The author compares the new article 1195 of the French Civil code, which empowers the judge (and the arbitrator) to revise the contract if the underlying circumstances have fundamentally changed, with the international arbitration practice. The French reform is certainly innovative from an internal law perspective, but not from the perspective of the international arbitration practice. Indeed, the arbitrators’ power to revise contract clauses in case of a fundamental change of circumstances is codified in the Unidroit and PECL Principles. Moreover, the same power is regularly exercised by a number of international tribunals at least in two sectors, namely the disputes arising from oil and gas and construction contracts. It is rather from a national law view point that the reform deviates from the traditional approach, according to which “judges do not make contracts” and solve issues of a legal nature with no authority to interfere with what contractually agreed by the parties.The French innovation was preceded by similar reforms in the Netherlands, Germany,Argentina, Switzerland, Austria and the Arabic countries, but in the world of international arbitration a similar trend evolved much earlier and more rapidly.