Court judgments travel less easily than arbitral awards. Within the EU they circulate almost automatically; the HCCH 2019 Judgments Convention now links the EU and the UK and a small number of other states, but not India, the UAE, Saudi Arabia, Singapore or the United States. Elsewhere enforcement depends on reciprocity statutes, bilateral arrangements or a fresh action, and Gulf courts add attestation and public policy requirements.
Treaties and regional regimes
Between EU Member States, a judgment is recognised without any special procedure and enforced without a declaration of enforceability. The HCCH 2019 Judgments Convention has 33 parties, including the EU and the UK, but it applies only if it was in force between the two states when the proceedings started, and it excludes insolvency, intellectual property, most antitrust matters and arbitration. India, the UAE, Saudi Arabia and Singapore are not listed, and the US has signed but not ratified.
The DIFC Courts point to the GCC Convention, the Riyadh Convention, conventions listed with China, India and France, and reciprocal arrangements with courts in New York, Singapore, London and Hong Kong as routes for their judgments abroad.1234
Reciprocity statutes and fresh actions
The UK registers final money judgments from countries designated under the Foreign Judgments (Reciprocal Enforcement) Act 1933; other judgments generally require separate proceedings. Singapore registers judgments from countries gazetted under its 1959 Act within six years. Germany refuses recognition where reciprocity is not guaranteed. The US has no treaty on judgments; enforcement is a matter of state law and requires a lawsuit.
In the UAE, a foreign judgment to be enforced onshore must be attested by the Ministry of Foreign Affairs and is executed under an execution judge. In Saudi Arabia enforcement has traditionally been slow and may be refused where it conflicts with Sharia, with judgments from GCC and Arab League courts enforced more readily.5678910
| Market | Main route | Condition | Source |
|---|---|---|---|
| Germany, France (EU) | Brussels I recast within the EU; 2019 Convention with the UK | No special procedure within the EU | EUR-Lex; HCCH |
| Germany (other states) | § 328 ZPO | Reciprocity must be guaranteed | gesetze-im-internet.de |
| United Kingdom | 2019 Convention (from 1 Jul 2025); 1933 Act for designated countries | Convention in force when proceedings began; money judgments under 1933 Act | HCCH; legislation.gov.uk |
| Singapore | REFJA registration for gazetted countries | Apply within 6 years | sso.agc.gov.sg |
| United States | State law; new lawsuit | No treaty in force | US State Department |
| UAE (onshore) | Execution judge after MOFA attestation | Conditions in Civil Procedure Code (not reviewed) | u.ae |
| UAE (DIFC judgments abroad) | GCC and Riyadh Conventions; listed conventions; reciprocal arrangements | Depends on the receiving court | difccourts.ae |
| Saudi Arabia | Enforcement courts | May be refused if contrary to Sharia | US State Department |
Decisions to make
- Is there a treaty or reciprocity regime between the court's country and the enforcing country?587Without one, the creditor may need to start fresh proceedings.
- Was the 2019 Convention in force between the two states when proceedings began?32It applies only to proceedings started after it took effect between the states.
- Will the judgment be enforced in the Gulf?910Attestation and public policy, including Sharia in Saudi Arabia, can delay or block enforcement.
- Would an arbitral award travel better?211India, the UAE, Saudi Arabia and Singapore are outside the 2019 Judgments Convention but inside the New York Convention.
Documents usually needed
- Certified copy of the judgment and evidence that it is final and enforceable
- Proof of service on the defendant in the original proceedings
- Certified translations into the enforcing court's language
- Legalisation and Ministry of Foreign Affairs attestation for the UAE
- Evidence of the jurisdiction agreement relied on
Common mistakes
- Assuming a UK judgment is enforced in the EU as it was before Brexit
- Choosing a court whose judgments have no route into the counterparty's country
- Missing Singapore's six-year registration window
- Forgetting attestation for UAE enforcement
- Expecting US enforcement to be automatic under a treaty
Questions businesses ask
Is an English judgment enforceable in Germany now?
For proceedings started after the 2019 Judgments Convention came into force between the UK and the EU on 1 July 2025, it provides a route, subject to its exclusions. Earlier proceedings depend on national law, including German reciprocity rules.237
How is a foreign judgment enforced in the United States?
There is no treaty in force; enforcement is under state law and requires a lawsuit in a competent court.8
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- India's reciprocating territories under section 44A of the Code of Civil Procedure (including the 2020 notification reported for the UAE) could not be confirmed; India Code blocked automated access.
- UAE Civil Procedure Code conditions for recognising foreign judgments could not yet be checked.
- The UK's list of countries designated under the 1933 Act and its 2019 Convention declarations were not reviewed.
- French exequatur procedure for non-EU judgments could not yet be checked on Legifrance.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
A judgment given in one EU Member State is recognised in the others without any special procedure and, if enforceable there, is enforceable in the others without a declaration of enforceability. Regulation (EU) No 1215/2012, Articles 36(1) and 39; applies from 10 January 2015. Civil and commercial matters; arbitration excluded.
The HCCH 2019 Judgments Convention has 33 contracting parties, including the EU and its Member States (in force from 1 September 2023) and the United Kingdom (from 1 July 2025); India, the UAE, Saudi Arabia and Singapore are not listed, and the United States signed on 2 March 2022 without ratifying. Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters. Other parties include Ukraine, Uruguay, Albania, Montenegro and Andorra.
The status table showed a last-updated date of 13 May 2025 while listing later entry-into-force dates; recheck before relying on it.
The 2019 Judgments Convention applies only if it was in effect between the state of origin and the requested state when the original proceedings were started, and it excludes matters including insolvency, intellectual property, defamation, privacy, most antitrust matters and arbitration. Article 16 (transitional) and Article 2 (exclusions). Applies to civil or commercial judgments, not revenue, customs or administrative matters.
Reused from gb-disputes-g15.
The DIFC Courts state that their judgments can be enforced abroad through treaties such as the GCC Convention and the Riyadh Convention, conventions listed with China, India and France, and reciprocal arrangements with commercial courts including those in New York, Singapore, London and Hong Kong. DIFC Courts enforcement page; the page notes that these routes do not apply to the ratification or recognition of arbitral awards.
The page names the conventions with China, India and France without quoting them; how an Indian court treats a DIFC judgment was not confirmed on an Indian source.
Under the Foreign Judgments (Reciprocal Enforcement) Act 1933, money judgments of recognised courts in countries designated by Order in Council for reciprocity can be registered in the UK if final and conclusive, but not judgments for taxes, fines or penalties. Applies only to countries covered by an Order in Council; judgments from other countries generally require separate proceedings.
The list of designated countries, the Administration of Justice Act 1920 regime and common-law enforcement were not confirmed. Reused from gb-disputes-g17.
Under the Reciprocal Enforcement of Foreign Judgments Act 1959, the Minister may by order in the Gazette extend the registration regime to a foreign country where substantial reciprocity is assured, and a judgment creditor may apply to the General Division of the High Court to register a covered judgment within 6 years of the judgment. Covers money and non-money judgments, including consent judgments and judicial settlements; non-money judgments are registered only where enforcement is just and convenient, or for a monetary equivalent. Foreign judgments that can be registered cannot be enforced otherwise (section 7).
Corrected and narrowed. The 1 March 2023 transfer of Commonwealth judgments into this Act, and the need for a fresh common-law action on judgments from non-gazetted countries, were not stated on the page and are not claimed. The Choice of Court Agreements Act 2016 is now a separate claim (sg-disputes-g04). Reused from sg-disputes-007.
German law refuses recognition of a foreign court judgment where reciprocity is not guaranteed, as well as for lack of jurisdiction under German rules, defective service on a defendant who did not appear, conflicting judgments or manifest incompatibility with essential principles of German law. § 328(1) ZPO, Nr. 1 to 5; applies where no EU regulation or treaty governs.
There is no bilateral treaty or multilateral convention in force between the United States and any other country on recognition and enforcement of court judgments; enforcement of foreign judgments in the United States is governed by state law and requires a lawsuit in a competent court. State law. Courts apply principles including comity, reciprocity and res judicata; many states have adopted a uniform recognition act, which was not confirmed on this page.
Reused from us-disputes-007.
To enforce a judgment issued abroad, the original judgment must be attested by the UAE Ministry of Foreign Affairs, and judgments are executed under the supervision of an execution judge at the Court of First Instance. Onshore courts; recognition conditions are in the Civil Procedure Code and were not reviewed.
Reused from ae-disputes-009.
Enforcement of foreign arbitral awards and foreign judgments has traditionally been time-consuming, and enforcement may be refused where it conflicts with Sharia principles; judgments from GCC and Arab League courts are enforced somewhat more readily.
Secondary (foreign government) source; the official Saudi text could not yet be checked run. Reused from sa-disputes-007.
The New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards has 172 parties. Count shown on the UNCITRAL status page when checked; all eight main markets are parties.
Saudi Arabia's entry carries only the reciprocity declaration; the UAE entry shows no declarations.
Questions on this topic
10 statements on enforcing foreign judgments
