Hague Judgments Convention 2019 enters into force in the UK

On 1 July 2025, the Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil Matters (commonly referred to as the Hague Judgments Convention 2019) entered into force across the UK for proceedings commencing on or after that date. This is a major development in the cross-border enforcement landscape, supporting the recognition and enforcement of English court judgments across a growing set of jurisdictions and vice-versa. This includes all EU member states (except Denmark), Ukraine, Uruguay, and other countries that have ratified the Convention. More countries are expected to join in the future.
 
The Hague Judgments Convention 2019 is an international treaty designed to facilitate the recognition and enforcement of court judgments across borders in civil and commercial cases. It aims to provide a uniform legal framework that enhances legal certainty, reduces costs and delays, and promotes international trade and investment by simplifying cross-border litigation.
 
The Convention applies specifically to judgments in civil and commercial matters but excludes certain areas such as family law, insolvency, intellectual property disputes, competition law, revenue, customs, defamation, privacy, and arbitration-related proceedings. This exclusion is largely because these areas are governed by other international instruments or require specialized treatment.
 
The UK formally ratified the 2019 Judgments Convention on 27 June 2024. The Convention entered into force for the UK on 1 July 2025, applying specifically to England and Wales. The ratification followed the UK's signature of the Convention in January 2024 and subsequent legislative amendments to align UK civil procedure rules with the Convention's requirements.
 
Since Brexit, the UK is no longer covered by the EU's Brussels I Recast Regulation, which previously governed the recognition and enforcement of judgments between EU Member States. The ratification of the 2019 Judgments Convention fills a critical gap in the UK's post-Brexit legal framework for cross-border judicial cooperation, especially with EU countries and other contracting states. Prior to this, recognition and enforcement of UK judgments in EU countries often relied on bilateral agreements or common law principles, which were more complex, costly, and legally uncertain.
 
The Convention offers a streamlined, standardized process that reduces reliance on bilateral treaties and enhances predictability and efficiency for businesses and individuals engaged in cross-border disputes.
 
Practical impact for businesses and legal practice
 
The Convention facilitates the automatic recognition and enforcement of judgments from contracting states without re-examining the merits of the case, provided certain criteria are met. This reduces the time, cost, and complexity of enforcing foreign judgments, encouraging smoother international trade and investment. It provides legal certainty by establishing clear rules and minimum standards for the circulation of foreign judgments among contracting states. Businesses can confidently choose jurisdictions for litigation, knowing that judgments will be enforceable in other member states.
 
The Convention applies only to proceedings commenced on or after 1 July 2025, so it will not affect judgments rendered before this date.
 
Limitations and exclusions
 
The Convention excludes certain matters such as insolvency, intellectual property, arbitration-related disputes, family law, and others. It does not replace or compete with other international treaties like the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, which remains the primary instrument for arbitral award enforcement. Contracting states, including the UK, may opt out of applying the Convention between themselves and other specific states within a 12-month period after ratification, potentially limiting its scope in some bilateral relationships.
 
Summary
 
The UK's ratification of the 2019 Hague Judgments Convention marks a significant development in international legal cooperation post-Brexit. It re-establishes a robust, multilateral framework for the recognition and enforcement of foreign judgments in civil and commercial matters, benefiting businesses and legal practitioners by reducing cross-border litigation risks and costs. The Convention's entry into force on 1 July 2025 should enhance the UK's ability to engage in international commerce with greater legal certainty and efficiency.