How to Enforce a Foreign Judgment: UK, EU and US Routes, Costs and Timelines

How to enforce a foreign judgment: the short answer

A foreign judgment has no automatic force abroad: the creditor must convert it into a local court order in the country where the debtor's assets are, using whichever treaty, statute or common law route links the two countries. Four questions decide the route and therefore the cost and the timetable.

• Where are the assets? Enforcement follows the money. A judgment against a company with bank accounts in Frankfurt, property in London and receivables in Texas may need three separate local applications.
• Which court gave the judgment, and when were proceedings started? The country of origin decides which treaty, if any, applies, and the start date of the original claim decides whether a newer treaty such as Hague 2019 covers it.
• What kind of judgment is it? Most regimes cover only final money judgments in civil or commercial matters. Tax, fines, penalties, family, insolvency and intellectual property orders are usually excluded or treated differently.
• Did the debtor take part, or agree to the court? Almost every regime checks that the original court had jurisdiction over the debtor in an internationally acceptable sense, so a default judgment against a party with no connection to the court is the hardest to enforce.

The same questions explain why many cross-border contracts choose arbitration instead, and why the seat of an arbitration matters so much at the enforcement stage. Where the parties chose a court, the answers above determine everything that follows.

What the Supreme Court decided in Drelle

The Supreme Court decided that, at common law, a final foreign judgment for a definite sum gives rise to an immediate obligation to pay, so it is a "debt" for the purposes of section 267 of the Insolvency Act 1986 even before any English court has recognised it. The facts show why that matters. Servis-Terminal LLC, a Russian company in bankruptcy, obtained a judgment for RUB 2 billion from the Arbitrazh Court of the Yaroslavl Region on 24 May 2019 against its former Director General, Valeriy Drelle, who had settled in London; appeals in Russia failed in 2019 and 2020.

The company served a statutory demand in England in October 2020 and presented a bankruptcy petition based on the Russian judgment alone. A bankruptcy order followed in March 2023 and was upheld by the High Court, but on 31 January 2025 the Court of Appeal set it aside, holding that an unrecognised foreign judgment could not found a petition ([2025] EWCA Civ 62).

Lord Briggs and Lord Hamblen, with whom the other three Justices agreed, reversed that decision. Their conclusion on the common law point is short: an unrecognised foreign judgment for a debt or definite sum "gives rise to an obligation to pay the judgment sum". Pinsent Masons put the judgment debt at about US$23.9 million and described the effect for debtors as a shift in where they fight rather than an end to their defences: fraud, natural justice, public policy and a genuine dispute about the debt can still be argued inside the insolvency proceedings.

There are three limits. First, the case was remitted to the Court of Appeal to decide whether the Russian judgment debt is genuinely disputed on substantial grounds, so the outcome of Mr Drelle's bankruptcy is not yet settled. Second, as Mayer Brown notes, the ruling concerns insolvency only: a creditor who wants to execute against assets for its own benefit still needs an English judgment or registration. Third, judgments that are registrable under the Foreign Judgments (Reciprocal Enforcement) Act 1933 must, on the older authority the Supreme Court noted, be registered first, which leaves judgments from countries with no treaty in a stronger position for petition purposes than judgments from treaty partners. Bankruptcy claims by foreign creditors against debtors living in England are not new, as Emirates NBD's claim against Al Kuwari showed, and Drelle removes one procedural obstacle to them. The case also carried a sanctions dimension, since the Russian company's largest creditor became a designated person on 10 January 2025, a reminder that sanctions can shape who may be paid even after judgment.

How to enforce a foreign judgment in the UK: the four routes

In England and Wales a foreign judgment is enforced by registration under one of three statutory schemes or, where none applies, by suing on the judgment as a debt at common law. Which one applies depends on the country of origin, and choosing correctly matters because the 1933 Act, where it applies, is the only route available, as Clifford Chance's guide points out by reference to section 6 of that Act.

Route	Which judgments	Time limit	Key feature
Administration of Justice Act 1920	Money judgments of superior courts in listed former British territories, for example the Cayman Islands, New Zealand and Nigeria	12 months from judgment, or longer if the court allows	Registration is discretionary: the court must think it "just and convenient"
Foreign Judgments (Reciprocal Enforcement) Act 1933	Final money judgments from treaty countries, for example Australia, Canada, Israel, Norway and Pakistan	Six years from the judgment or the last appeal judgment	Registration is mandatory if the conditions are met; it is the exclusive route
Civil Jurisdiction and Judgments Act 1982 (Hague 2005 and Hague 2019)	Judgments under an exclusive choice of court agreement (Hague 2005), and civil or commercial judgments from Hague 2019 states in proceedings started on or after 1 July 2025	Set by the convention conditions and English procedure	No review of the merits; limited refusal grounds
Common law action on the judgment	Everything else, including judgments from the United States, Russia and China	Six years for an action upon a judgment	A fresh claim for the debt, usually resolved by summary judgment

Scotland and Northern Ireland have parallel arrangements, and judgments from one part of the UK are registered in another under Part 74 of the Civil Procedure Rules. For assets in London, Corporate INTL's directory lists lawyers in England. One caution applies to every route: the creditor cannot simply start the original dispute again in England, because section 34 of the Civil Jurisdiction and Judgments Act 1982 bars a new claim on the same cause of action where the foreign judgment is enforceable or entitled to recognition.

The Hague Judgments Convention: what changed on 1 July 2025

The 2019 Hague Judgments Convention created, for the first time since Brexit, a treaty route for ordinary civil and commercial judgments between the UK and the EU. The Ministry of Justice confirmed that it entered into force for the UK on 1 July 2025, and the Recognition and Enforcement of Judgments (2019 Hague Convention etc.) Regulations 2024 gave it the force of law by amending the 1982 Act. According to the Hague Conference status table, it now has 33 contracting parties: the EU and 26 member states (Denmark is not bound), Ukraine since 1 September 2023, Uruguay since 1 October 2024, the UK, Albania and Montenegro since 1 March 2026, and Andorra since 1 June 2026. The United States, Israel, Costa Rica, Kosovo, North Macedonia and Russia have signed but not ratified.

Four features of the Convention text matter most in practice:

• Timing. Article 16 applies the Convention only where it had effect between both states when the original proceedings were instituted. For UK and EU judgments that means claims filed from 1 July 2025 onwards, as Freshfields notes, so most judgments being enforced today still fall outside it.
• Scope. Article 2 excludes, among other things, insolvency, intellectual property, defamation, privacy, carriage of goods and passengers, most competition claims and arbitration. Article 3 says an interim measure of protection is not a judgment, so freezing orders do not travel under it.
• Jurisdictional filters. Article 5 makes a judgment eligible only if there was a recognised link to the court of origin, such as the debtor's habitual residence there, consent, or the place of performance of the contractual obligation.
• Limited defences. Article 4 forbids any review of the merits, and Article 7 lists the refusal grounds: defective notice, fraud, manifest incompatibility with public policy, proceedings brought in breach of a choice of court agreement, and inconsistent judgments.

The Convention does not extend to the Crown Dependencies or British Overseas Territories, which matters for structures held through Jersey, Guernsey, the Isle of Man or the British Virgin Islands.

Registering a foreign judgment in England: step by step

Registering a foreign judgment in England is a paper application to the High Court, usually made without notice to the debtor, followed by a short window in which the debtor may apply to set the registration aside. CPR Part 74 sets out the steps, which are broadly the same under the 1920 Act, the 1933 Act and the 1982 Act.

1. Obtain an authenticated copy of the judgment and, where it is not in English, a translation certified by a notary or confirmed by written evidence (CPR 74.4(1)).
2. Prepare the written evidence. It must give the names and addresses of the creditor and debtor, the grounds on which the creditor is entitled to enforce, the amount still unpaid and the interest position under the law of the country of origin (CPR 74.4(2)). Each Act adds its own statements; for Hague 2019 the evidence must confirm that the judgment is enforceable where it was given, that it meets an Article 5 or 6 basis and that the Article 12 documents are produced.
3. Apply to the High Court. The application may be made without notice (CPR 74.3). Under the 1920 and 1933 Acts the court may order security for costs; under the 1982 Act a creditor cannot be required to give security solely because it is resident abroad (CPR 74.5).
4. Serve the registration order. The order must state the debtor's right to apply to set it aside, the period for doing so, and that no enforcement will take place before that period ends other than measures to preserve the debtor's property (CPR 74.6).
5. Deal with any set-aside application, which must be made within the stated period, although the court can extend it (CPR 74.7).
6. Enforce once the period has expired, filing evidence of service. From that point the judgment is enforced like an English one (CPR 74.9).

The rules are short; the risk lies in the detail of the evidence, the treaty conditions and the debtor's likely objections. Dispute resolution lawyers who regularly appear on registration applications can usually say quickly whether a judgment is registrable and which route applies.

Suing on the judgment at common law

Where no statute applies, the creditor issues a fresh claim in England for the sum due under the foreign judgment and normally asks for summary judgment, because the foreign judgment is treated as creating a debt. The Supreme Court in Drelle restated the conditions through the Dicey rules: the judgment must be given by a court with jurisdiction over the debtor in the English sense, be final and conclusive, and be for a debt or definite sum of money that is not a tax, fine or penalty. A judgment that meets those conditions cannot be reopened for errors of fact or law.

Clifford Chance observes that, where there is no real issue on the conditions, a summary English judgment "seldom takes materially longer" than registration. The defences are narrow but real: fraud, breach of natural justice, public policy and lack of jurisdiction. One statutory bar catches many US judgments: section 5 of the Protection of Trading Interests Act 1980 prevents enforcement of a judgment for multiple damages, and Clifford Chance notes that even the compensatory part of such an award cannot be enforced. Treble damages awarded under US antitrust or racketeering statutes therefore need careful handling before a claim is issued in London.

Enforcing a judgment inside the EU

Between EU member states, enforcement is close to automatic under the Brussels I recast Regulation: a judgment enforceable in one member state is enforceable in the others "without any declaration of enforceability being required" (Regulation (EU) No 1215/2012, Article 39). The creditor gives the local enforcement authority an authentic copy of the judgment and the Article 53 certificate issued by the court of origin (Article 42). The debtor may apply to refuse enforcement only on the Article 45 grounds: manifest breach of public policy, lack of proper service in a default case, irreconcilable judgments, and breach of the protective jurisdiction rules for consumers, employees and insured parties. Article 52 forbids any review of the substance. The Regulation applies to proceedings instituted on or after 10 January 2015.

For UK judgments the position is different. Brussels I stopped applying to UK proceedings started after 31 December 2020, and the UK's application to rejoin the Lugano Convention stalled: Clifford Chance recorded in 2021 that the European Commission had recommended the EU withhold its consent. A UK creditor enforcing in the EU therefore uses Hague 2019 for claims filed from 1 July 2025, Hague 2005 where there is an exclusive English jurisdiction clause, or each member state's national exequatur procedure. Under Hague 2019 the procedure is still governed by local law, although Article 13 requires the court to act expeditiously and Article 14 bars security for costs imposed only because the applicant is foreign. In practice that means instructing counsel in the member state where the assets are, for example lawyers in Ireland where Irish assets are concerned.

How to enforce a UK judgment in the US

There is no federal statute or treaty for foreign-country judgments in the United States, so a UK creditor must seek recognition under the law of the state where the debtor's assets are, and then enforce the recognised judgment like a local one. The Transnational Litigation Blog's primer, updated in May 2026, records that 29 states and the District of Columbia have adopted the 2005 Uniform Foreign-Country Money Judgments Recognition Act, nine states still apply the 1962 Uniform Act, and the remaining 12 rely on common law shaped by the Supreme Court's 1895 decision in Hilton v Guyot.

Under both Uniform Acts a final, conclusive and enforceable money judgment is presumed entitled to recognition. A court must refuse recognition if the foreign legal system lacks impartial tribunals or due process, or if the foreign court lacked personal or subject-matter jurisdiction, judged by US constitutional standards. It may refuse on discretionary grounds including lack of notice, fraud, repugnance to public policy, a conflicting judgment, breach of a forum selection or arbitration clause and, under the 2005 Act only, substantial doubt about the integrity of the court or lack of due process in the specific proceeding.

Tax, fines, penalties and family judgments are outside both Acts, and the federal SPEECH Act blocks foreign defamation judgments that would fail US free speech standards.

Reciprocity is not a ground for refusal under the Uniform Acts, but five states have added it: Arizona, Florida, Massachusetts, Ohio and Texas. A creditor holding a judgment from a country that does not itself enforce US judgments should check the rule in the relevant state before filing. The US has signed both Hague conventions but ratified neither, so state law will remain the route for the foreseeable future; Corporate INTL's directory lists advisers in New York and other states.

Asset tracing and freezing injunctions before you enforce

A judgment is only as good as the assets it can reach, so experienced creditors trace and freeze before they register or sue. In England the High Court can grant a freezing injunction restraining a party from removing assets from the jurisdiction or from dealing with assets "whether located within the jurisdiction or not", and can order the respondent to disclose where those assets are (CPR 25.1). Interim remedies may be granted before proceedings start or after judgment (CPR 25.2), on affidavit evidence and using the approved model order. CPR 74.9 expressly allows orders preserving the debtor's property while a registration is pending, and section 25 of the 1982 Act lets the High Court grant interim relief in support of proceedings abroad.

Once a judgment is enforceable in England, CPR Part 71 allows the creditor to apply, without notice, for an order requiring the debtor, or an officer of a debtor company, to attend court and answer questions about its means. Investigators and forensic accountants usually do the groundwork on corporate structures and bank flows. After Drelle, an insolvency petition is also a realistic lever for an individual debtor in England, and insolvency specialists can advise whether a statutory demand would bring payment faster than execution. Where the debtor is already in insolvency elsewhere, cross-border recognition regimes such as Malaysia's new Cross-Border Insolvency Act may govern instead of judgment enforcement rules.

Cost of enforcing a foreign judgment and how long it takes

The cost of enforcing a foreign judgment is driven mainly by legal fees, translation and whether the debtor fights; court fees are a smaller part. In England a common law action is a new money claim, so the issue fee is 5% of the claim for sums between £10,000.01 and £200,000 and £10,000 above that. Registration applications are cheaper and quicker because they are made on paper and without notice. Timelines elsewhere vary widely, and the estimates below come from practitioner guides rather than official statistics.

Where the assets are	Main route for a foreign money judgment	Indicative timeline if unopposed	Typical sticking points
England and Wales	1920 or 1933 Act registration, Hague 2005 or 2019 registration, or common law claim	Common law summary judgment seldom materially longer than registration (Clifford Chance)	Jurisdiction of the original court, fraud and natural justice defences, multiple damages bar
EU member state, EU judgment	Brussels I recast: no exequatur, Article 53 certificate	No exequatur step: the creditor goes straight to the enforcement authority	Article 45 refusal grounds
EU member state, UK judgment	Hague 2019 (claims filed from 1 July 2025), Hague 2005, or national exequatur	Depends on the member state's procedure	Article 16 timing, Article 5 filters
United States	State Uniform Act or common law recognition	Depends on the state and on contest	Personal jurisdiction, due process, reciprocity in five states
Singapore	REFJA registration, Choice of Court Agreements Act 2016, or common law action	Four to eight weeks for REFJA registration (Global Law Experts)	Whether the court of origin is gazetted
Australia	Foreign Judgments Act 1991 registration, Trans-Tasman registration for New Zealand, or common law	Six to twelve weeks (Global Law Experts)	US and Chinese judgments are not covered by the Act
China	Bilateral treaty or reciprocity	Around 12 to 24 months or longer (Global Law Experts)	Proof of reciprocity, public policy

The Global Law Experts guide to enforcing foreign judgments in China makes a point worth carrying into any budget: a New York Convention arbitral award is generally faster and more predictable to enforce there than a court judgment, which depends on a treaty or proof of reciprocity. Its Australian guide notes that judgments from countries outside the Foreign Judgments Regulations, including the United States, must go through a slower common law claim. Where the sums are large and the debtor is solvent but evasive, some creditors fund enforcement through third parties; our guide to litigation funding in the UK explains how that market works.

When to instruct a local enforcement lawyer and what to prepare

Instruct a lawyer in the country where the assets are as soon as there is a final judgment and any sign that the debtor will not pay voluntarily, and before the debtor has time to move assets. Enforcement is local: the judgment-giving court's lawyers can prepare documents, but only a lawyer qualified where the assets sit can register, sue, freeze and execute there. A short, well-prepared instruction saves weeks. Have the following ready:

• The judgment and its status: a certified copy, any appeal decisions, a statement or certificate that it is final and enforceable, and the date the original claim was issued, which decides whether Hague 2019 applies.
• Proof of service of the claim on the debtor, especially for a default judgment, and evidence of how the debtor took part.
• The contract, including any jurisdiction or arbitration clause, which can open the Hague 2005 route or close others.
• The amount outstanding, interest under the law of the original court, costs orders and any payments received.
• What you know about assets: bank accounts, property, shareholdings, receivables, related companies and where the debtor lives.
• Translations and apostilles, or a plan and budget for them.
• Deadlines: 12 months under the 1920 Act, six years under the 1933 Act and for common law claims in England, and local limitation periods elsewhere.

Corporate INTL's directory lists vetted lawyers and advisers in more than 150 jurisdictions, including cross-border specialists. If you hold an unpaid judgment, use the Find an Expert form below to tell us the country where judgment was given and the country where the assets are, and we will put you in touch with a member who handles enforcement there.

Frequently asked questions

How do you enforce a foreign judgment?

You apply in the country where the debtor's assets are, using the treaty, statute or common law route that links it to the country of origin. In England that means registration under the 1920 Act, the 1933 Act or the Hague conventions, or a fresh claim on the judgment debt at common law.

How do I enforce a foreign judgment in the UK?

Check whether the judgment comes from a 1920 Act territory, a 1933 Act treaty country or a Hague 2019 state with proceedings started on or after 1 July 2025. If so, apply to the High Court under CPR Part 74. If not, issue a claim on the judgment debt and seek summary judgment.

Is the United Kingdom part of the Hague Judgments Convention?

Yes. The UK ratified the 2019 Hague Judgments Convention on 27 June 2024 and it entered into force for the UK on 1 July 2025. It applies only where the original proceedings were started after it had effect between the UK and the other state, so most UK and EU judgments enforced today predate it.

Which countries are covered by the Foreign Judgments (Reciprocal Enforcement) Act 1933?

The 1933 Act applies to countries with which the UK has a reciprocal treaty, set out in orders made under the Act. Clifford Chance's guide gives Australia, Canada, Israel, Norway and Pakistan as examples. Registration must be sought within six years of the judgment or the last appeal judgment.

How can I enforce a foreign judgment in the United States?

File for recognition in the state where the debtor's assets are. Most states apply the 2005 or 1962 Uniform Act, which presumes final money judgments are recognised unless a listed ground applies, such as lack of jurisdiction or due process, fraud or public policy. Once recognised, the judgment is enforced like a local one.

How long does it take to enforce a foreign judgment?

Unopposed registrations can take weeks: practitioner guides estimate four to eight weeks in Singapore and six to twelve weeks in Australia. Contested cases take months, and recognition in China is estimated at 12 to 24 months or more. In England, summary judgment on a common law claim is often not much slower than registration.

How much does it cost to enforce a foreign judgment?

Legal fees, translations and any contest are the main costs. In England a common law claim attracts an issue fee of 5% of the claim between £10,000.01 and £200,000, capped at £10,000 above that. Registration on paper is usually cheaper, and costs orders against the debtor can recover part of the spend.

Can an unrecognised foreign judgment be used to bankrupt someone in England?

Yes, following Drelle v Servis-Terminal LLC [2026] UKSC 29. The Supreme Court held that a final foreign money judgment creates a debt that can found a bankruptcy petition without recognition proceedings. The debtor can still argue the debt is genuinely disputed, for example on fraud or natural justice grounds.

Can a foreign freezing order be enforced in the UK?

Generally not under the Hague 2019 Convention, which says an interim measure of protection is not a judgment. Instead, the creditor applies to the English High Court for its own freezing injunction, which can cover assets worldwide, including in support of proceedings abroad under section 25 of the 1982 Act.

Conclusion: how to enforce a foreign judgment in 2026

Knowing how to enforce a foreign judgment now starts with two dates: when the original claim was filed, which decides whether Hague 2019 applies, and when the judgment became enforceable, which starts the registration and limitation clocks. Drelle has strengthened the creditor's hand in England, Hague 2019 has rebuilt part of the bridge to the EU, and the US remains a state-by-state exercise. In every case the work is done where the assets are, so the most valuable early step is local advice. Corporate INTL's directory lists dispute resolution lawyers by country, and the request form below this article is the quickest way to tell us the jurisdictions involved so that we can introduce a member.

Sources

1. UK Supreme Court: Drelle v Servis-Terminal LLC [2026] UKSC 29 (27 July 2026)
2. Pinsent Masons Out-Law: Supreme Court removes recognition hurdle for foreign judgment creditors (21 August 2026)
3. Mayer Brown: UK Supreme Court confirms that unrecognised foreign judgments can trigger insolvency proceedings (September 2026)
4. Ministry of Justice: Statement on the entry into force of the 2019 Hague Convention (2 July 2025)
5. HCCH: Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters, full text
6. HCCH: Status table for the 2019 Judgments Convention
7. The Recognition and Enforcement of Judgments (2019 Hague Convention etc.) Regulations 2024, SI 2024/713
8. Civil Procedure Rules Part 74: Enforcement of judgments in different jurisdictions
9. Administration of Justice Act 1920, section 9
10. Foreign Judgments (Reciprocal Enforcement) Act 1933, section 2
11. Civil Jurisdiction and Judgments Act 1982, section 34
12. Limitation Act 1980, section 24
13. Protection of Trading Interests Act 1980, section 5
14. Civil Procedure Rules Part 25: Interim remedies
15. Civil Procedure Rules Part 71: Orders to obtain information from judgment debtors
16. GOV.UK: Make a court claim for money, court fees
17. Regulation (EU) No 1215/2012 (Brussels I recast), EUR-Lex
18. Clifford Chance: How to enforce a foreign judgment in England (July 2021)
19. Freshfields: Enforcement of judgments made easier between the EU and UK (July 2025)
20. Transnational Litigation Blog: A primer on foreign judgments (updated 17 May 2026)
21. Global Law Experts: How do you enforce foreign judgments in Australia (July 2026)
22. Global Law Experts: Registration of a foreign judgment in Singapore (May 2026)
23. Global Law Experts: Enforcing foreign judgments in China (August 2026)

About this article

This analysis was researched and written by The Corporate INTL Newsroom, which covers cross-border legal, regulatory and business developments for lawyers, professional advisers and financiers in over 150 jurisdictions. It has been checked against the UK Supreme Court's judgment in Drelle v Servis-Terminal LLC, the text and status table of the 2019 Hague Judgments Convention, the UK implementing regulations, the Administration of Justice Act 1920, the Foreign Judgments (Reciprocal Enforcement) Act 1933, the Civil Jurisdiction and Judgments Act 1982, the Limitation Act 1980, the Protection of Trading Interests Act 1980, Civil Procedure Rules Parts 25, 71 and 74, the Brussels I recast Regulation, published court fees, practitioner commentary and guides published by our sister publication Global Law Experts. Timelines quoted from practitioner guides are estimates, not official figures, and national procedures inside the EU and the 50 US states are summarised rather than set out in full. This article is general information, not legal advice; for advice on a specific judgment, consult a qualified lawyer in the country where the assets are. Last reviewed 10 October 2026. For more analysis like this, visit the Corporate INTL newsroom or subscribe to Corporate INTL.