As of 1 July 2025, following its ratification in June 2024, the UK officially becomes a contracting party to the 2019 Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters.
This marks a key milestone in the UK’s post-Brexit legal landscape, strengthening cross-border cooperation and simplifying the enforcement of court judgments between the UK, the EU, and other signatory states.
What is the Hague Judgements Convention?
The 2019 Hague Convention provides a uniform legal framework for recognising and enforcing civil and commercial judgments across member countries. It eliminates the need to re-litigate cases in foreign jurisdictions, allowing judgments issued in one country to be enforced in another via a simplified registration process.
This is particularly relevant for businesses engaged in international trade and contracts, where swift and reliable enforcement of court decisions is essential.
Key Advantages for Commercial Parties
UK businesses currently face delays and added complexity when seeking to enforce judgments abroad. The Convention addresses this by offering a clearer, more consistent approach, helping reduce legal costs, uncertainty, and duplication of proceedings.
Legal Certainty and Efficiency
The Convention provides UK companies and consumers with increased confidence that UK court judgments will be recognised and enforced in other contracting states—and vice versa. This predictability encourages cross-border trade, investment, and dispute resolution.
Bridging the Post-Brexit Enforcement Gap
Since leaving the EU, the UK has no longer been part of the Brussels Recast Regulation ve Lugano Convention, which previously facilitated enforcement across the EU and EFTA states. The 2019 Hague Convention fills much of this void, although it does not govern jurisdiction allocation.
Support for Commercial Dispute Resolution
The new Convention complements the 2005 Hague Convention on Choice of Court Agreements, extending enforcement protections to non-exclusive jurisdiction agreements. This strengthens the UK’s attractiveness as a forum for resolving international dispute.
Cost and Time Savings
Particularly beneficial for SMEs, the Convention is expected to reduce legal fees and delays in enforcing foreign judgments, improving access to justice and facilitating debt recovery in cross-border transactions.
Challenges and Limitations
Limited Scope and Exclusions
The Convention applies only to specific civil and commercial matters. It excludes areas such as family law and certain personal injury claims, meaning some cases will still require traditional enforcement mechanisms.
Concerns Around Judicial Standards
Recognising judgments from countries with lower judicial transparency or fairness raises potential concerns. The UK government has stated it will actively monitor new members joining the Convention and may issue declarations to restrict enforcement where necessary.
No Rules on Jurisdiction Allocation
The Convention does not determine which country’s courts should hear a dispute. Questions of jurisdiction will continue to be resolved under national laws or other international agreements.
Sonuç
The UK’s accession to the 2019 Hague Judgments Convention is a major advancement in re-establishing international legal cooperation after Brexit. It introduces a clearer and more efficient system for cross-border enforcement of civil and commercial judgments, benefiting UK businesses, consumers, and the broader legal sector.
While some limitations remain—such as exclusions in scope and concerns over fairness in certain jurisdictions—the Convention is expected to strengthen the UK’s position as a preferred venue for dispute resolution and promote smoother global trade and investment.
If you require any assistance in relation to enforcing a foreign judgment in the UK or a judgment outside of the UK, please contact Partner Jonathan Chan at J.Chan@rfblegal.co.uk.
Jonathan Chan
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