Hong Kong and France are both strong promoters of arbitration as a means of alternative dispute resolution. They both have legal systems that are well developed and arbitration friendly. And coincidentally, both have recently enacted new arbitration legislation. Hong Kong’s new Arbitration Ordinance came into force on 1 June 2011, and France’s new arbitration law, Decree 2011-48 of 13 January 2011 came into force on 1 May 2011. The writer does not profess to be an expert on French law. Nevertheless, the differences between the two new regimes are so striking that it hardly matters. This article highlights some of them.