Harmonization of National Civil Law with International Arbitration Rules in the Field of Cybersecurity: A Comparative Analysis of the ICC, LCIA and UNCITRAL Rules

Abstract

This article examines the harmonization of national civil law with the procedural regimes of international commercial arbitration in the sphere of cybersecurity. It compares the approaches of the International Chamber of Commerce (ICC), the London Court of International Arbitration (LCIA), and the United Nations Commission on International Trade Law (UNCITRAL) to information security, data protection, and cyber-incident management within arbitral proceedings. Using doctrinal and comparative legal analysis, the study reviews institutional rules, soft-law protocols, and civil-law codifications to identify convergences and gaps. The results show that while arbitral institutions increasingly reference cybersecurity through procedural discretion, national civil codes rarely provide corresponding substantive rules on liability, evidentiary integrity, or breach notification. The article argues that harmonization requires embedding baseline cybersecurity standards into civil codification, supported by cross-referencing arbitration rules, to ensure coherent, enforceable, and globally consistent protection of arbitral data.