Executive Summary

This article explores the role of arbitration institutions in system-building and argues that arbitration institutions by replicating each other's rules, facilitating growth of a common culture of arbitration and strategically cooperating with each other act as important agents in making arbitration a truly international system. Arbitration institutions impact international arbitration in a fundamental way, i.e., despite lacking a formal system of precedent, cross-institutional convergence of rules by replication underpinned by a shared culture of arbitration increases the chances of similar outcomes in procedural disputes with similar facts as borrowing of interpretations across institutions become easier. This can eventually lead to the creation of 'uniform global rules of arbitration practice' in the future. Though convergence across institutional rules has its merits, it may also undermine the benefits of diversity. Further research is required to understand the role of arbitration institutions as system-builders and how cross-institutional convergence of rules will impact the evolution of international arbitration - for example, will adoption of similar arbitration rules to harness the power of technology, systemically transform the way lawyers arbitrate disputes in the future?