I.   Introduction: The Evolving Role of Arbitral Secretaries in International Arbitration

The landscape of international arbitration has witnessed a growing reliance on arbitral secretaries to support arbitral tribunals in the efficient management of increasingly complex disputes. These individuals, often junior lawyers, perform a range of tasks delegated by the tribunal, contributing to the smooth progression of proceedings. The expanding use of arbitral secretaries has, however, generated discussions within the arbitration community regarding the appropriate scope of their functions. Concerns have been raised about potential overreach, the risk of undue influence on the tribunal’s decision-making process, and the need for transparency in their appointment and involvement. Consequently, arbitral institutions have been prompted to consider and, in some cases, refine their rules and guidance to provide clearer parameters for the role of arbitral secretaries, aiming to balance efficiency with the fundamental principles of due process and the integrity of the arbitral process. This report undertakes an analysis of the recent developments in the rules and practices of three prominent arbitral institutions – the International Chamber of Commerce (ICC), the International Centre for Settlement of Investment Disputes (ICSID), and the London Court of International Arbitration (LCIA) – concerning the functions of arbitral secretaries.

II.   The International Chamber of Commerce (ICC)

1. ICC Rules and the Guidance Note on Arbitral Secretaries: An Overview

The ICC Rules of Arbitration, while comprehensive in addressing various aspects of the arbitral process, do not contain specific articles dedicated to the appointment, duties, or remuneration of administrative secretaries assisting arbitral tribunals ¹.

Instead, the ICC’s approach to providing guidance on this matter has primarily been through its “Note to Parties and Arbitral Tribunals on the Conduct of the Arbitration under the ICC Rules” ¹. This Note serves as a practical guide for parties and tribunals involved in ICC arbitrations, reflecting the established practices of the ICC International Court of Arbitration ⁴. Over time, the ICC has updated this Note to address evolving practices and concerns within the field. Notably, a version issued on March 1, 2017, already identified the role and tasks of secretaries in arbitrations conducted under the ICC Rules ¹. The absence of explicit rules within the ICC Arbitration Rules themselves, coupled with the reliance on a non-binding Note,

suggests a deliberate choice by the ICC to maintain a degree of flexibility in addressing the use of arbitral secretaries, potentially allowing for adaptation to the specific needs of individual cases. However, this approach might be perceived as offering less legal certainty compared to institutions that have incorporated specific provisions into their formal arbitration rules.

B.  Recent Updates to the ICC Guidance Note and their Implications

The ICC has continued to refine its guidance on arbitral secretaries through subsequent updates to the Note to Parties and Arbitral Tribunals, including versions issued in 2019 and 2021 ⁴. These recent updates underscore the ICC’s commitment to enhancing transparency and efficiency in the conduct of arbitration proceedings ⁸.

Paragraphs 183 to 188 of the updated Note specifically delineate the permissible tasks that administrative secretaries may undertake under the supervision of the arbitral tribunal ⁷. These tasks include drafting correspondence and sending it on behalf of the tribunal, preparing drafts of procedural orders for the tribunal’s review, and preparing drafts of factual portions of the award, such as the background section ⁷.

Additionally, secretaries may be involved in maintaining the case file, organizing meetings and hearings, and communicating documents on behalf of the tribunal ¹. Conducting legal research to assist the arbitrators in performing their duties also falls within the scope of permissible tasks ¹. Importantly, the updated Note explicitly reiterates the fundamental principle that arbitral tribunals must not delegate any decision-making functions or other essential duties to the administrative secretary ⁷. This clear distinction between permissible auxiliary tasks and the non-delegable core responsibilities of the arbitrators aims to strike a balance between promoting efficiency through the assistance of secretaries and safeguarding the integrity of the arbitral process by ensuring that substantive decisions remain within the purview of the tribunal.

C.   Permissible and Impermissible Tasks of Arbitral Secretaries under ICC Practice

Drawing from the ICC’s Guidance Note and established practices, several examples illustrate the types of tasks commonly entrusted to administrative secretaries in ICC arbitrations ¹. These include reviewing exhibits to ensure completeness, maintaining the organization of the case file, coordinating logistical aspects such as scheduling meetings and hearings, and serving as a conduit for the tribunal’s communications with the parties ¹. Furthermore, administrative secretaries often conduct legal research on specific issues as directed by the tribunal and may prepare initial drafts of procedural orders and factual sections of the award for the arbitrators’

consideration and finalization ⁷. Conversely, there are clear limitations on the tasks that administrative secretaries can perform ¹. They are expressly prohibited from taking any substantive decisions related to the merits of the dispute or jurisdictional matters ¹. Participating in the tribunal’s deliberations on the substantive issues of the case is also outside their permissible role ¹. Critically, drafting the reasoning or the dispositive parts of the award without the strict control and personal input of the tribunal members is considered an impermissible delegation of the arbitrators’ core duties ⁷. To ensure transparency and uphold party autonomy, the ICC’s practice, as reflected in the Note, requires the arbitral tribunal to inform the parties of its intention to appoint an administrative secretary, providing them with the candidate’s curriculum vitae and a declaration of impartiality and independence. The parties are then afforded the opportunity to raise any objections to the proposed appointment ¹. This emphasis on transparency and the right of parties to object underscores the ICC’s commitment to procedural fairness in the context of utilizing arbitral secretaries.

D.  Impact on the Use of Arbitral Secretaries in ICC Arbitrations

The ICC’s updated Guidance Note on the Conduct of Arbitration has had a notable impact on the use of arbitral secretaries in ICC proceedings. By providing greater clarity on the permissible scope of their role, the Note has the potential to reduce the likelihood of challenges to arbitral awards based on allegations of improper delegation of the tribunal’s functions ⁷. This enhanced clarity contributes to the legitimacy of the arbitral process. Furthermore, by explicitly outlining the tasks that can appropriately be assigned to secretaries, the Note encourages their effective utilization in streamlining proceedings, thereby potentially saving time and reducing costs for the parties ¹. However, it is important to acknowledge that the debate surrounding the precise boundaries of permissible assistance, particularly in more complex areas such as drafting sections of the award that involve legal analysis, continues within the international arbitration community ¹². While the ICC’s guidance offers valuable direction, the inherent challenge of definitively distinguishing between permissible preparatory assistance and impermissible delegation means that some degree of interpretational flexibility remains. This ongoing discussion reflects the delicate balance that must be maintained between leveraging the efficiency gains offered by arbitral secretaries and preserving the core decision-making responsibilities of the arbitral tribunal.

III.   The International Centre for Settlement of Investment Disputes (ICSID)

1. The Role of the ICSID Secretariat and its Functions

The International Centre for Settlement of Investment Disputes (ICSID) operates with a distinct model for providing support to arbitral tribunals, centered around the significant role of its Secretariat in administering proceedings ¹⁵. The functions of the ICSID Secretariat are primarily outlined in the ICSID Convention and the ICSID Administrative and Financial Regulations ¹⁵. Within this framework, the Secretariat performs a wide range of duties that are akin to those often carried out by arbitral secretaries in other institutional settings ¹⁵. These include acting as the registrar for proceedings, which involves receiving, reviewing, and registering requests for arbitration ¹⁵. The Secretariat also plays a crucial role in assisting with the constitution of arbitral tribunals ¹⁵ and provides comprehensive support to both the parties and the tribunals throughout all stages of the case procedure ¹⁵. Logistical support, such as organizing and assisting at hearings, is another key function ¹⁵. Furthermore, the Secretariat is responsible for administering the finances associated with each case ¹⁵ and offering other administrative support as needed by the tribunals ¹⁵. Notably, a member of the ICSID Secretariat, typically a legal counsel, is designated to serve as the Secretary of the Tribunal for each case ¹⁶. In this capacity, the Secretary of the Tribunal acts on behalf of the Secretary-General and performs functions delegated to them by the Regulations, the applicable Rules, or the ICSID Convention ¹⁷. A core objective of the Secretary of the Tribunal is to assist the parties and the tribunal in ensuring that the proceeding is conducted in an expeditious and cost-effective manner ¹⁷. The Secretariat is also responsible for the routing of all documents in the proceeding ²¹. This embedded support system within the ICSID institution, where a designated Secretary of the Tribunal from the Secretariat staff provides ongoing assistance, distinguishes it from the ICC and LCIA models, where the tribunal typically appoints an external arbitral secretary.

B.  Analysis of the 2022 ICSID Rule Amendments Relevant to Secretarial Functions

In 2022, ICSID implemented a comprehensive set of amendments to its rules, aimed at modernizing procedures, enhancing efficiency and transparency, and improving disclosure requirements ¹⁸. While these amendments brought about significant changes across various aspects of the ICSID arbitration process, the term “arbitral secretary” is not explicitly introduced within the revised rules ²¹. However, the 2022 version of Regulation 28 of the Administrative and Financial Regulations remains highly relevant to the functions performed by a Secretary of the Tribunal ¹⁷. This

regulation stipulates that the Secretary for each Tribunal, Commission, and Committee is appointed by the Secretary-General and is drawn from the Secretariat staff ¹⁷. The Secretary acts as a representative of the Secretary-General, performing delegated

functions, and plays a crucial role in assisting both the parties and the Tribunal in the efficient and cost-effective conduct of the proceedings ¹⁷. Additionally, Rule 3 of the Arbitration Rules (2022 Version) introduces a new general duty obligating both the tribunal and the disputing parties to act in good faith and in an expeditious and

cost-effective manner ²¹. This overarching principle may indirectly influence how the Secretariat supports the tribunal in achieving these objectives. Furthermore, Rule 4 of the Arbitration Rules (2022 Version) mandates electronic filing as the default method for document submissions ²¹. This shift towards digital communication likely impacts the administrative tasks handled by the Secretariat in managing case files and exchanging information. Although the 2022 ICSID rule amendments do not introduce a new concept of an externally appointed “arbitral secretary,” they do refine the established role and responsibilities of the ICSID Secretariat, particularly the Secretary of the Tribunal, with a clear emphasis on promoting efficiency and

cost-effectiveness throughout the arbitration process. This aligns with the underlying objectives of utilizing arbitral secretaries in other institutional contexts.

C.   Distinction Between ICSID Secretariat Functions and Arbitral Secretary Roles (as understood in ICC/LCIA)

A key distinction exists between the support provided by the ICSID Secretariat and the role of arbitral secretaries as typically understood in the context of institutions like the ICC and LCIA. In ICSID, the support functions are institutionally embedded, with the Secretariat providing comprehensive administrative and procedural assistance, including the assignment of a Secretary of the Tribunal from its own staff ¹⁵. This contrasts with the ICC and LCIA, where it is common for the arbitral tribunal itself to appoint an external individual, often referred to as an arbitral or tribunal secretary, to assist with the proceedings ¹. While the scope of functions may overlap, encompassing administrative support and procedural guidance, the ICSID Secretary of the Tribunal operates as an integral part of the institution and within its established regulatory framework. In the ICC and LCIA models, parties typically have a more direct involvement in the appointment process of an external arbitral secretary, including the right to object to the proposed candidate, a level of direct influence that is less pronounced in the ICSID system, although parties certainly interact closely with the Secretariat throughout the proceedings ¹. This fundamental difference in the source and nature of support suggests that while the objectives of efficiency and effective case management are shared, the mechanisms for achieving them and the level of party involvement may vary significantly between these institutions.

D.  Impact on the Use of Arbitral Secretaries (in the broader sense) in ICSID

Arbitrations

The dedicated support provided by the ICSID Secretariat plays a crucial role in ensuring the efficiency and leveraging the institutional expertise inherent in ICSID’s administration of investment arbitrations. This institutional approach fosters consistency in handling administrative and procedural aspects across a diverse caseload. The costs associated with the Secretariat’s comprehensive support are integrated into ICSID’s overall fee structure. Notably, ICSID has not recently introduced refinements to its rules specifically concerning the appointment and functions of external arbitral secretaries. This is primarily because their established support model relies on the internal resources and expertise of the ICSID Secretariat, with the Secretary of the Tribunal fulfilling many of the functions that an external arbitral secretary might undertake in proceedings under other institutional rules.

Therefore, while ICSID does not utilize external arbitral secretaries in the same manner as the ICC or LCIA, the robust support provided by its Secretariat effectively addresses the need for administrative and procedural assistance to arbitral tribunals.

IV.  The London Court of International Arbitration (LCIA)

1. Article 14A of the LCIA Arbitration Rules 2020: Explicit Provisions on Tribunal Secretaries

The 2020 revision of the LCIA Arbitration Rules marked a significant development with the introduction of Article 14A, which specifically addresses the role of tribunal secretaries ¹⁰. This addition formalizes and expands upon the previous guidance provided in the 2017 LCIA Guidance Notes for Arbitrators ¹⁰. While the full text of Article 14A is not entirely contained within the provided snippets, the commentary surrounding its introduction offers substantial detail on its key provisions. Article 14A mandates that the appointment of a tribunal secretary requires the prior written approval of all parties involved in the arbitration ¹⁰. Furthermore, the tribunal is obligated to consult with the parties and seek their agreement on the specific tasks that the secretary will be authorized to perform ¹⁰. A critical aspect of Article 14A is the explicit prohibition against the delegation of any decision-making function of the arbitral tribunal to the secretary ¹⁰. To ensure impartiality and independence, the proposed secretary must provide a written declaration confirming their independence and impartiality ¹⁰. This obligation is ongoing, with the secretary having a continuing duty to disclose any circumstances that might give rise to justifiable doubts about their independence or impartiality ¹⁰. The confidentiality obligations outlined in Article 30 of the LCIA Rules are explicitly extended to apply equally to tribunal secretaries ³⁹. Regarding remuneration, the LCIA’s Schedule of Costs provides guidance on

reasonable hourly rates for tribunal secretaries, and the parties must agree to the secretary’s proposed hourly rate and any anticipated expenses ¹¹. The introduction of Article 14A by the LCIA represents a significant step towards establishing a clear legal framework for the appointment, duties, and limitations of tribunal secretaries within its arbitration rules.

B.  Approval, Appointment, Role, and Limitations of Tribunal Secretaries under LCIA Rules

The process for approving and appointing a tribunal secretary under the LCIA Rules 2020, as detailed in Article 14A, emphasizes the necessity of obtaining the explicit consent of all parties ¹⁰. To facilitate this approval, the tribunal is expected to provide the parties with relevant information about the proposed secretary, typically including their curriculum vitae and a declaration of independence and impartiality ¹⁰. The role of the tribunal secretary and the specific tasks they may perform are subject to agreement between the tribunal and the parties ¹⁰. While the LCIA does not provide an exhaustive list of permissible tasks within the rules themselves, commentary suggests that these can range from administrative duties such as organizing documents and proofreading to more substantive assistance like summarizing submissions, reviewing legal authorities, and preparing initial drafts of awards ¹¹. However, it is crucial to note that any involvement in more substantive tasks typically requires explicit agreement from the parties ¹¹. The LCIA Rules 2020 impose strict limitations on the functions of tribunal secretaries, unequivocally stating that they cannot be delegated any

decision-making authority that rests with the arbitral tribunal ¹⁰. Furthermore, the ongoing duty of independence and impartiality ensures that the secretary’s assistance is provided without any potential conflicts of interest ¹⁰. The LCIA’s approach in Article 14A reflects a careful balancing act, aiming to harness the potential efficiency gains offered by tribunal secretaries while implementing robust safeguards to protect the fundamental principles of due process and the integrity of the arbitral proceedings.

C.   Impact of Article 14A on the Use of Arbitral Secretaries in LCIA Arbitrations

The inclusion of Article 14A in the LCIA Arbitration Rules 2020 has several significant implications for the use of arbitral secretaries in LCIA proceedings. The explicit rules enhance transparency surrounding the secretary’s role and increase the accountability of arbitral tribunals in their utilization ¹⁰. Parties now benefit from a clearer legal framework governing the involvement of tribunal secretaries, which is likely to reduce the potential for disputes and challenges related to their functions ¹⁰. The requirement for explicit party approval reinforces the principle of party autonomy

within the arbitral process, ensuring that parties have a say in who assists the tribunal

10. ¹⁰. When utilized appropriately and with the informed consent of all parties, tribunal secretaries can contribute to a more efficient and cost-effective arbitration process by undertaking administrative and preparatory tasks under the tribunal’s supervision
11. ¹¹. Article 14A provides a solid foundation for the appropriate and transparent use of tribunal secretaries in LCIA arbitrations, balancing efficiency with the fundamental requirements of due process and party autonomy.

1. Comparative Analysis and Synthesis
   1. Comparative Table of Rules and Guidance on Arbitral Secretaries

1. Trends in the Regulation of Arbitral Secretaries by Major Institutions

An examination of the approaches taken by the ICC, ICSID, and LCIA reveals a discernible trend towards greater recognition and formalization of the role of arbitral secretaries in international arbitration. The LCIA’s introduction of Article 14A in its 2020 Rules exemplifies this trend, moving from informal guidance to specific, binding rules. Across these institutions, there is a common emphasis on transparency, ensuring that parties are informed about the appointment and involvement of arbitral secretaries. Furthermore, the need to involve parties in the process, particularly in agreeing to the secretary’s tasks and, in the case of the LCIA, their appointment, highlights a commitment to party autonomy. A consistent principle underlying the regulations and guidance is the unequivocal prohibition on the delegation of core decision-making functions from the arbitral tribunal to the secretary. This reflects a universal understanding of the fundamental responsibility of the appointed arbitrators to decide the dispute. Ultimately, these refinements aim to address concerns about both efficiency and due process, seeking to harness the benefits of secretarial assistance while safeguarding the fairness and integrity of the arbitral proceedings.

C.   Implications for Efficiency, Transparency, and Due Process

The clearer rules and guidance on the functions of arbitral secretaries have significant implications for efficiency, transparency, and due process in international arbitration. When arbitral secretaries are utilized appropriately, under the clear parameters set forth by institutional rules and with the consent of the parties, they can substantially enhance the efficiency of arbitration proceedings by managing administrative burdens and assisting with procedural and factual matters. The emphasis on transparency, particularly the requirement for disclosure of the secretary’s identity, qualifications, and any potential conflicts of interest, as well as the need for party

approval and agreement on tasks, promotes greater trust and reduces the risk of challenges to awards based on the secretary’s involvement. Crucially, the consistent prohibition against delegating decision-making functions to arbitral secretaries is vital for safeguarding due process. It ensures that the parties’ right to have their case heard and decided by the duly appointed arbitral tribunal is upheld, preventing any undue influence or usurpation of the tribunal’s core responsibilities by the secretary. The evolution of these rules and guidelines reflects a collective effort within the international arbitration community to optimize the process while adhering to fundamental principles of fairness and procedural integrity.

VI.   Conclusion: Summary of Rule Refinements and their Overall Impact on the Use of Arbitral Secretaries

In conclusion, this analysis reveals that while the ICC and LCIA have recently refined their approaches to the functions of arbitral secretaries, ICSID’s model relies primarily on the internal support provided by its Secretariat. The ICC has continued to provide guidance through its updated Note to Parties and Arbitral Tribunals, clarifying permissible tasks and reiterating the prohibition on delegating decision-making. The LCIA has taken a more formal step by introducing Article 14A into its 2020 Arbitration Rules, establishing specific requirements for the approval, appointment, role, and limitations of tribunal secretaries. ICSID, with its institutionalized support system, has focused its recent rule amendments on broader aspects of efficiency and transparency, with the Secretariat continuing to play a central role in assisting tribunals.

Overall, there is a clear trend among major arbitral institutions towards providing greater clarity and regulation regarding the role of arbitral secretaries in international arbitration. This trend reflects a recognition of the increasing prevalence of arbitral secretaries and a desire to balance the benefits of their assistance in enhancing efficiency with the fundamental principles of transparency, party autonomy, and due process. The refinements made by the ICC and, particularly, the LCIA, are likely to have a significant impact on the practical use of arbitral secretaries, emphasizing the importance of adherence to these rules and guidance to ensure that arbitration proceedings are conducted in an efficient, transparent, and fair manner. Ongoing discussions within the arbitration community suggest that this area will continue to evolve as institutions and practitioners seek to optimize the use of arbitral secretaries while upholding the integrity of the arbitral process.

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