Enforcing your judgment against someone abroad
A judgment of the County Court of England and Wales has direct legal effect only within England and Wales. To enforce it elsewhere — Scotland, Northern Ireland, Spain, Australia — you need either a reciprocal enforcement regime that allows you to register the judgment in the foreign court, or a fresh action in the foreign court suing on the English judgment as a debt.
Enforcing your judgment against someone abroad
The general principle
The route depends entirely on which country the assets are in. After Brexit, the previously routine Brussels Regulation route into the EU is no longer available for most new judgments. Instead, several layered regimes apply, none of them universal. The result is that cross-border enforcement is more complicated and more expensive than it was before 2021.
Before commencing any cross-border action, do a hard cost-benefit analysis. Translations, foreign-lawyer fees, certified copies, apostille certifications, and local court fees can easily exceed £2,000 even for a straightforward registration. For most small-track judgments, the answer is to focus on UK-based assets the defendant retains, or to write the debt off.
The main reciprocal regimes
| Jurisdiction | Regime | Notes |
|---|---|---|
| European Union | Brussels (post-Brexit) | The UK is no longer party to the Brussels I Recast Regulation. Pre-2021 judgments may still be enforceable under the previous regime; post-2021 judgments depend on the Hague Conventions or local procedure. |
| Republic of Ireland | Foreign Judgments (Reciprocal Enforcement) Act 1933 | Limited reciprocal regime. Most UK judgments require fresh proceedings in the Irish High Court rather than registration. |
| Hague Convention 2005 states | Hague Choice of Court Convention 2005 | Covers judgments arising under exclusive choice-of-court agreements between businesses. The UK acceded in its own right in 2021. |
| Hague Convention 2019 states | Hague Judgments Convention 2019 | A broader recognition regime now in force between the UK, EU member states (excluding Denmark), and Ukraine for judgments given in proceedings begun on or after 1 July 2025. |
| Commonwealth countries | Administration of Justice Act 1920 | Australia, Canada (not Quebec), Hong Kong, Singapore, India, and others. UK judgments registered as if rendered locally. |
| Other reciprocal states | Foreign Judgments (Reciprocal Enforcement) Act 1933 | A narrow list — Israel, Norway, Tonga among others — listed in orders made under the 1933 Act. |
| Other countries | Common law action on the judgment | Where no statute applies, you must sue in the foreign country on the English judgment as a debt. The local court decides whether to recognise it. |
Step one is to obtain a sealed copy of the judgment from the issuing court along with a Certificate of Judgment if the relevant regime requires it. Many regimes also require an apostille — a certified authentication for use in another Hague Convention country, available from the Foreign, Commonwealth and Development Office for around £45 per document.
Step two is translation. Most non-English-speaking jurisdictions require a certified translation of the judgment, the certificate, and any supporting documents. Costs vary widely — typically £100–£500 per document.
Step three is application to the foreign court. The procedural rules vary by country. In most reciprocal jurisdictions, registration is administrative and takes 4–12 weeks. In jurisdictions requiring fresh proceedings, you face a full new action with attendant costs and delays.
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Enforcement overview