mandatory once the conditions are met, but it must be sought before taking a step to answer the substantive claim.Common law
Your draft
APPLICATION TO STAY PROCEEDINGS (Section 9, Arbitration Act 1996)

In: [The court and claim number]
Applicant: [Applicant (the party seeking the stay)]

1. The Applicant applies under section 9 of the Arbitration Act 1996 for a stay of the proceedings brought by [The party who started the court proceedings].

2. The arbitration agreement
The parties agreed to refer disputes to arbitration by [The arbitration agreement relied on].

3. The matter in dispute
[The matter in the proceedings that falls within the agreement] is a matter which, under that agreement, is to be referred to arbitration.

4. The Applicant has not taken any step in these proceedings to answer the substantive claim. The arbitration agreement is not null and void, inoperative, or incapable of being performed.

5. The Applicant asks the court to stay the proceedings so the dispute proceeds to arbitration, with costs.

Reference: Arbitration Act 1996, s.9

Follows section 9 of the Arbitration Act 1996 on staying legal proceedings in favour of arbitration.

A reference scaffold, not legal advice. The s.9 stay is mandatory once the conditions are met, but the right is lost once a party takes a step in the proceedings to answer the claim. Confirm timing before acting.

Application to the court for orders in support (Arbitration Act 1996, s.44)An application to the court for orders in support of an arbitration, such as preserving evidence or assets, where the tribunal cannot act effectively, for example before it is constituted or where the order is needed against a non-party.Common law
Your draft
APPLICATION UNDER SECTION 44, ARBITRATION ACT 1996

Applicant: [The applying party]
Arbitration: [The arbitration (or note that it is not yet commenced)]

1. The Applicant applies under section 44 of the Arbitration Act 1996 for the following order in support of the arbitration: [The order sought (e.g. preservation of evidence or assets, interim injunction)]

2. Why the court should act
[Why the court, rather than the tribunal, must act (urgency, tribunal not yet constituted, order needed against a non-party)]

3. The matter is one in which the court has the same power to make orders as it has in legal proceedings. The order is needed because the tribunal cannot, for the time being, act effectively.

4. The Applicant offers the usual undertakings and asks the court to make the order, with liberty for any affected person to apply.

Reference: Arbitration Act 1996, s.44

Follows section 44 of the Arbitration Act 1996 (court powers in support), as amended by the Arbitration Act 2025.

A reference scaffold, not legal advice. As amended by the Arbitration Act 2025 (in force 1 August 2025), s.44 orders can be made against non-parties, who may appeal without the court's permission. In urgent cases the court acts only as needed to preserve evidence or assets. Confirm the current position.

Leave to enforce an award as a judgment (Arbitration Act 1996, s.66)How an English-seated award is enforced at home: leave to enter judgment in the terms of the award, so it can be executed like any court judgment. For a foreign award under the New York Convention, use the separate enforcement template.Common law
Your draft
APPLICATION FOR LEAVE TO ENFORCE AN AWARD (Section 66, Arbitration Act 1996)

In: [The court in which leave is sought]
Applicant: [The party seeking to enforce]
Respondent: [The party against whom enforcement is sought]

1. The Applicant seeks leave under section 66 of the Arbitration Act 1996 to enforce the following award in the same manner as a judgment, and for judgment to be entered in its terms: [The award (tribunal, seat, date, sum)]

2. The Applicant produces the award and the arbitration agreement.

3. There is no ground on which the court should refuse leave. The Respondent has not satisfied the award.

4. The Applicant asks the court for leave to enforce, judgment in the terms of the award, and costs.

Reference: Arbitration Act 1996, s.66

Follows section 66 of the Arbitration Act 1996 on enforcement of an award as a judgment.

A reference scaffold, not legal advice. s.66 is the route for a domestic award; foreign Convention awards run through s.101 to s.103 and the New York Convention. Confirm the procedure and evidence required.

Challenge to an award: substantive jurisdiction (Arbitration Act 1996, s.67)A challenge to an English-seated award on the ground that the tribunal lacked substantive jurisdiction. Brought within 28 days, after first exhausting any available recourse to the tribunal, and only where the challenger took part in the arbitration.Common law
Your draft
CHALLENGE TO AN AWARD: SUBSTANTIVE JURISDICTION (Section 67, Arbitration Act 1996)

Applicant: [The challenging party]
Respondent: [The other party]
Award: [The award challenged (date, tribunal)]

1. The Applicant challenges the award under section 67 on the ground that the tribunal lacked substantive jurisdiction.

2. The jurisdiction objection
[Why the tribunal lacked substantive jurisdiction]

3. Recourse first exhausted
[What recourse to the tribunal was first exhausted (e.g. a ruling under s.31)]

4. The challenge is brought within 28 days of the award (or of the result of any arbitral process of appeal or review), in accordance with s.70.

5. The Applicant asks the court to confirm, vary, remit, set aside, or declare the award to be of no effect, in whole or in part, as the court thinks fit.

Reference: Arbitration Act 1996, s.67

Follows section 67 of the Arbitration Act 1996, as amended by the Arbitration Act 2025.

A reference scaffold, not legal advice. The Arbitration Act 2025 (in force 1 August 2025) refined s.67 for arbitrations commenced on or after that date: the court does not rehear evidence already before the tribunal, and new grounds or evidence are barred unless they could not have been raised earlier with reasonable diligence. Remedies now include remittal. The 28-day limit is strict.

Challenge to an award: serious irregularity (Arbitration Act 1996, s.68)A challenge to an award for serious irregularity affecting the tribunal, the proceedings or the award, where it has caused or will cause substantial injustice. The grounds are a closed statutory list and the threshold is high.Common law
Your draft
CHALLENGE TO AN AWARD: SERIOUS IRREGULARITY (Section 68, Arbitration Act 1996)

Applicant: [The challenging party]
Award: [The award challenged (date, tribunal)]

1. The Applicant challenges the award under section 68 for serious irregularity.

2. The irregularity
[The serious irregularity relied on (from the s.68(2) list)]

3. Substantial injustice
[The substantial injustice it has caused or will cause]

4. The irregularity falls within the closed list in s.68(2) and has caused or will cause substantial injustice to the Applicant. The challenge is brought within 28 days under s.70, after exhausting any available recourse.

5. The Applicant asks the court to remit the award, set it aside, or declare it of no effect, in whole or in part.

Reference: Arbitration Act 1996, s.68

Follows section 68 of the Arbitration Act 1996 on serious irregularity.

A reference scaffold, not legal advice. s.68 has a deliberately high threshold and a closed list of irregularities; it is not a route to reargue the merits. The 28-day limit is strict.

Appeal on a point of law (Arbitration Act 1996, s.69)An appeal to the court on a question of English law arising out of the award. It is available only if not excluded by the parties, and needs either the other side's agreement or the court's permission.Common law
Your draft
APPEAL ON A POINT OF LAW (Section 69, Arbitration Act 1996)

Appellant: [The appealing party]
Award: [The award appealed (date, tribunal)]

1. The Appellant appeals under section 69 on a question of law arising out of the award.

2. The question of law
[The question of law arising out of the award]

3. The case for permission
[Why the tribunal was wrong, and why the question substantially affects a party's rights] The question substantially affects the rights of a party, the tribunal was asked to determine it, and on the findings of fact the decision is open to serious doubt.

4. The Appellant asks the court for permission to appeal (unless the parties agree) and, on the appeal, to confirm, vary, remit, or set aside the award.

Reference: Arbitration Act 1996, s.69

Follows section 69 of the Arbitration Act 1996 on appeals on a point of law.

A reference scaffold, not legal advice. s.69 can be, and often is, excluded by agreement or by institutional rules (for example the LCIA and ICC Rules exclude it). It applies only to a question of English law, not to findings of fact. The 28-day limit is strict.

Construction and adjudication
Notice of Adjudication (construction, HGCRA 1996)The notice that starts a statutory construction adjudication, the fast interim-binding process available as of right on most construction contracts. It names the parties, the contract, the dispute and the redress sought.Construction and engineeringCommon law
Your draft
NOTICE OF ADJUDICATION

From: [Referring party]
To: [Responding party]

1. The Referring Party gives notice of its intention to refer a dispute to adjudication under the contract and the Housing Grants, Construction and Regeneration Act 1996.

2. The contract
[The construction contract (date, works, parties)]

3. The dispute
[The dispute referred]

4. Redress sought
[The redress sought (sum, declaration, or other relief)]

5. The Referring Party will ask the adjudicator nominating body named in the contract (or the Scheme) to appoint an adjudicator, and will serve its Referral within 7 days of this Notice.

Reference: Housing Grants, Construction and Regeneration Act 1996, Part II

Follows the adjudication framework in Part II of the 1996 Act and the Scheme for Construction Contracts.

A reference scaffold, not legal advice. The right to adjudicate at any time applies to most construction contracts under the 1996 Act; the timetable (a decision usually within 28 days of the Referral) is tight. Confirm the contract's nomination route and any exclusions.

Referral Notice (construction adjudication)The document served on the adjudicator, within 7 days of the Notice of Adjudication, that sets out the referring party's full case: the facts, the contentions, the redress, and the documents relied on.Construction and engineeringCommon law
Your draft
REFERRAL NOTICE

To: [The appointed adjudicator]
Referring Party: [Referring party]

1. This Referral is served within 7 days of the Notice of Adjudication and sets out the Referring Party's case.

2. The facts
[The facts (chronological)]

3. Contentions
[The contentions on the contract and the law]

4. Redress sought
[The redress sought]

5. The documents relied on accompany this Referral. The Referring Party asks the adjudicator to decide the dispute within the statutory period.

Reference: Scheme for Construction Contracts (England and Wales) Regulations 1998

Follows the Referral stage under the Scheme for Construction Contracts and Part II of the 1996 Act.

A reference scaffold, not legal advice. The 7-day service deadline and the adjudicator's short decision window are strict. Put the whole case in the Referral; later expansion of the dispute may fall outside the adjudicator's jurisdiction.

Letter of claim (Pre-Action Protocol for Construction and Engineering Disputes)The protocol letter of claim that precedes Technology and Construction Court proceedings: the parties, the works and contract, the claim and the breaches, the loss, and the relief, in the form the protocol expects.Construction and engineeringCommon law
Your draft
LETTER OF CLAIM (Pre-Action Protocol for Construction and Engineering Disputes)

From: [Claimant]
To: [Proposed defendant]

1. The works and contract
[The works and the contract]

2. The claim
[The claim and the breaches alleged]

3. Loss
[The loss and how it is calculated]

4. Relief
The Claimant claims: [The relief or sum claimed]

5. This letter is sent under the Pre-Action Protocol for Construction and Engineering Disputes. The Claimant invites the proposed Defendant to acknowledge within 14 days and to respond within the protocol period, and proposes a pre-action meeting.

Reference: Pre-Action Protocol for Construction and Engineering Disputes

Follows the letter of claim required by the TCC Pre-Action Protocol for Construction and Engineering Disputes.

A reference scaffold, not legal advice. The TCC protocol has its own timetable and a pre-action meeting requirement. Note the protocol exempts adjudication and certain enforcement claims. Follow the current protocol.

Statutory arbitration schemes (UK)
Reference to arbitration of a protected rent debt (Commercial Rent (Coronavirus) Act 2022)The reference that puts a ringfenced pandemic-period rent debt to a statutory arbitrator under an approved scheme. It identifies the business tenancy, the protected rent debt, and the relief from payment sought.Property and tenancyCommon lawWorked example: DAS-01375-S2S1P (XX v YY), Final Award by Agreement, 27 July 2023 (CIArb scheme)
Your draft
REFERENCE TO ARBITRATION (Commercial Rent (Coronavirus) Act 2022)

Applicant: [Applicant (landlord or tenant)]
Other party: [The other party]
Approved body: [The approved arbitration body]

1. The Applicant refers the following matter to arbitration under the Commercial Rent (Coronavirus) Act 2022.

2. The tenancy
[The business tenancy and the premises]

3. The protected rent debt
[The protected rent debt (the ringfenced sum and the period)]

4. Relief sought
[The relief from payment sought (write off, time to pay, or reduction)]

5. The Applicant confirms the debt is a protected rent debt within the Act, that the parties have not reached agreement, and asks the arbitrator to determine the relief in accordance with the Act's principles of preserving the tenant's viability while not making the landlord insolvent.

Reference: Commercial Rent (Coronavirus) Act 2022

A reference scaffold, not legal advice. The Act set a six-month window to refer for most cases; this scaffold is a structural reference for understanding the process and for any agreed or out-of-window reference. Confirm eligibility and timing under the Act.

Formal proposal on relief from a protected rent debt (Commercial Rent (Coronavirus) Act 2022)Under the Act, each party puts a formal proposal to the arbitrator setting out the relief it says is appropriate, with supporting evidence of the tenant's viability and the landlord's solvency. This is its structure.Property and tenancyCommon lawWorked example: DAS-01375-S2S1P, Final Award by Agreement, 27 July 2023 (relief by agreed instalments)
Your draft
FORMAL PROPOSAL (Commercial Rent (Coronavirus) Act 2022)

By: [The party making the proposal]

1. This is the party's formal proposal for resolving the protected rent debt, made under the Act.

2. The proposal
[The relief proposed (write off, reduction, or time to pay, with figures)]

3. Tenant viability
[The evidence of the tenant's viability relied on]

4. Landlord solvency
[The evidence of the landlord's solvency relied on]

5. The proposal is supported by the evidence referred to above and is consistent with the Act's aim of preserving or restoring the viability of the tenant's business so far as that is consistent with the landlord's solvency.

Reference: Commercial Rent (Coronavirus) Act 2022

A reference scaffold, not legal advice. The Act requires proposals to be supported by evidence and lets the arbitrator make an award where the parties' final proposals differ. Confirm the scheme's procedure and any deadlines.

Referral to the Pubs Code Adjudicator (Pubs Code arbitration)A tied-pub tenant's referral of a Pubs Code dispute to the Pubs Code Adjudicator for arbitration, including a Market Rent Only (MRO) dispute. It identifies the pub-owning business, the Code provisions in issue, and the outcome sought.Property and tenancyCommon lawWorked example: Star Pubs, Award Summary July 2025 (Pubs Code Adjudicator)
Your draft
REFERRAL FOR ARBITRATION (Pubs Code)

Tied-pub tenant (TPT): [Tied-pub tenant (TPT)]
Pub-owning business (POB): [Pub-owning business (POB)]
Premises: [The tied pub premises]

1. The TPT refers a dispute under the Pubs Code etc. Regulations 2016 to the Pubs Code Adjudicator for arbitration.

2. The Code provisions in issue
[The Pubs Code provisions said to be breached, or the MRO trigger relied on]

3. Outcome sought
[The outcome sought]

4. The TPT asks the Pubs Code Adjudicator to appoint an arbitrator and to determine the dispute, including any consequential relief available under the Code.

Reference: Pubs Code etc. Regulations 2016

A reference scaffold, not legal advice. Time limits run from the relevant Code event (for example a rent proposal or an MRO notice) and are strict. The arbitrator's powers are confined to the arbitrable provisions of the Code; money claims outside the Code fall away. The PCA appoints the arbitrator.

Final award under the Commercial Rent (Coronavirus) Act 2022 (CIArb scheme)The structure a scheme arbitrator uses to write a reasoned award resolving a protected rent debt: the statutory framework, eligibility and jurisdiction, the protected rent debt, the parties' proposals, the relief granted, and costs and publication under the Act. Modelled on real awards on the board.Property and tenancyCommon lawWorked example: a reasoned CIArb scheme Final Award (Gibbs, 23 April 2023)
Your draft
FINAL AWARD

IN THE MATTER OF THE COMMERCIAL RENT (CORONAVIRUS) ACT 2022
AND IN THE MATTER OF AN ARBITRATION UNDER THE ARBITRATION ACT 1996 (the CIArb Commercial Rent Debt Arbitration Scheme)

BETWEEN: [Applicant] (Applicant) and [Respondent] (Respondent)

A. Introduction
I, [The arbitrator and date of appointment], was appointed to determine this reference under the scheme. The premises and tenancy are: [The premises and the business tenancy]

B. Jurisdiction, seat and applicable law
This is a statutory arbitration under section 94 of the Arbitration Act 1996. The seat is England and Wales. The award is made under the Commercial Rent (Coronavirus) Act 2022 and the scheme rules.

C. Procedure
[The procedure (referral date, documents-only or hearing, submissions)]

D. Eligibility and the protected rent debt
I am satisfied the debt is a protected rent debt within the Act and that the matter is eligible for relief from payment. The protected rent debt is: [The protected rent debt (the ringfenced sum and period)]

E. The parties' proposals
[The parties' final proposals on relief]

F. The appropriate relief
Applying the Act's principles, to preserve or restore the viability of the tenant's business so far as that is consistent with the landlord's solvency, I determine the relief as follows: [The relief the arbitrator awards (write off, reduction, time to pay)]

G. Costs
Pursuant to section 19(7) of the Act, the parties bear their own legal costs; the arbitrator's and scheme fees are dealt with as set out in this award.

H. Publication
Pursuant to section 18 of the Act, an anonymised version of this award may be published.

Made at the seat (England and Wales) on the date below.
Signed: [The arbitrator and date of appointment]

Reference: Commercial Rent (Coronavirus) Act 2022

A reference scaffold modelled on real scheme awards, not legal advice. The scheme runs as a statutory arbitration (s.94 Arbitration Act 1996) applying the relief test and the eligibility, costs and publication provisions of the 2022 Act (notably ss.13 to 19). Confirm the current scheme rules.

Award by agreement under the Commercial Rent (Coronavirus) Act 2022 (CIArb scheme)Where the parties settle the protected rent debt during the arbitration, the arbitrator records the settlement as a final award by agreement, enforceable like any award. Its structure is the recitals, the agreed operative terms, and costs and publication under the Act. Modelled on the DAS-01375 award.Property and tenancyCommon lawWorked example: DAS-01375-S2S1P, Final Award by Agreement, 27 July 2023 (protected rent debt partly waived, balance by instalments)
Your draft
ARBITRATOR'S FINAL AWARD (AS AGREED BETWEEN THE PARTIES)

IN THE MATTER OF THE COMMERCIAL RENT (CORONAVIRUS) ACT 2022
AND IN THE MATTER OF THE ARBITRATION FOR RELIEF FROM PAYMENT OF A PROTECTED RENT DEBT

BETWEEN: [Applicant] (Applicant) and [Respondent] (Respondent)

WHEREAS:
(a) The parties referred the protected rent debt to arbitration under the Act.
(b) The parties have reached agreement on relief and have asked me to record it as a final award by agreement.

AND ACCORDINGLY BY AGREEMENT, I HEREBY MAKE AND PUBLISH MY FINAL AWARD THAT:

1. The protected rent debt is [The protected rent debt].

2. Agreed terms
[The agreed terms (waiver, sums payable, instalment schedule)]

3. Costs
Pursuant to section 19(7) of the Act, the parties bear their own legal costs; the arbitrator's and scheme fees are dealt with as agreed and recorded above.

4. Publication
Pursuant to section 18 of the Act, an anonymised version of this award may be published.

Made at the seat (England and Wales) on the date below.
Signed: [The arbitrator]

Reference: Commercial Rent (Coronavirus) Act 2022

A reference scaffold modelled on a real scheme award by agreement, not legal advice. Recording a settlement as an award (compare s.51 of the Arbitration Act 1996) lets it be enforced as an award. Confirm the scheme rules and the costs and publication provisions of the 2022 Act.

Pubs Code arbitration award (PCA summary structure)The structure the Pubs Code Adjudicator uses for a published award: a summary of findings, the factual background, the issues, the relevant legislation, the arbitrator's findings issue by issue, and the decision. Useful for following or writing a Pubs Code award. Modelled on the published summaries.Property and tenancyCommon lawWorked example: Pubs Code Award Summary, June 2024 (full Summary, Background, Issues, Findings, Decision)
Your draft
PUBS CODE ARBITRATION AWARD (SUMMARY)

Pub-owning business: [Pub-owning business (named)]
Parties: the tied-pub tenant (the TPT) and the pub-owning business (the POB)

1. Summary of findings
[Summary of findings (who succeeded, on what)]

2. Factual background
[Factual background (the agreement, the premises, what happened)]

3. Issues
[The issues considered]

4. The relevant legislation
The Pubs Code etc. Regulations 2016 and the Small Business, Enterprise and Employment Act 2015. [The Code provisions and statutory provisions in issue]

5. The Arbitrator's findings
[The arbitrator's findings, issue by issue]

6. Decision
[The decision and any relief]

Reference: Pubs Code etc. Regulations 2016

A reference scaffold modelled on the PCA's published award summaries, not legal advice. These summaries are anonymised: the parties appear as the TPT and the POB (though the pub-owning business is named) and the arbitrator is not named. The arbitrator's jurisdiction is confined to the arbitrable provisions of the Code, and there is no general power to award money damages.

Property and tenancy (UK)
Notice seeking possession (Housing Act 1988, s.8, as amended by the Renters' Rights Act 2025)Since 1 May 2026, with Section 21 abolished, possession of an assured tenancy in England runs solely through Section 8 on the statutory grounds in Schedule 2. The notice must use the current prescribed form and give the notice period set for the ground relied on.Property and tenancyCommon law
Your draft
NOTICE SEEKING POSSESSION (Section 8, Housing Act 1988)

Landlord: [Landlord]
Tenant(s): [Tenant(s)]
Dwelling: [The dwelling]

1. The Landlord intends to seek possession of the dwelling on the following ground(s) in Schedule 2 to the Housing Act 1988: [The ground(s) for possession relied on (Schedule 2)]

2. Particulars
[The particulars of each ground (e.g. the arrears, with dates and amounts)]

3. Notice period
Proceedings will not begin before [The earliest date proceedings may begin (the notice period for the ground)], and not later than 12 months after this notice is served.

4. This notice is given under section 8 of the Housing Act 1988. Section 21 no longer applies. If you need advice, seek it promptly from a solicitor, Citizens Advice, or a housing aid centre.

Reference: Housing Act 1988, s.8

Reflects section 8 of the Housing Act 1988 as amended by the Renters' Rights Act 2025 (in force 1 May 2026).

A reference scaffold, not legal advice. From 1 May 2026 the Renters' Rights Act 2025 abolished s.21 and possession runs through s.8 on the amended Schedule 2 grounds, using the current prescribed form (Form 3A). Notice periods vary by ground (for example four months for the sale and moving-in grounds, which cannot be used in the first 12 months); Ground 8 (serious rent arrears) is mandatory. Use the prescribed form and confirm the current grounds and periods.

Recovery and enforcement
Letter before action / claimA letter before action setting out the claim, the basis for it, the sum due and a deadline to respond, before proceedings or arbitration are commenced.
Your draft
LETTER BEFORE ACTION

From: [Sender (your client)]
To: [Recipient (the proposed defendant)]

We write on a matter that may proceed to formal dispute resolution if it is not resolved.

1. The claim
[The basis of the claim]

2. The sum due
The sum of [The sum claimed] is due and owing.

3. Response
Unless we receive your substantive response, or payment, within [Deadline to respond (e.g. 14 days)] of the date of this letter, our client reserves the right to commence proceedings or arbitration without further notice, and to rely on this letter on the question of costs.

Yours faithfully

Reference: Pre-action conduct and protocols (England and Wales)

A reference scaffold. Where a pre-action protocol applies, follow it; this letter does not replace protocol compliance.

Statutory demand for a debt (UK, Insolvency Act 1986)A formal demand for an undisputed debt. Non-payment within 21 days can found a bankruptcy petition against an individual or a winding-up petition against a company. It is not a tool for a debt that is genuinely disputed or subject to a cross-claim.Common law
Your draft
STATUTORY DEMAND

To: [Debtor (individual or company)]
From: [Creditor]

1. This is a demand for payment of a debt for which the Creditor says there is no genuine dispute and no cross-claim.

2. The debt
[The debt (amount, when it arose, the document or invoices)]

3. Consideration
The debt is in respect of: [What the debt is for (the consideration)]

4. You must pay the sum demanded, or secure or compound it to the Creditor's satisfaction, within 21 days of service.

5. If you do not, the Creditor may present a bankruptcy petition (individual) or a winding-up petition (company) without further notice. If you dispute the debt, you should contact the Creditor immediately and, for an individual debtor, may apply to set this demand aside.

Reference: Insolvency Act 1986

Reflects the statutory demand procedure under the Insolvency Act 1986 and the Insolvency Rules.

A reference scaffold, not legal advice. The prescribed forms and the set-aside procedure are strict. Serving a statutory demand for a genuinely disputed debt can be an abuse of process and attract costs. Confirm the debt is undisputed before using it.

Mediation and settlement
Mediation agreementAn agreement to mediate: the parties, the appointment of the mediator, confidentiality and without-prejudice protection, the process, and how a settlement will be recorded.
Your draft
MEDIATION AGREEMENT

Parties: [The parties to the mediation]
Mediator: [The mediator]

1. The dispute
The parties agree to mediate the following dispute: [The dispute to be mediated]

2. The mediator
The parties appoint the mediator named above, who is and will remain neutral and impartial.

3. Confidentiality
The mediation is confidential and conducted without prejudice. Nothing said or produced in the mediation may be relied on in any later proceedings, save for a concluded settlement.

4. Process and logistics
[Date, place or platform, and costs sharing]

5. Settlement
Any settlement will be binding only when reduced to writing and signed by or on behalf of the parties.

Reference: CEDR model mediation documents

Reflects the structure of standard commercial model mediation agreements.

A reference scaffold. CEDR and other bodies publish model mediation documents, linked below. Not legal advice.

Settlement agreement (Tomlin-style)A settlement recording the agreed terms and providing for the proceedings to be stayed save for the purpose of carrying the terms into effect, in the Tomlin form.
Your draft
SETTLEMENT AGREEMENT

Parties: [The settling parties]
Proceedings: [The proceedings being settled]

1. The parties have agreed to settle the above proceedings on the following terms.

2. Terms
[The agreed settlement terms]

3. Payment
[Any payment, amount and date]

4. The proceedings are stayed save for the purpose of carrying these terms into effect, with permission to apply to enforce them without the need to bring a fresh claim.

5. This agreement is in full and final settlement of all claims between the parties arising from the matters in the proceedings.

Reference: Tomlin order (England and Wales practice)

Follows the Tomlin order structure used in England and Wales to record settlement.

A reference scaffold using the Tomlin structure. Not legal advice. Confirm enforceability in the relevant jurisdiction.

Part 36 offer (CPR Part 36)A formal settlement offer under Part 36 of the Civil Procedure Rules, carrying automatic costs consequences if it is not beaten at trial. The form requirements are strict; an offer that does not comply does not attract the Part 36 consequences.Common law
Your draft
PART 36 OFFER

From: [Offeror]
To: [Offeree]
Claim: [The claim (and number, if issued)]

1. This offer is made under Part 36 of the Civil Procedure Rules and is intended to have the consequences of that Part.

2. The offer
[The offer (the sum or terms)]

3. Scope
This offer relates to: [Whether it relates to the whole claim or part, and any counterclaim]

4. Relevant period
The offer is open for acceptance for a relevant period of not less than 21 days from the date of this letter. The offer takes into account any counterclaim where stated.

5. If the offer is not accepted and the offeree fails to obtain a more advantageous outcome at trial, the offeror will rely on this offer and the costs consequences in Part 36.

Reference: Civil Procedure Rules, Part 36

Follows the form and effect of a Part 36 offer under the Civil Procedure Rules (England and Wales).

A reference scaffold, not legal advice. Part 36 is technical: the offer must state that it is made under Part 36, specify a relevant period of at least 21 days, and meet the other formal requirements, or it loses the Part 36 costs protection. Confirm the current rule.

Domestic and statutory (India)
Notice invoking arbitration (India, s.21 Arbitration and Conciliation Act)A notice invoking arbitration under section 21 of the Arbitration and Conciliation Act 1996 (India): the disputes, the arbitration clause, the proposal on the arbitrator, and the demand to refer, which marks the date of commencement.
Your draft
NOTICE INVOKING ARBITRATION (Section 21, Arbitration and Conciliation Act 1996)

From: [Sender (claimant)]
To: [Recipient (respondent)]

1. Disputes have arisen between the parties under [The arbitration clause and the agreement].

2. The disputes
[The disputes to be referred]

3. Invocation
The sender hereby invokes the arbitration agreement and refers these disputes to arbitration. By section 21 of the Act, the arbitral proceedings commence on the date this notice is received by the respondent.

4. The arbitrator
[Proposal on the appointment of the arbitrator]

5. The respondent is called upon to consent to the appointment within 30 days, failing which the sender will seek appointment in accordance with the Act.

Reference: Arbitration and Conciliation Act 1996, s.21 (India)

Follows section 21 of the Arbitration and Conciliation Act 1996 (India) on commencement.

A reference scaffold for Indian-seated arbitration. Confirm the current provisions of the Act and any amendments. Not legal advice.

Statutory demand notice (India, s.138 Negotiable Instruments Act)A demand notice on a dishonoured cheque under section 138 of the Negotiable Instruments Act 1881 (India): the cheque, its dishonour, the demand for payment within the statutory period, and the consequence of non-payment.
Your draft
DEMAND NOTICE UNDER SECTION 138, NEGOTIABLE INSTRUMENTS ACT 1881

From: [Sender / payee]
To: [Recipient / drawer]

1. You issued the following cheque in discharge of a legally enforceable debt or liability: [Cheque details (number, date, amount, bank)]

2. Dishonour
On presentation, the cheque was returned unpaid: [The dishonour (date and reason on the return memo)]

3. Demand
You are hereby called upon to pay the sum of [The amount demanded] within 15 days of receipt of this notice.

4. Consequence
If payment is not made within the said period, the sender will be constrained to initiate proceedings under section 138 of the Negotiable Instruments Act 1881, which is a punishable offence, and to pursue all available civil and criminal remedies at your risk as to costs and consequences.

Reference: Negotiable Instruments Act 1881, s.138 (India)

Follows section 138 of the Negotiable Instruments Act 1881 (India), including the 15-day statutory demand period.

A reference scaffold for an Indian s.138 demand. The 15-day period and statutory wording are strict; confirm the current provisions. Not legal advice.

Official forms and rules

Straight from the institutions.

We do not host these. Each link opens the institution's own page, the authoritative source for its rules, model clauses and forms. Always draft to the current version.

ICCParis · neutral or institutional · 8 documents
LCIALondon · common law · 7 documents
SIACSingapore · neutral or institutional · 8 documents
CASLausanne · civil law · 9 documents
ICSIDWashington DC · neutral or institutional · 9 documents
PCAThe Hague · neutral or institutional · 10 documents
FINRAUnited States · common law · 13 documents
CIArbLondon · common law · 11 documents
WIPOGeneva · neutral or institutional · 1 document
UNCITRALVienna / UN · neutral or institutional · 1 document

Institutional rules and forms are the property of the respective institutions and are linked, not reproduced. The fillable templates above are original reference scaffolds, not legal advice.