AAA Arbitration Exhibit Requirements
American Arbitration Association (AAA) Commercial Arbitration Rule R-22 requires parties to exchange exhibits at least 5 business days before the hearing. Claimants label exhibits C-1, C-2, C-3 and Respondents label exhibits R-1, R-2, R-3. Unlike court trials, AAA proceedings do not apply the Federal Rules of Evidence.
- AAA Commercial Arbitration Rule R-22 establishes a default 5-day exhibit exchange deadline before the hearing, which the arbitrator may extend or shorten by order.
- Claimants in AAA arbitration label exhibits C-1, C-2, C-3 (or C-001 for large productions); Respondents label exhibits R-1, R-2, R-3.
- The Federal Rules of Evidence do not apply in AAA arbitration; under Rule R-31 the arbitrator may consider any evidence deemed relevant and material, including hearsay.
- AAA arbitrators have authority under Rule R-27 to direct document production and exchange and may exclude exhibits not timely exchanged.
- AAA's Arbitration Management Platform (AMP) is commonly used for electronic document exchange in complex commercial cases.
- The AAA International Centre for Dispute Resolution (ICDR) uses different exhibit procedures for international arbitrations than domestic AAA proceedings.
- AAA Employment, Consumer, and Construction rule sets each have their own exhibit provisions distinct from the Commercial Arbitration Rules.
- Exhibit lists identifying each exhibit by label, description, and page count are required for complex AAA commercial cases and typically become part of the final award record.
AAA Exhibit Key Requirements
C/R Prefix Labels
Claimants use C-1, C-2, C-3. Respondents use R-1, R-2, R-3. Zero-padded numbering (C-001) recommended for large productions.
Rule R-22 Exchange
Default deadline is 5 business days before the hearing. Arbitrator has broad discretion to modify the deadline by order.
Electronic Submission
AAA's Arbitration Management Platform (AMP) or agreed cloud folder. Single-PDF-per-exhibit or bookmarked combined binder preferred.
No FRE Required
Federal Rules of Evidence do not apply. Arbitrator may admit any relevant and material evidence under Rule R-31, including hearsay.
ICDR vs. AAA: Check Whether Your Arbitration Is Domestic or International
International arbitrations under the AAA's International Centre for Dispute Resolution (ICDR) have different exhibit procedures than domestic AAA proceedings. ICDR arbitrations typically follow the ICDR International Arbitration Rules, which give the tribunal discretion to direct document production and may apply IBA Rules on the Taking of Evidence as a guideline. Always confirm whether your arbitration is governed by AAA Commercial Rules or ICDR International Rules before preparing your exhibits.
AAA Arbitration Exhibit Checklist
- Confirm which AAA rule set governs (Commercial, Employment, Consumer, or Construction)
- Identify the exhibit exchange deadline from the scheduling order or R-22 default (5 days)
- Assign Claimant (C-1, C-2, C-3) or Respondent (R-1, R-2, R-3) labels to each exhibit
- Use zero-padded numbering (C-001) if your exhibit count exceeds 9 documents
- Prepare a formal exhibit list with label, description, date, and page count for each exhibit
- Exchange exhibit copies and exhibit list on all parties and the arbitrator by the deadline
- Upload documents to AAA Arbitration Management Platform (AMP) if required by the arbitrator
- Confirm with opposing counsel whether courtesy copies of exhibit binders are expected at the hearing
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Frequently Asked Questions
What is the AAA exhibit exchange deadline under Rule R-22?
AAA Commercial Arbitration Rule R-22 requires parties to exchange copies of all documents they intend to offer as exhibits at least 5 business days before the arbitration hearing. The arbitrator has broad discretion to adjust this deadline by order, either extending or shortening it based on the complexity of the case and the number of exhibits involved. Some AAA case types—including Employment, Consumer, and Construction—operate under different rule sets and may have distinct exchange deadlines, so always verify which rule set governs your arbitration.
How are exhibits labeled in AAA arbitration?
In AAA arbitration, Claimants label their exhibits C-1, C-2, C-3 and Respondents label their exhibits R-1, R-2, R-3. For large document productions, zero-padded numbering (C-001, C-002) is recommended so files sort correctly in digital case management systems. If multiple claimants or respondents are present, the arbitrator typically establishes a coordinated numbering convention at the preliminary hearing to prevent duplicate exhibit labels.
How are exhibits submitted electronically in AAA arbitration?
AAA offers its Arbitration Management Platform (AMP) for document exchange in many complex commercial cases. Parties may also use other agreed-upon methods such as shared cloud folders or email exchange for smaller matters. A single PDF per exhibit (e.g., C-001_Contract.pdf) or a combined exhibit binder PDF with bookmarks are both acceptable formats. Confirm the preferred submission method with the arbitrator at the initial scheduling conference, as practice varies by case and arbitrator preference.
Do the Federal Rules of Evidence apply in AAA arbitration?
No. AAA arbitration does not apply the Federal Rules of Evidence unless the parties have expressly stipulated otherwise. Under AAA Commercial Rule R-31, the arbitrator may receive and consider all evidence the arbitrator deems relevant and material, including hearsay. The arbitrator determines what weight to give each exhibit. This gives arbitrators substantially more flexibility than federal judges in admitting documentary evidence, but parties may still object to exhibits on relevance or authenticity grounds.
What authority does the arbitrator have over exhibit exchange in AAA proceedings?
Under AAA Rule R-22, the arbitrator has broad authority to direct the production and exchange of documents, including exhibits. The arbitrator may set earlier or later exchange deadlines, require an exhibit list prior to exchange, direct the format of exhibit submissions, and exclude exhibits not timely exchanged. Under R-23, the arbitrator may also issue subpoenas to compel the production of documentary evidence. Parties who fail to comply with exchange orders risk having their exhibits excluded from the hearing.
How does AAA arbitration differ from JAMS for exhibit purposes?
Both AAA and JAMS use the Claimant (C-1) and Respondent (R-1) prefix labeling convention. The key procedural difference is that AAA Commercial Rule R-22 establishes a default 5-day exchange deadline, while JAMS Comprehensive Rule 22 gives the arbitrator full discretion to set the deadline with no fixed default. AAA's AMP platform is used for electronic exchange in AAA proceedings, while JAMS uses its own online case management platform. For cases involving large document productions, JAMS tends to allow more discovery and may require a more structured pre-hearing exchange process.
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