The Hague Judgments Convention: What the UK’s 2025 Accession Means for Cross-Border Enforcement

The Hague Judgments Convention, which was finalised on 2 July 2019, has been in force in the EU (other than Denmark) and Ukraine since 1 September 2023, but only came into force here in the UK on 1 July 2025.

The Convention provides a unified framework for the enforcement of judgments in civil and commercial matters between contracting states. It does so by obliging such states to recognise and enforce each other’s judgments.

Though this is subject to specific defences such as public policy, fraud, and insufficient notice, it should facilitate an easier enforcement process on a broader scale than was previously the case. It will avoid a claimant having to navigate the national laws of the country where enforcement is to be carried out, which can render the enforcement process unpredictable, time-consuming, and expensive.

Specified matters are indeed excluded from the remit of the Hague Judgments Convention, including those relating to defamation, intellectual property, insolvency, and arbitration.

However, for those judgments contained within the scope of the Convention, the enforcing contracting state is not allowed to review its merits, and recognition and enforcement can only be declined based on the defences referred to above, which are specified in the Convention itself.