In July 2025, the Hague Convention On the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters (2019) came into effect in the United Kingdom. The Convention introduces a streamlined mechanism for recognising and enforcing judgments between contracting states, aiming to make cross‑border recovery more accessible and predictable for international market participants.
A Simplified Enforcement Mechanism
A key feature of the Convention is the removal of any requirement to re‑examine the underlying dispute when enforcing a foreign judgment. As long as the issuing court acted within its jurisdiction — as defined by the Convention’s rules — enforcement may only be refused on a narrow set of grounds listed in Article 7. This significantly reduces procedural uncertainty and limits the scope for objections.
Matters Outside the Convention
The Convention does not apply to several categories of disputes that remain subject to exclusive jurisdiction or special procedural regimes. These include insolvency, intellectual property, defamation, privacy, competition law, family matters, carriage of passengers and goods, and arbitration‑related judgments. These areas continue to rely on domestic rules or other international instruments.
Impact on Ukraine–UK Judicial Cooperation
Both Ukraine and the UK are contracting states to the Convention, alongside EU member states (except Denmark) and Uruguay. Their participation establishes a shared legal framework for recognising and enforcing civil and commercial judgments.
Because refusal grounds are limited and courts no longer revisit the merits of the dispute, cross‑border enforcement between Ukraine and the UK becomes more predictable and procedurally efficient. This alignment enhances judicial cooperation and reduces the complexity traditionally associated with enforcing judgments across these jurisdictions.
As Ukraine and the UK now operate under the same enforcement mechanism, parties increasingly benefit from guidance that accounts for the procedural nuances of both systems. My dual qualification in Ukraine and the UK allows me to assist with jurisdiction assessment, enforcement strategy, and practical risks with clarity and precision.
A More Certain Cross‑Border Landscape
Overall, the Convention marks a significant step toward greater certainty and predictability for businesses and individuals engaged in international legal matters. By harmonising enforcement rules and limiting refusal grounds, it makes cross‑border enforcement of obligations more definitive and strategically manageable.
If you’re assessing enforcement options under the Hague Convention 2019, contact me to evaluate jurisdiction, refusal grounds, and cross‑border recovery prospects — supported by dual Ukraine–UK qualification and practical experience in foreign judgment enforcement.
✒️By Olena Sadovets, Dual‑Qualified Advocate (Ukraine) & Solicitor (England & Wales)