Post-Brexit judgment enforcement for France, Germany and Italy - An overview Q&A

At the end of the transitional period on 31 December 2020, the final so-called “Brexit” occurred: the United Kingdom officially left the European Union. As a result, it became unclear which, and to what extent, European regulations are still applicable. This ambiguity occurred also with respect to the cross-border recognition and enforcement of judgments. 

The current status is that, on 12 February 2024, the UK signed the Hague Convention of 2019 regarding the Recognition and Enforcement of Foreign Judgments in Civil and Commercial Matters (hereafter referred to as the “2019 Hague Convention”), and announced that it will ratify it as soon as possible. Once ratified, the 2019 Hague Convention will come into force after a period of 12 months, i.e. not before 2025. 

In the Q&A, we take a closer look at the consequences for enforcement law in France, Italy and Germany after Brexit and before the ratification by UK of the 2019 Hague Convention.