The Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters (Hague 2019) came into force on 1 July 2025 in the UK.

Hague 2019 provides a uniform framework for the recognition and enforcement of judgments between the UK and the other contracting states, which currently include all EU member states (except Denmark), Uruguay and Ukraine. The coming into force of Hague 2019 will therefore facilitate the enforcement of English judgments in other Hague 2019 contracting states and vice versa.

English judgments are currently enforceable under the Hague 2005 Convention on Choice of Court Agreements (Hague 2005), which includes all EU member states (as well as Mexico, Singapore, Montenegro, Ukraine, Moldova, Albania, Switzerland, North Macedonia and Bahrain),  but only where there is an exclusive English jurisdiction clause. Otherwise, the question of enforceability depends on whether there is a reciprocal arrangement for the enforcement of judgments between the UK and the relevant state, such as via a relevant bilateral treaty or (failing that) the relevant state’s national rules on the enforcement of foreign judgments.

Hague 2019 allows for a much broader range of judgments to be enforced. In particular, it provides for the enforcement of a judgment given by a court designated in an agreement between the parties on jurisdiction, where the dispute falls within a non-exclusive or asymmetric jurisdiction clause, as well as in a wide range of scenarios where there is no applicable jurisdiction clause. It is also wider in scope than Hague 2005, applying for example to employment and consumer contracts.

For a more detailed analysis of Hague 2019, including when it will apply, what judgments are eligible for enforcement and when enforcement can be refused, see our disputes colleagues’ blog post here. Their quick reference guide will also help determine whether and how an English court judgment may be enforced in another country. 

 

 

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