This article discusses pre-arbitration ADR requirements in Mainland China, focusing on court decisions as to the enforceability of these requirements and the legal consequences of noncompliance. Conflicting approaches of Mainland Chinese courts to the characterisation and reviewability of compliance-related objections at the annulment and enforcement stages are given particular attention. A comparative case study evaluates (1) different approaches to the problem under Chinese law (including the current Draft Revision of the Chinese Arbitration Law) and Swiss law, and (2) an alternative approach in England & Wales, Hong Kong and France.