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Key takeaways
- From today, 1 July 2025, the Hague Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters (the Convention) applies in the United Kingdom.
- The Convention will govern the recognition and enforcement in England and Wales, Scotland and Northern Ireland of judgments obtained in proceedings commenced on or after 1 July 2025 in any other Contracting State, and vice-versa.
- Amendments to Part 74 of the Civil Procedure Rules, designed to give effect to the Convention in England and Wales, also take effect today.
For a detailed analysis of the Convention’s scope, eligibility requirements and grounds for refusal, please refer to our earlier client alert, “Simplifying enforcement: UK ratifies the 2019 Hague Judgments Convention” (July 2024).
What this means in practice
The Convention now offers UK-based businesses a streamlined, treaty-based route to enforce qualifying judgments in several jurisdictions, including the EU27 (except Denmark), Ukraine and Uruguay.
Since our earlier client alert, Kosovo has signed the Convention, Andorra has acceded to the Convention (it will come into force in Andorra on 1 June 2026) and both Albania and Montenegro have ratified it (with the Convention coming into force in both countries on 1 March 2026). Furthermore, the UK has deposited a declaration confirming that the Convention extends to all three UK jurisdictions (England and Wales, Scotland and Northern Ireland).
For eligible judgments, the Convention will replace existing common-law regimes, domestic laws and bilateral treaties, reducing both cost and uncertainty.
Commercial parties litigating cross-border disputes should:
- Check start dates. Only judgments arising from proceedings instituted on or after 1 July 2025 qualify.
- Audit dispute-resolution clauses. Where exclusive jurisdiction clauses are used, the 2005 Hague Choice of Court Convention may remain the primary instrument; in other cases, the 2019 Convention now fills many of the post-Brexit gaps.
- Monitor new developments. The Convention’s reach is expanding. With notable signatories such as Russia and the U.S., further signatories, accessions and ratifications are expected.
Client Alert 2025-170