Which route applies to your judgment
The route depends on where the judgment was given and when the original proceedings began:
- The Hague Judgments Convention 2019. For proceedings started on or after 1 July 2025 in a participating state, including the EU member states, judgments can be recognised and enforced under the Convention.
- Registration under the 1920 and 1933 Acts. Judgments from many Commonwealth and reciprocal countries can be registered in the High Court through a relatively quick procedure.
- The Hague Choice of Court Convention 2005. This can apply where the contract contained an exclusive jurisdiction clause in favour of a participating state's courts.
- A claim on the judgment at common law. Where no treaty or statute applies, as with judgments from the United States, a fresh claim is brought on the foreign judgment, usually followed by an application for summary judgment.
EU judgments in proceedings started before the end of 2020 may still fall under the old rules. Because the routes differ in speed and cost, we confirm the correct one at the outset.
Arbitral awards
Arbitral awards made in countries that are party to the New York Convention can be recognised and enforced in England and Wales under the Arbitration Act 1996. The grounds for resisting enforcement are narrow, such as serious procedural unfairness or public policy, so a valid award is usually enforced. Once recognised, the award is enforced like an English judgment.
Common questions
How long does registration take?
Registration applications are usually made without notice to the debtor and can be granted within weeks. The debtor then has a set period to apply to set the registration aside.
Can the debtor challenge enforcement?
Only on limited grounds, such as lack of jurisdiction, fraud or a breach of natural justice. The English court does not re-hear the merits of the case.
Do I need a translation?
Yes, where the judgment or award is not in English. A certified English translation is required, and we can arrange one.
Need a foreign judgment or award enforced in the UK? Request a call back using the form. International callers can reach us on +44 1482 616 616, US callers on 1 (917) 338 0244, and UK callers on 0800 037 1305.
