OMB APPROVAL
                                  UNITED STATES
                       SECURITIES AND EXCHANGE COMMISSION                       OMB Number: 3235-0058
                             Washington, D.C. 20549                             Expires: March 31, 2006
                                                                                Estimated average burden
                                   FORM 12b-25                                  hours per response...2.50
                           NOTIFICATION OF LATE FILING
                                                                                SEC FILE NUMBER
(Check One) [ ] Form 10-K     [ ] Form 20-F   [ ] Form 11-K   [x] Form 10-Q     1-16017
            [ ]Form N-SAR     [ ] Form N-CSR
                                                                                CUSIP NUMBER
                   For Period Ended:  March 31, 2004                            G67743
                                      --------------
                   [ ] Transition Report on Form 10-K
                   [ ] Transition Report on Form 20-F
                   [ ] Transition Report on Form 11-K
                   [ ] Transition Report on Form 10-Q
                   [ ] Transition Report on Form N-SAR
                   For the Transition Period Ended: ____________________


  Read Instruction (on back page) Before Preparing Form. Please Print or Type.
Nothing  in this  form  shall be  construed  to imply  that the  Commission  has
verified any information contained herein.

If the notification  relates to a portion of the filing checked above,  identify
the Item(s) to which the notification relates:
Not applicable.

PART I - REGISTRANT INFORMATION

Orient-Express Hotels Ltd.
--------------------------
Full Name of Registrant

         --
---------------------
Former Name if Applicable

22 Victoria Street
---------------------------------------------------------
Address of Principal Executive Office (Street and Number)

Hamilton HM 12, Bermuda
-----------------------
City, State and Zip Code

PART II - RULES 12b-25(b) AND (c)

If the subject report could not be filed without  unreasonable effort or expense
and the registrant seeks relief pursuant to Rule 12b-25(b), the following should
be completed. (Check boxes if appropriate)

[X]  (a)  The reasons  described in  reasonable  detail in Part III of this form
          could not be eliminated without unreasonable effort or expense;

[X]  (b)  The subject annual report,  semi-annual  report,  transition report on
          Form 10-K, Form 20-F,  11-K, Form N-SAR or N-CSR, or portion  thereof,
          will be filed on or before the  fifteenth  calendar day  following the
          prescribed  due date;  or the subject  quarterly  report or transition
          report on Form 10-Q,  or portion  thereof,  will be filed on or before
          the fifth calendar day following the prescribed due date; and

[ ]  (c)  The accountant's statement or other exhibit required by Rule 12b-25(c)
          has been attached if applicable.

                  Persons who are to respond to the collections of
                  information contained in this form are not required to
                  respond unless the form displays a currently
SEC 1344 (07-03)  valid OMB control number.






PART III - NARRATIVE

State below in reasonable  detail the reasons why Forms 10-K,  20-F, 11-K, 10-Q,
N-SAR,  N-CSR, or the transition  report or portion thereof,  could not be filed
within the prescribed time period.

          On Friday,  May 7, 2004,  the  Registrant  received a letter  from the
          Commission staff dated May 6, 2004, making certain accounting comments
          on the  Registrant's  Annual  Report on Form 10-K for the fiscal  year
          ended  December  31,  2003.  All but one of the  comments  are "future
          filings"  comments.  The Registrant's  first future filing will be its
          Quarterly Report on Form 10-Q for the quarterly period ended March 31,
          2004. The filing deadline for this Form 10-Q was Monday, May 10, 2004.
          The  Registrant  requires one more day past this  deadline to complete
          the Form 10-Q in a manner  properly  responsive to the staff comments,
          and plans to file the Form 10-Q today.

          On May 4, 2004,  the Registrant  issued a news release  announcing its
          earnings for the quarterly period ended March 31, 2004, which has been
          furnished  to the  Commission  in a Form  8-K  Current  Report  of the
          Registrant  with  a  front  cover  dated  May  4,  2004.  None  of the
          Commission  staff's  accounting  comments  is  expected  to affect the
          consolidated net earnings and financial  position of the Registrant as
          previously announced in that news release.

          As a foreign  private  issuer,  the Registrant is eligible to file its
          interim  reports  on SEC  Form  6-K in lieu of  Forms  10-Q  and  8-K.
          However,  the Registrant elects to file its annual and interim reports
          with the SEC on the forms for U.S. domestic issuers (i.e., Forms 10-K,
          10-Q and 8-K).]


PART IV - OTHER INFORMATION

(1)  Name  and  telephone  number  of  person  to  contact  in  regard  to  this
     notification

     Edwin S. Hetherington
     ---------------------
    (Name)

    011-44-207-805-5200
    ------------------------------
    (Area Code) (Telephone Number)

(2)  Have all other periodic  reports  required under Section 13 or 15(d) of the
     Securities Exchange Act of 1934 or Section 30 of the Investment Company Act
     of 1940 during the preceding 12 months or for such shorter  period that the
     registrant was required to file such report(s) been filed? If answer is no,
     identify report(s).
     [x] Yes [ ] No

(3)  Is it anticipated that any significant change in results of operations from
     the corresponding  period for the last fiscal year will be reflected by the
     earnings  statements  to be  included  in the  subject  report  or  portion
     thereof?
     [ ] Yes [x] No

     If so, attach an explanation of the anticipated  change,  both  narratively
     and quantitatively, and, if appropriate, state the reasons why a reasonable
     estimate of the results cannot be made.

--------------------------------------------------------------------------------


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                           Orient-Express Hotels Ltd.
                  (Name of Registrant as Specified in Charter)
has  caused  this  notification  to be signed on its  behalf by the  undersigned
thereunto duly authorized.

Date:  May 11, 2004                         By: /s/ Edwin S. Hetherington
                                                -------------------------
                                                    Edwin S. Hetherington
                                                    Secretary


INSTRUCTION: The form may be signed by an executive officer of the Registrant or
by any other duly  authorized  representative.  The name and title of the person
signing  the form  shall  be typed or  printed  beneath  the  signature.  If the
statement is signed on behalf of the Registrant by an authorized  representative
(other than an executive officer), evidence of the representative's authority to
sign on behalf of the registrant shall be filed with the form.


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                                    ATTENTION

Intentional  misstatements  or omissions  of fact  constitute  Federal  Criminal
Violations (See 18 U.S.C. 1001).

                              GENERAL INSTRUCTIONS

1.   This form is  required by Rule  12b-25 (17 CFR  240.12b-25)  of the General
     Rules and Regulations under the Securities Exchange Act of 1934.

2.   One signed  original and four conformed  copies of this form and amendments
     thereto  must be  completed  and filed  with the  Securities  and  Exchange
     Commission,  Washington,  D.C.  20549,  in accordance  with Rule 0-3 of the
     General Rules and Regulations  under the Act. The information  contained in
     or filed  with  the form  will be made a matter  of  public  record  in the
     Commission files.

3.   A manually  signed copy of the form and  amendments  thereto shall be filed
     with each national  securities exchange on which any class of securities of
     the registrant is registered.

4.   Amendments to the notifications  must also be filed on form 12b-25 but need
     not restate information that has been correctly  furnished.  The form shall
     be clearly identified as an amended notification.

5.   Electronic Filers.  This form shall not be used by electronic filers unable
     to timely  file a report  solely  due to  electronic  difficulties.  Filers
     unable  to  submit  a  report  within  the time  period  prescribed  due to
     difficulties  in  electronic  filing  should comply with either Rule 201 or
     Rule 202 of Regulation  S-T  (ss.232.201  or ss.232.202 of this chapter) or
     apply for an adjustment in filing date pursuant to Rule 13(b) of Regulation
     S-T (ss.232.13(b) of this chapter).




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