How the ICC’s new expedited and highly expedited proceedings make resolution faster and leaner

The revised ICC Rules place accelerated dispute resolution at their core, giving parties greater access to streamlined processes and more flexibility over how quickly less complex disputes are resolved.

The 2026 revisions, which came into effect on 1 June, are the most significant update to ICC proceedings in five years and come as the organisation looks to streamline and increase efficiency during the arbitration process.

The revisions include an expanded expedited procedure, which builds on an increasingly popular route for faster and more cost-controlled proceedings, and a new highly expedited arbitration mechanism, which offers an even faster process for less complex cases where speed and procedural simplicity are priorities.

Where this originates from

The ICC's Expedited Procedure Provisions (EPP) have been a proven success since their introduction in March 2017. The latest ICC statistics revealed that users are increasingly electing to implement expedited proceedings, with a notable increase to 169 cases in 2025 compared to 152 last year.

The final ICC dispute resolution statistics for 2025 (31-page / 792KB PDF) showed that between its implementation and 2025, 1,034 cases were administered under the EPP, with a record of 189 cases in 2023 alone. Out of the awards rendered under the EPP until 2024, 63% were rendered on or around the six-month deadline, with only 26 cases referred to the ICC Court with a view to withdrawal from mechanism, according to an ICC Commission on Arbitration and ADR report on the impact of EPP eight years on from its introduction (36-page / 361KB PDF). Of those, only 17 were actually removed from the expedited track.

As the ICC Commission noted, the EPP "undeniably caused a shift in the market”, prompting arbitration centres in Singapore, Dubai, Hong Kong and elsewhere to introduce their own streamlined procedures.

The 2026 revisions build on that foundation with two distinct tracks.

Updated Expedited Procedure Provisions

Under the 2021 Rules, the EPP applied by default to disputes not exceeding US$3 million where the arbitration agreement was concluded on or after 1 January 2021. An original threshold of US$2 million applied to agreements concluded between 1 March 2017 and 31 December 2020.

The 2026 Rules now add a third tier under Appendix V: for arbitration agreements concluded on or after 1 June 2026, the EPP threshold becomes US$4 million. The earlier thresholds remain in place for earlier agreements.

The core features of the existing expedited regime enforced through the new article 32 - what was the old article 30(1) - are preserved, including the default appointment of a sole arbitrator, shorter timelines, cost controls and a six-month deadline for rendering awards, from the initial case management conference.

While parties retain the right to opt-out, regardless of the threshold, the increased threshold to US$4 million means that a larger share of ICC disputes will now be subject to EPP by default, further enabling parties’ access to the efficient resolution of disputes.

The Singapore International Arbitration Centre (SIAC) and the Hong Kong International Arbitration Centre (HKIAC) also recently increased the threshold for application of their expedited processes (US$ 6,4 million in Hong Kong and US$7.4 million in Singapore) following a similar assessment of the success of expedited-type proceedings.

The ICC’s new ultra-fast arbitration track

Furthering the steps of efficient resolution of disputes, the ICC’s launch of its Highly Expedited Arbitration Procedure (HEAP) is the most significant structural innovation of the 2026 Rules. HEAP did not exist under the 2021 Rules in any form and is, for many, a welcomed addition to the ICC toolkit.

Its addition is timely and comes as the most recent Queen Mary survey (46-page/2.1MB PDF) found users felt expedited and early determination procedures for unmeritorious cases were the most effective ways of enhancing efficiency.

Article 33 of the 2026 Rules provides that, when all parties agree, the arbitration is conducted as a "Highly Expedited Arbitration" under the new HEAP provisions in Appendix VI. Unlike the EPP, HEAP is not triggered by default - it requires the express agreement of all parties. The 2026 Note to the Parties and Arbitral Tribunal on the Conduct of ICC Arbitration (48-page/2.1MB PDF) specifies, however, that the parties may agree to the HEAP regime once the arbitration has commenced. In that case, parties are expected to agree on whether and how any pending time limits should be modified.

There is also no monetary threshold: HEAP is available for any dispute regardless of value, provided the parties have agreed to it. The Note further clarifies that, because HEAP applies regardless of the amount in dispute, a change in the amount in dispute would not normally lead the ICC Court to decide that HEAP shall no longer apply.

HEAP requires the claimant to file the Request for Arbitration together with a Statement of Claim, and the respondent to file the Answer together with a Statement of Defence (and any counterclaim), both supported by evidence to the extent possible, on compressed timelines. This front-loading of the merits distinguishes HEAP from the standard EPP, where the pleading timetable is set by the tribunal at the case management conference (CMC), the parties having only exchanged the RFA and Answer.

Alongside these efficiencies, another notable aspect of HEAP is the target of making an award within three months – via a sole arbitrator – from the date of the initial CMC. This cuts the equivalent time period from the expedited procedure in half. Parties can also now elect to receive an award which is unreasoned.

The HEAP is similar and yet distinct from the SIAC streamlined procedure which was introduced in the SIAC 2025 rules. Both sets of rules differ materially in design:

• Under HEAP, the procedure applies only where all parties expressly agree, with no monetary threshold and no default trigger. The SIAC Streamlined Procedure, by contrast, applies by default where the amount in dispute does not exceed SGD$1 million and may be excluded only by written agreement.
• HEAP is built around frontloaded pleadings whereas the SIAC Streamlined Procedure imposes no equivalent frontloading obligation.
• HEAP provides that the sole arbitrator has discretion to decide the case on documents only after consulting the parties, but this is not an automatic default – and the parties must be consulted, thereby allowing the parties to properly evidence their case upfront. The SIAC streamlined procedure, however, defaults to written submissions only with no document production and no witness or expert evidence unless the tribunal directs otherwise.
• HEAP expressly prohibits joinder and consolidation while the SIAC Streamlined Procedure contains no equivalent bar.
• SIAC caps fees under the Streamlined Procedure at 50% of the maximum limits under its Schedule of Fees, whereas the ICC applies a dedicated lower fee scale to both its EPP and HEAP cases.
• Finally, under HEAP, any award must state reasons unless the parties have expressly agreed otherwise, with the Court and sole arbitrator required to make every effort to ensure the award is enforceable at law; the SIAC Streamlined Procedure requires only summary reasons, again unless the parties agree otherwise.

The latest SIAC statistics showed a significant uptake for the new streamlined procedure with 60 cases proceeding under the new regime in 2025. We watch with interest as to whether the ICC’s HEAP will be as successful given its opt-in premise, but the initial reactions from the market have been positive so far.

The 2026 revisions mark a clear shift towards speed, proportionality and user choice. By expanding the EPP and introducing HEAP, the ICC both responds to demand for efficiency and strengthens its competitive position. The EPP will now capture a larger share of disputes by default, while HEAP offers a deliberately streamlined, opt-in process where speed is paramount.

These tools also offer parties with a suite of alternatives to processes including adjudication or dispute boards, particularly in circumstances – and jurisdictions – where enforcement remains a key consideration for parties involved. The combination of quick resolution and the weight of the ICC allows for a meaningful and stringent process.

Ultimately, the success of the new offering from the ICC will depend on the uptake from parties, but together these tracks offer a more flexible and fast-paced toolkit - allowing procedure to be more precisely matched to the nature and complexity of the dispute.