Arbitration analysis: On 11 December 2025, the Paris Court of Appeal dismissed in full an Italian franchisor (the Franchisor)’s application to set aside an ICC award rendered in a dispute with its former Portuguese franchisee (the Franchisee) and the latter’s parent company (the Parent Company), reaffirming once again France’s pro-enforcement and arbitration-friendly stance. The court adopted a formalistic approach to annulment control and, more broadly, to the application of civil procedure rules. It refused to reopen the proceedings absent any serious circumstance arising after the order closing the proceedings and held that the scope of judicial review is defined exclusively by the claims precisely framed at the outset of the annulment proceedings. In practice, only the specific operative heads of the award expressly challenged in the applicant’s submissions filed within the statutory time limit could be examined, with all other challenges declared inadmissible. The court further dismissed all alleged annulment grounds based on due process, excess of mandate, and the violation of international public policy as unlawful attempts to revisit the merits. For practitioners, the decision underscores the narrow scope of French annulment review, the need to front-load and precisely frame challenges from the outset, and the growing financial risks of speculative or ‘kitchen-sink’ set-aside strategies, particularly given the court’s willingness to award substantial adverse costs, EUR 240,000 in this case. Written by Julie Spinelli, partner at Le 16 Law, and Carl Szymura, associate at Le 16 Law.