In July 2025, the Hague Convention “On the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters” of 2019 came into effect in the UK. The Convention presents an efficient mechanism of recognition and enforcement of judgments between the contracting countries. In accordance with the preamble, it will facilitate access to justice and enhance chances of recovery in cross-border transactions for international market participants.
The Convention effectively abandons the need for review of the underlying disputes when enforcing judgments from countries different from where it is being implemented. Providing that the court has passed its decision within its powers as defined by the rules of jurisdiction, the grounds for refusal of enforcement of such judgments are limited to very few reasons outlined in Article 7 of the document.
The Convention, however, explicitly excludes judgments in a number of areas, which still remain subject to an exclusive jurisdiction, special scrutiny, or different rules for the enforcing courts. Among these are matters arising from insolvency, intellectual property, defamation, privacy, competition law, family law, carriage of passengers and goods and arbitration-related judgments.
In addition to the UK, other countries that have joined this agreement include EU nations (except Denmark), Ukraine, and Uruguay.
Overall, the adoption of this convention marks an important step in providing greater certainty and predictability for businesses and individuals engaged in international legal matters, making cross-border enforcement of obligations more definitive.