Question
How do I enforce an arbitration clause against a non-paying Pennsylvania client?
My client hasn't paid, and the contract required good-faith negotiation followed by AAA arbitration. I don't know what that means or how to start. How do I get paid without wasting a bunch of my own money?
Answer
To enforce an arbitration clause, you generally follow the dispute resolution steps outlined in your contract—for example, attempting "good-faith negotiation" before initiating arbitration with a provider such as the American Arbitration Association (AAA).
Arbitration typically replaces court litigation on the merits of the dispute. However, courts may still play a role, such as compelling arbitration if one party refuses to participate or enforcing the final arbitration award.
What does "good-faith negotiation" mean?
It means you must make a real attempt to resolve the issue before starting arbitration. This often includes sending a clear payment demand, sharing invoices, and giving the client a chance to respond.
Document your efforts. Emails or written notices showing you tried to resolve the issue can matter if the dispute moves forward.
How do you start AAA arbitration?
If negotiation fails, you can file a "Demand for Arbitration" with the AAA. This document explains the dispute, the amount owed, and what you are asking for.
You will need to pay a filing fee, which depends on the claim size. After filing, an arbitrator is assigned, and the process begins. The final decision (called an award) can be enforced in court if needed.
What to do next...
- Send a clear final demand for payment and document it.
- Review your contract's arbitration clause for AAA details.
- Prepare and file a Demand for Arbitration with the AAA.
- Consider the filing cost compared to the amount owed.
What to consider in your specific situation
While arbitration can help you get paid, the best approach depends on your contract and claim size.
- The amount owed versus arbitration filing costs.
- Whether your contract allows recovery of fees or costs.
- The client's willingness or ability to pay.
- The clarity of your invoices and agreement terms.
- Whether negotiation could still resolve the issue.
- The time and effort required to complete arbitration.
Taking structured steps can help you enforce your rights while managing costs and expectations. Since every situation is different, consider more information through Rocket Copilot, a Legal Pro, or a legal document review to move forward with confidence.

At Rocket Lawyer, we follow a rigorous editorial policy to ensure every article is helpful, clear, and as accurate and up-to-date as possible. This page was created, edited and reviewed by trained editorial staff who specialize in translating complex legal topics into plain language, then reviewed by experienced Legal Pros—licensed attorneys and paralegals—to ensure legal accuracy.
Please note: This page offers general legal information, but not legal advice tailored for your specific legal situation. Rocket Lawyer Incorporated isn't a law firm or a substitute for one. For further information on this topic, you can Ask a Legal Pro.

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Disclosures
- This page offers general legal information, not legal advice tailored for your specific legal situation. Rocket Lawyer Incorporated isn't a law firm or a substitute for one. For further information on this topic, you can Ask a Legal Pro.