Enforcement of foreign judgments: how to collect when your customer is abroad

Enforcing a judgment abroad in short

Whether a court judgment against a business customer can be enforced in another country depends on where the judgment was given and where the debtor's assets are. Within the EU, a judgment from one member state is enforceable in the others without any declaration of enforceability (Brussels Ia, Regulation (EU) No 1215/2012, article 39). Between the EU, Switzerland, Norway and Iceland, the 2007 Lugano Convention applies. The 2019 Hague Judgments Convention links the EU with the UK (since 1 July 2025), Ukraine, Uruguay and a few others. The US has no judgment treaty with any country: recognition there is a matter of state law.

In every case, enforcement itself happens under the law of the country where the assets are, through its courts and enforcement agents. Below is a decision table, the rules for each regime with dates, and why many creditors collect pre-legally in the debtor's country before, or instead of, enforcing a home judgment. This guide is general information, not legal advice.

Which rules apply: a decision table

Dates and parties change. The 2019 Convention status table and 2005 Convention status table at the Hague Conference show who is bound and from when.

Inside the EU: Brussels Ia, no exequatur

For legal proceedings started on or after 10 January 2015 (article 66), Brussels Ia applies between the EU member states:

• A judgment given in one member state is recognized in the others without any special procedure (article 36).
• If it is enforceable where it was given, it is enforceable in the other member states without a declaration of enforceability (article 39).
• To enforce, you give the enforcement authority a copy of the judgment and the certificate that the court of origin issues on request (articles 42 and 53). A translation can be required (article 37).
• The debtor can apply for refusal only on limited grounds: public policy, no proper service of a default judgment, an irreconcilable judgment, or a breach of the protective rules for consumers, employees and insurance (article 45).

Denmark is not bound by Brussels Ia itself; it takes part in the EU rules through a 2005 agreement with the EU (recitals 8 and 41), so check how they apply to a Danish case. For undisputed money claims, two EU procedures give you an enforceable title without a full trial: the European payment order and the European Small Claims Procedure for claims up to €5,000.

The Hague conventions: 2005 and 2019

The 2019 Hague Judgments Convention covers the recognition and enforcement of judgments in civil or commercial matters between contracting states (article 1). Recognition can be refused only on the grounds in the Convention, and the court of enforcement does not review the merits (article 4). It applies only if, when the proceedings were started in the state of origin, the Convention already had effect between that state and the state of enforcement (article 16). According to the HCCH status table, it is in force for:

The United States signed the 2019 Convention on 2 March 2022 but has not ratified it, so it is not in force for the US.

The 2005 Hague Choice of Court Convention applies when the contract has an exclusive choice of court agreement. It applies to agreements concluded after the Convention entered into force for the state of the chosen court (article 16). Parties include the EU (since 1 October 2015), Denmark (1 September 2018), the United Kingdom (1 October 2015), Mexico, Singapore, Montenegro, Ukraine, Moldova, Albania, North Macedonia, Bahrain, Switzerland (1 January 2025) and Monaco (1 March 2026), according to the HCCH status table. The US and China have signed but not ratified it.

Switzerland, Norway and Iceland: the Lugano Convention

The 2007 Lugano Convention, signed on 30 October 2007 by the European Community, Denmark, Iceland, Norway and Switzerland, extends rules similar to the EU's to those countries (Brussels Ia, recital 8). Unlike Brussels Ia, a judgment is enforced in another Lugano state only once it has been declared enforceable there on application (Lugano Convention, article 38).

The UK applied to join after Brexit. On 28 June 2021 the European Union notified the depositary that it was not in a position to give its consent to invite the UK to accede (Swiss Federal Council, 1 July 2021), so the Convention does not apply between the UK and the EU, Switzerland, Norway or Iceland.

The UK after Brexit

At the end of the transition period (11pm on 31 December 2020) the UK revoked Brussels Ia and its predecessors as they applied in the UK, ended the effect of the Lugano Convention 2007 in the UK, and kept those rules only for cases already ongoing (UK Ministry of Justice). Since then:

• Proceedings started from 1 July 2025: judgments between the UK and EU countries (except Denmark) can be enforced under the 2019 Hague Judgments Convention (HCCH).
• Exclusive choice of court agreements: the 2005 Hague Convention has applied to the UK without interruption since 1 October 2015.
• Everything else: the common law, or a bilateral arrangement with the country concerned, such as the Foreign Judgments (Reciprocal Enforcement) Act 1933 for the countries it covers (legislation.gov.uk). In practice that means a new claim on the judgment in the other country's courts or an exequatur under its national law.

For a UK creditor with a customer in the EU, the date the proceedings started now decides a lot. A claim issued before 1 July 2025 does not benefit from the 2019 Convention.

The United States: no treaty, state law

The US Department of State puts it plainly: there is no bilateral treaty or multilateral convention in force between the United States and any other country on reciprocal recognition and enforcement of judgments, and enforcement of foreign court judgments in the US is governed by the laws of the states (U.S. Department of State).

• A foreign judgment against a US business has to be recognized by a court in the state where the debtor or its assets are. The Uniform Law Commission publishes a model law for this, the Foreign-Country Money Judgments Recognition Act (2005), which replaced its 1962 act; in states that have enacted it, its rules decide recognition. Check the law of the state concerned.
• A US judgment against a business abroad is recognized under the law of the other country, because no treaty applies. Many countries require local proceedings first.

For a US debtor, the practical first step is usually collection by a partner in the US, not enforcement of a foreign judgment. See debt collection in the United States and the commercial collection agency guide.

Cost and time: what to expect

There is no single figure for enforcing a judgment abroad, and anyone who quotes one without seeing the case is guessing. The cost and time depend on:

• The regime. Under Brussels Ia you go straight to the enforcement authority; under Lugano, the Hague 2019 Convention or national law you first need a court decision in the country of enforcement.
• Translations and certificates. The certificate, sometimes the judgment, and the service documents may need certified translations.
• A local lawyer or enforcement agent. Enforcement is local work, done by professionals in the debtor's country at local rates.
• The debtor. Whether there are assets to seize, and whether the debtor challenges recognition.

Ask for a written quote from a lawyer in the debtor's country before you start, and compare it with the amount you can realistically recover.

Often faster: a local partner in the debtor's country

A judgment at home gives you a title. It does not make a business abroad pay. Many creditors get further by starting where the debtor is: a local partner contacts the debtor in its language, under its law, and escalates locally if needed, without first winning at home and then enforcing abroad.

• Debitura matches your case to a vetted local partner in the debtor's country, in 180 countries, based on the type of debtor, the claim and how partners perform on our platform.
• Pre-legal collection of undisputed unpaid invoices runs under one Standard Debt Collection Agreement, with no upfront cost: you pay a success fee only when money is recovered. Fees are from 6% in Europe and 7.5% elsewhere, depending on claim size and the debtor's country (see your fee).
• Legal action, including enforcing a judgment you already have, is optional, quoted separately by the partner and only starts if you accept the quote.

A judgment does not help against a debtor with no assets or in insolvency proceedings, which follow their own rules. See how it works, debt collection in Europe, B2B debt collection explained and how to collect a debt from a business customer abroad. Country pages explain the local process, for example the United Kingdom, Germany, Switzerland and Norway.

Checklist before you enforce abroad

1. Where are the debtor's assets? Enforce there, not where the debtor is registered if the money is elsewhere.
2. When were the proceedings started, and in which court? That decides whether Brussels Ia, Lugano or the Hague 2019 Convention applies.
3. Does your contract have an exclusive choice of court clause? Then check the 2005 Hague Convention. See retention of title and other clauses for the clauses that make enforcement easier.
4. Is the judgment enforceable where it was given? Most regimes require it.
5. Do you have the documents: a certified copy, the certificate or declaration, proof of service, translations?
6. Is the claim still within the limitation period for enforcement in that country? See limitation periods by country.
7. Would collection in the debtor's country get you paid sooner? Compare it with the enforcement quote. For the full set of country pages, see Europe. For the interest you can add, see late payment interest by country.