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Drafting Arbitration Clauses to International Standards

In FDI contracting practice in Vietnam, the arbitration clause usually occupies a few lines at the end of the contract — and those are often the most carelessly drafted lines. The damage surfaces only when a dispute erupts: the institution's name is wrong, the wording says "may" instead of "shall," no procedural rules are specified. At that point, sloppy drafting of an arbitration clause does more than waste years arguing over jurisdiction — in the worst case, the entire arbitration agreement is held incapable of being performed, pushing the dispute back into exactly the forum the parties wanted to avoid: the courts. This guide covers the technique of drafting arbitration clauses to international standards: the seven mandatory components, three model clauses from VIAC, ICC and SIAC, and seven common mistakes to avoid.

Table of Contents

1. What Is an Arbitration Clause? Who Needs One?

An arbitration agreement is an agreement between parties to resolve by arbitration disputes that may arise or have already arisen (Article 3(2), Law on Commercial Arbitration 2010). An arbitration clause is one form of arbitration agreement — written into the contract to govern future disputes. The other form is a separate submission agreement signed after a dispute has arisen; in practice, once parties are in conflict, they almost never agree on a dispute-resolution mechanism — which is why the clause in the contract is the real line of defense.

Who needs a properly drafted arbitration clause?

  • Foreign investors contracting in Vietnam: joint ventures, M&A share deals, EPC contracts, distribution, agency, loan and leasing agreements — any significant cross-border transaction.
  • Vietnamese companies contracting with foreign counterparties: the clause balances the playing field — it keeps you out of foreign courts operating under unfamiliar law.
  • Contract drafters and negotiators: general counsel, in-house lawyers, external advisors — because one sloppy clause can collapse the client's entire dispute-resolution strategy.

Equally important are the cases where arbitration is unavailable or restricted from the outset:

  • Disputes outside arbitral jurisdiction under Article 2 of the Law on Commercial Arbitration 2010 — arbitration covers disputes arising from commercial activities, disputes where at least one party engages in commercial activity, and other disputes the law submits to arbitration.
  • Consumer contracts: Article 17 of the Law on Commercial Arbitration 2010 preserves the consumer's right to choose arbitration or the courts, even where the supplier's standard terms already contain an arbitration clause. A supplier may only commence arbitration with the consumer's consent — copying a "hard" clause into retail standard terms is a mistake (see 5.7).

Drafting an arbitration clause for a Vietnam-related contract engages three layers of law — domestic, treaty, and the chosen institution's rules:

Vietnamese law. The Law on Commercial Arbitration No. 54/2010/QH12 (effective 1 July 2011, in force) is the foundation, with key provisions for drafters:

  • Article 2 — arbitral jurisdiction: which disputes may go to arbitration.
  • Article 6 — where parties have an arbitration agreement and one party sues in court, the court must decline jurisdiction, unless the agreement is invalid or incapable of being performed. This "negative effect" — excluding the courts — is what makes the clause valuable.
  • Article 16 — form of arbitration agreements: must be in writing, as a contractual clause or a separate agreement.
  • Article 17 — consumer choice (the key exception).
  • Article 18 — six grounds on which an arbitration agreement is invalid (dispute outside jurisdiction; signatory lacking authority or civil capacity; defective form; fraud, threat or coercion; violation of legal prohibitions).
  • Article 19 — separability: the arbitration agreement is fully independent of the contract — amendment, extension, cancellation, invalidity or unenforceability of the contract does not affect it.
  • The law further recognizes the competence-competence principle: before examining the merits, the tribunal must satisfy itself of the arbitration agreement's validity and its own jurisdiction.

Treaty law. The 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards — Vietnam acceded under Decision 453/QD-CTN dated 28 July 1995, with three reservations: (1) the Convention applies only to awards rendered in the territory of a member state (reciprocity for non-members); (2) only to disputes arising from commercial legal relationships; (3) interpretation before Vietnamese courts follows the Constitution and laws of Vietnam. Two provisions matter most to drafters: Article II (arbitration agreements must be in writing — the reason Vietnam and most states mandate written form) and Article V (grounds for refusing recognition and enforcement — including an invalid arbitration agreement under the parties' chosen law). In short: a sloppy clause endangers not just the proceedings but the award itself, at the enforcement stage in 170+ Convention states. Procedures for recognizing foreign arbitral awards in Vietnam are set out in the Civil Procedure Code 2015 (in force).

Institutional rules. Choosing an arbitral institution and incorporating its rules means the entire proceedings run under those rules. The three most-used rule sets for Vietnam-related contracts today: the VIAC Rules of Arbitration 2026 (effective 1 July 2026), the ICC Arbitration Rules 2021, and the SIAC Rules 2025. Each institution publishes a model arbitration clause — the safest starting point for any drafter (see section 4).

3. Seven Components of an International-Standard Arbitration Clause

An international-standard clause need not be long — but it must answer seven questions. Every unanswered question leaves the parties' future dispute to someone else's interpretation.

3.1. Clear, Mandatory Intent

This is the most important component — and where Vietnamese-drafted clauses most often fail. The intent to arbitrate must be expressed in mandatory, not optional, language.

  • Right: "Any dispute… shall be finally resolved by arbitration…"
  • Wrong: "The parties may refer disputes to arbitration…"

Why? Optional language ("may," "có thể") opens a threshold battle: one party commences arbitration, the other argues the clause merely permits — not requires — arbitration, and elects the courts. The tribunal then burns time (and the parties' money) interpreting intent, with an unpredictable outcome. The golden rule: if you have decided on arbitration, write it as an obligation, not a suggestion.

3.2. Correct Institution and Rules

Two models exist: institutional arbitration (administered by an arbitral center under its rules) and ad hoc arbitration (parties design their own procedure or adopt rules such as the UNCITRAL Arbitration Rules without an institution). For most FDI contracts, institutional arbitration is far safer: administrative support, a default appointing mechanism when parties deadlock, and settled interpretive practice.

When choosing institutional arbitration, the clause must state the institution's exact official name and the correct rules. It sounds simple, yet practice is full of faulty variants: outdated names tied to a chamber of commerce, "ICC Court of Arbitration in Paris" instead of the International Chamber of Commerce, "Singapore Arbitration Centre" instead of the Singapore International Arbitration Centre (SIAC). A misnamed institution is the shortest path to a pathological clause (see 5.1).

On rules, the international-standard formulation refers to the rules "for the time being in force" — as the SIAC model does. This avoids freezing the clause into an outdated rule version when a dispute arises years after signing.

3.3. Sufficiently Broad Scope

The clause must capture every conceivable dispute — not only performance disputes but also disputes over the contract's existence, validity, interpretation and termination. The standard international formula, used by ICC, SIAC and LCIA alike:

"Any dispute arising out of or in connection with this contract, including any question regarding its existence, validity or termination…"

"Arising out of or in connection with" is far broader than "arising out of" alone. The italicized tail matters especially in Vietnam: thanks to separability under Article 19 of the Law on Commercial Arbitration 2010, disputes over the contract's validity remain arbitrable — but only if the clause is drafted broadly enough to cover them. A clause limited to "disputes concerning performance" invites the argument that validity disputes fall outside scope.

3.4. Number of Arbitrators

Always specify: one or three (an odd number is a procedural necessity). There is no universally right answer:

  • Sole arbitrator: faster, cheaper — suits mid-value disputes without extreme complexity.
  • Three arbitrators: each party appoints one; the two (or the institution) choose the presiding arbitrator — suits high-value, complex disputes, or where parties want their voice on the tribunal.

The danger is saying nothing. When the clause is silent, the institution or competent authority decides under the rules — the parties surrender self-determination on day one. For high-value FDI contracts, three arbitrators is the international norm; for ordinary commercial contracts, a sole arbitrator with an expedited procedure is the efficient choice.

3.5. Seat of Arbitration — Not the Hearing Venue

This is the most misunderstood concept. The seat is not where hearings happen (the venue) — it is the juridical home of the arbitration, determining two critical matters: (1) which arbitration procedural law governs (the lex arbitri); and (2) which courts supervise and support (appointing arbitrators on deadlock, granting interim relief, hearing set-aside applications).

Example: parties may seat an arbitration in Singapore but hold hearings in Ho Chi Minh City for convenience — the award remains a "Singapore" award subject to Singapore court supervision. Conversely, a clause that says "arbitration at VIAC, hearings in Hanoi" without fixing a seat invites needless argument.

Common seat choices for Vietnam-related contracts:

  • Vietnam (Hanoi/Ho Chi Minh City): convenient where assets and enforcement concentrate in Vietnam; tribunals know Vietnamese law; lower cost.
  • Singapore: neutral, with court support for arbitration among Asia's best; a New York Convention member — the balanced regional choice.
  • Hong Kong, Paris, London, Geneva: traditional seats for high-value multi-jurisdictional deals, depending on the parties' profile and nationalities.

Caution: the more "foreign" the seat relative to the enforcement forum, the higher the risk and cost — this decision deserves counsel's input, not mechanical copying from a foreign template.

3.6. Language of Proceedings

State the arbitral language expressly: Vietnamese, English, Chinese, or bilingual. For FDI contracts in Vietnam, English is common where foreign arbitrators sit; but weigh the reality — all domestic evidence, witnesses and experts operate in Vietnamese, so an English-language arbitration carries significant translation and interpretation costs.

One VIAC-specific note: agreeing on a non-Vietnamese arbitral language (and a non-Vietnamese governing law) is guided by VIAC toward disputes with a foreign element, or where at least one party is a foreign-invested enterprise. For purely domestic disputes between Vietnamese companies, do not reflexively copy bilingual FDI wording.

3.7. Governing Law — Three Layers to Distinguish

Professional drafters separate three layers of law in a complete arbitration clause:

  1. Substantive governing law: the law deciding right and wrong on the merits. E.g., "This contract is governed by the laws of Vietnam."
  2. Lex arbitri: determined by the seat — covers court support, set-aside grounds. This is why the seat decision (3.5) matters more than most realize.
  3. Law governing the arbitration agreement itself: in principle, a separate choice independent of both layers above. Safe practice in Vietnam-related FDI contracts is to state expressly which law governs the arbitration clause (usually aligned with the contract's governing law), rather than leaving it for the tribunal or a court to construe later — interpretive approaches differ across legal systems.

All three layers belong in the contract expressly. Never let the arbitration clause "drift" under a country's law the parties never intended to choose.

4. Three International Model Clauses

The number-one rule of the international arbitration bar: start from the model clause published by the institution itself, then fill in the blanks for your transaction — instead of reinventing it. The three models below are quoted verbatim, with guidance for Vietnam-related contracts.

4.1. VIAC Model (2026 Rules)

The Vietnam International Arbitration Centre publishes its model in Appendix III of the VIAC 2026 Rules of Arbitration:

Vietnamese:

"Mọi tranh chấp phát sinh từ hoặc liên quan đến hợp đồng này sẽ được giải quyết bằng trọng tài tại Trung tâm Trọng tài Quốc tế Việt Nam (VIAC) theo Quy tắc tố tụng trọng tài của VIAC."

English (VIAC's official text):

"Any dispute arising out of or in relation with this contract shall be resolved by arbitration at the Vietnam International Arbitration Centre (VIAC) in accordance with its Rules of Arbitration"

VIAC recommends adding:

(a) Number of arbitrators [one or three](b) Place of arbitration [city and/or country](c) Governing law of the contract […] *
(d) Language of the arbitration […] **

VIAC's notes: (c) applies only to disputes with a foreign element; (d) applies only to disputes with a foreign element or where at least one party is a foreign-invested enterprise.

Usage guidance: the VIAC model is short and minimally sufficient, but a proper clause should not stop at the sample sentence. For FDI contracts, complete all four additions (a)–(d): arbitrator numbers suited to the expected dispute value; the seat (see 3.5); governing law; arbitral language. VIAC also publishes a separate model for expedited procedure — worth considering when parties want fast, streamlined proceedings for lower-value disputes.

4.2. ICC Model (ICC Arbitration Rules 2021)

The International Chamber of Commerce (Paris) recommends its famously simple standard clause:

"All disputes arising out of or in connection with the present contract shall be finally settled under the Rules of Arbitration of the International Chamber of Commerce by one or more arbitrators appointed in accordance with the said Rules."

The ICC notes parties may adapt the clause by adding: the number of arbitrators (one or three), the seat of arbitration, the language, and the law governing the merits of the contract.

Usage guidance: the point to remember with the ICC model — under Article 6(2) of the 2021 ICC Rules, agreeing to the ICC Rules means the arbitration is administered by the ICC Court; there is no such thing as "ICC Rules ad hoc." Never write "arbitration under the ICC Rules but not administered by the ICC" — a self-contradiction. ICC suits high-value multi-jurisdictional transactions needing global prestige and the ICC's distinctive draft-award scrutiny — at typically higher cost than regional centers.

4.3. SIAC Model (SIAC Rules 2025)

The Singapore International Arbitration Centre recommends a model that builds all key elements in from the start:

"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 the Singapore International Arbitration Centre ("SIAC") in accordance with the Arbitration Rules of the Singapore International Arbitration Centre ("SIAC Rules") for the time being in force, which rules are deemed to be incorporated by reference in this clause.

The seat of the arbitration shall be [Singapore].
The Tribunal shall consist of _________________ arbitrator(s).
The language of the arbitration shall be ________________."

With SIAC's recommended governing-law clause drafted separately:

"This contract is governed by the laws of _________________."

Usage guidance: the SIAC model teaches two lessons even if you choose another institution. First, "for the time being in force" — never freeze the clause into an outdated rule version. Second, seat, tribunal size, language and governing law appear as standalone lines the drafter must complete — exactly the discipline of the seven components in section 3. SIAC's notes: state an odd number of arbitrators (one or three); the seat need not be Singapore — parties may choose another city or country while retaining SIAC administration.

Bottom line: whichever of VIAC, ICC or SIAC you choose, the formula is institution's model + all seven components completed. Never "innovate" by pairing one institution's name with another's rules (e.g., "arbitration at VIAC under the ICC Rules") — a guaranteed jurisdictional dispute.

5. Seven Fatal Mistakes That Kill Arbitration Clauses

The international arbitration world calls sloppily drafted clauses pathological clauses — they do not die at signing; they fall ill exactly when the parties need them most. Seven pathologies recur in Vietnam-related contracts.

5.1. Misnamed or Vague Institution

  • Symptoms: "All disputes shall be resolved by international arbitration in Vietnam"; "VIAC arbitration under the UNCITRAL Rules"; homemade abbreviations no one interprets the same way.
  • Consequences: the tribunal (or a court, in a jurisdictional fight) cannot identify which institution the parties meant → the clause risks being held incapable of being performed, and under Article 6 of the Law on Commercial Arbitration 2010, the court will hear the case instead of declining it.
  • Prevention: use the institution's exact current official name plus the correct rules; re-check the institution's official website before signing (names change over time).

5.2. Optional Instead of Mandatory Language

  • Symptoms: "The parties may agree to refer disputes to arbitration"; "disputes may be resolved by arbitration or the courts."
  • Consequences: when conflict erupts, the party preferring litigation argues the clause merely permits arbitration; the pro-arbitration party spends time and money proving mandatory intent — the outcome turns entirely on case-by-case interpretation.
  • Prevention: use mandatory language — "shall be finally resolved." If parties genuinely want a choice, design an explicit selection mechanism (who chooses, when, in what form) — never leave it hanging.

5.3. Arbitration and Courts Side by Side, No Selection Mechanism

  • Symptoms: "Disputes shall be resolved by Arbitration Centre X or the People's Court of Ho Chi Minh City."
  • Consequences: the most dangerous pathological form — two mutually exclusive mechanisms both "switched on." The first party to file in court invokes the clause to justify it; the other invokes the same clause to object. The result is prolonged warfare over where to litigate before the merits are ever touched.
  • Prevention: one contract, one final mechanism. If you want stages (negotiation → mediation → arbitration), draft a multi-tier clause with a clear sequence and deadline for each tier (see 5.4), ending in arbitration.

5.4. Multi-Tier Clauses Without Time Limits

  • Symptoms: "Parties shall negotiate in good faith; failing which, mediation; failing which, arbitration" — with no negotiation period, no mediation venue, no definition of "failure."
  • Consequences: the delaying party argues the preconditions (negotiation/mediation) are unfulfilled, so the tribunal lacks jurisdiction — the tribunal must decide the jurisdictional objection before the merits, at significant cost.
  • Prevention: each tier needs a specific deadline ("within 30 days of written notice of dispute"), a defined endpoint ("if no written settlement is reached by expiry"), and automatic escalation. Use multi-tier clauses only where parties genuinely need to preserve a long-term relationship.

5.5. Asymmetric Clauses — Only One Party May Choose Arbitration

  • Symptoms: "Party A may elect arbitration or litigation; Party B may only commence arbitration" — typically in contracts drafted by the stronger party (banks, project owners).
  • Consequences: the validity of unilateral/asymmetric option clauses is globally debated — some systems uphold them, others strike them down as violating equality of arms. In Vietnam, no implementing guidance or clear case law exists, so the outcome in a real dispute is unpredictable.
  • Prevention: for FDI contracts in Vietnam, avoid asymmetric clauses. If the stronger party wants leverage, use lawful tools instead (performance security, payment terms, indemnities) rather than gambling on a clause of uncertain validity. Where such a clause already exists, have counsel assess the risk before a dispute arises.

5.6. Leaving Seat, Language, Law and Numbers Blank

  • Symptoms: the clause reads "arbitration at VIAC under the VIAC Rules" and stops — no seat, no language, no governing law, no tribunal size.
  • Consequences: the clause remains minimally valid, but every missing element will be decided for the parties by the institution, the tribunal or a court — surrendering self-determination precisely on points that drive cost and outcome (language determines translation costs; seat determines the supervisory court).
  • Prevention: apply the seven-component checklist in section 3 — complete it before signing. Four or five extra lines today can save hundreds of hours of argument later.

5.7. Copying a "Hard" B2B Clause into Consumer Contracts

  • Symptoms: standard terms drafted by the business (telecoms, e-commerce, consumer services) providing "all disputes shall be resolved by arbitration at…" with no consumer choice mechanism.
  • Consequences: under Article 17 of the Law on Commercial Arbitration 2010, the consumer retains the right to choose arbitration or the courts regardless of the clause; the business may only commence arbitration with the consumer's consent. The "hard" clause therefore fails its purpose of excluding the courts.
  • Prevention: for consumer contracts, design the clause around the consumer's statutory choice from the outset, instead of copying B2B templates.

6. Arbitration Clause Drafting Checklist

Before signing, run through these ten checkpoints — each unchecked item is a risk waiting to detonate:

  • [ ] Mandatory language: "shall be finally resolved" — no "may" survives in the clause.
  • [ ] Correct institution name: the exact current official name (VIAC / International Chamber of Commerce / Singapore International Arbitration Centre) — verified on the institution's official website.
  • [ ] Correct, "open" rules: the right rule set, preferably with "for the time being in force" formulation.
  • [ ] Broad scope: "arising out of or in connection with" plus coverage of existence, validity and termination disputes.
  • [ ] Tribunal size: one or three (odd number) expressly stated — never blank.
  • [ ] Seat of arbitration: city/country fixed — distinguished from the hearing venue.
  • [ ] Language: one express language (or a bilingual mechanism with priority on conflict).
  • [ ] Three layers of governing law: substantive law of the contract; seat (fixing the lex arbitri); law governing the arbitration agreement itself — all express.
  • [ ] No contradictions: a single final mechanism across the whole contract; multi-tier clauses carry deadlines and escalation triggers per tier.
  • [ ] Fit for the counterparty: no "hard" B2B clause copied into consumer contracts (Article 17, Law on Commercial Arbitration 2010).

7. Frequently Asked Questions

7.1. Must an arbitration clause be in writing?

Yes — mandatory. Article 16 of the Law on Commercial Arbitration 2010 requires arbitration agreements to be in writing, as a contractual clause or a separate agreement. Oral agreements are unenforceable.

"Writing" is interpreted broadly, however. The following all qualify: exchanges by telegram, fax, telex or email; written exchanges between the parties; minutes recorded by a lawyer or notary at the parties' request; incorporation by reference to a document containing an arbitration agreement (contract, company charter, etc.); and even one party's assertion of an arbitration agreement in its statement of claim or defense that the other party does not deny. Basis: Article 16, Law on Commercial Arbitration 2010; Article II, New York Convention 1958. Next step: review negotiation email threads — if they clearly express arbitral intent, preserve them as part of the agreement file.

7.2. If the main contract is invalid, does the arbitration clause survive?

Yes. Article 19 of the Law on Commercial Arbitration 2010 provides that the arbitration agreement is fully independent of the contract: amendment, extension, cancellation, invalidity or unenforceability of the contract does not affect the arbitration agreement. This is the separability principle recognized worldwide.

Practical consequence: disputes over the contract's validity remain arbitrable — provided the clause is drafted broadly enough to cover them (see 3.3). Next step: always include "including any question regarding its existence, validity or termination" in the clause's scope.

7.3. What if the clause names the institution incorrectly?

It depends on severity. If the parties' intent to submit to a specific institution remains identifiable (full name slightly off but no real confusion), a tribunal or court may construe the clause to save it. But a generic reference ("international arbitration in Vietnam") identifying no institution risks being held incapable of being performed — and under Article 6 of the Law on Commercial Arbitration 2010, the court will then hear the case.

The only prevention: the correct official name plus the correct rules, at the drafting stage (see 3.2 and 5.1). If the contract is already signed and an error is found, the parties should sign a corrective addendum immediately — not wait for a dispute to "cure" it.

7.4. Can a clause provide for both arbitration and litigation?

Parties are generally free to agree, but placing two mutually exclusive mechanisms side by side without a clear selection procedure is one of the most dangerous errors (see 5.3). A clause reading "disputes shall be resolved by arbitration or the People's Court of Ho Chi Minh City" invites a jurisdictional battle from day one.

To combine methods, draft a proper multi-tier clause: negotiation (specific deadline) → mediation (institution and venue specified) → arbitration as the final step. Each tier needs an express deadline and escalation trigger (see 5.4).

7.5. Are foreign arbitral awards enforceable in Vietnam?

Yes. Vietnam is a party to the New York Convention 1958 (Decision 453/QD-CTN, 28 July 1995), and the Civil Procedure Code 2015 provides the recognition and enforcement procedure. This is arbitration's greatest advantage over foreign court judgments in cross-border settings.

Caveat: Vietnam's three reservations — key among them, the Convention applies only to awards rendered in a member state's territory (reciprocity for non-members) and only to commercial disputes. When choosing a foreign seat, prefer New York Convention member states. For procedure, see our guide on recognition and enforcement of foreign arbitral awards in Vietnam.

7.6. VIAC, ICC or SIAC for a foreign-related contract?

No universal answer — it turns on potential dispute value and complexity, the parties' nationalities and positions, the desired seat, and budget:

  • VIAC: the natural choice where parties and assets sit mainly in Vietnam — reasonable costs, tribunals versed in Vietnamese law, logistical ease.
  • ICC: for high-value multi-jurisdictional deals needing global prestige and ICC's distinctive scrutiny mechanism — at higher cost.
  • SIAC: the balanced Asian option — neutral, efficient, cheaper than ICC, with outstanding Singapore court support.

The decisive factor is not the most "prestigious" institution but a clause that names the right institution, the right rules, and completes all seven components (section 3). A well-drafted VIAC clause always beats a sloppy ICC one.

8. When to Engage Counsel

The arbitration clause is one of the few contractual provisions where a small error can collapse the entire dispute-resolution strategy — and the error surfaces only when it is too late to fix. Engage arbitration counsel when you see these signs:

  1. High-value or structurally complex deals (M&A, joint ventures, EPC, PPP projects): the clause must be designed together with governing law, security packages and multi-party dispute mechanisms.
  2. Parties from different legal systems: counsel should weigh seat, lex arbitri and award enforceability in each relevant country — particularly in Vietnam–China transactions, where legal differences run deep.
  3. An existing clause shows pathological symptoms (misnamed institution, optional language, arbitration–court contradictions): assess the risk and sign a corrective addendum before a dispute arises.
  4. A dispute is brewing under an unclear clause: analyze jurisdiction, filing strategy and fallback options (courts, mediation) before acting.
  5. Multi-tier or bespoke mechanisms are needed (emergency arbitration, independent experts, multi-party tribunals): these structures demand precise drafting to survive jurisdictional challenges.

FLAT Law Firm advises on drafting and reviewing arbitration clauses for FDI contracts, Vietnam–China cross-border transactions and international commercial disputes. Contact our hotline at 0988424851 for matter-specific advice — because no model clause substitutes for one designed around your transaction.

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References

  • Law on Commercial Arbitration No. 54/2010/QH12 (effective 1 July 2011).
  • 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (Vietnam acceded under Decision 453/QD-CTN dated 28 July 1995).
  • Civil Procedure Code No. 92/2015/QH13 (effective 1 July 2016).
  • VIAC Rules of Arbitration 2026 (effective 1 July 2026) — Appendix III: Model Arbitration Clause.
  • ICC Arbitration Rules 2021 — ICC Model Arbitration Clause.
  • SIAC Rules 2025 — SIAC Model Arbitration Clause.

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