A Paradox is that the Energy Transition is Policy not Market Driven and will require a significant expansion in state roles in the energy sector. Yet, at the same time it cannot achieve its goals without very large scale funding from the private sector. For lawyers, the challenge will be how to design or adapt protections for investors, especially foreign investors, that make it possible for them to participate on scale. This will question the current balance of protections in investor-state arbitration which was designed in different circumstances for a very different and more stable energy world. Questions they will need to consider: What do disputes to date tell us about the shape and limits of such protections? Are there regional or jurisdictional differences? Are there peculiarities in federal states that complicate matters? What sense is there to the notion of 'stability' in long term agreements in this context and will arbitrators be supportive? The talk will cover: (1) Disputes in new kinds of energy – renewables, and (2) Disputes in traditional kinds of energy – oil and gas. It will then draw up a checklist of early lessons with indications of areas of concern and sources of optimism.