The Court of Justice of the European Union (the Court) has famously sought to eliminate intra-European Union (EU) investment arbitration under bilateral investment treaties and the multilateral Energy Charter Treaty. In doing so, the Court has navigated settled case law concerning commercial arbitration. In this regard, Achmea and subsequent rulings are premised upon a distinction drawn by the Court between investment and contract-based arbitration, based on the origin of arbitral proceedings and the intensity of the review of the relevant award. This article demonstrates that this distinction disregards important commonalities and the diversity of enforcement regimes. It is further argued that, even in the light of Achmea, EU law rightly permits intra-EU arbitration under investment contracts, that is, contracts between States and foreign investors. The article thus examines investment contract-based arbitration as the only surviving form of intra-EU investment arbitration and cautions against expansive applications of the Achmea reasoning to contractual agreements, signs of which are already emerging.