France: Arbitration & Dispute Resolution

The French Court of Cassation has issued two landmark decisions addressing whether dual nationals can bring investment treaty arbitration claims against a state of which they hold nationality. These May 2026 rulings establish critical precedents for treaty interpretation under the Vienna Convention, particularly regarding the role of subsequent diplomatic agreements and the primacy of treaty text over general international law principles.

In March 2025, the French Ministry of Justice released the report of its Working Group on modernizing French arbitration law.1 This is the first major reform proposal since 2011.

On July 10, 2023, the European Commission adopted its adequacy decision for the EU-U.S. Data Privacy Framework.