Comparison

Court fees for enforcing a foreign judgment

This page compares court fees charged for enforcing a foreign judgment across the jurisdictions where the firm holds verified figures. It is not a fee estimate for a specific claim. Some jurisdictions cap the fee regardless of judgment size. Others charge a percentage or a value-based scale with no ceiling. That structural difference, not the headline number, decides which route costs less once a judgment runs into millions. See how foreign judgment enforcement is organised across the jurisdictions this firm tracks.

What is being compared

Four different amounts sit under one heading, and each attaches to a different act. A fee for recognition of a foreign judgment attaches to the recognition claim itself, often tariffed by the value of that claim (DIFC, Germany, Portugal, Malta). A fee for enforcement attaches to the enforcement application once recognition is granted, and is frequently a percentage of the judgment sum (Dubai Courts, DIFC, ADGM). A fee for appeal or review of either decision sits on its own scale (Spain, the onshore UAE courts). Security for costs, where a court can order a deposit against the claimant's own costs exposure, is not a fee at all but a contingent risk (ADGM). A non-payment case of this kind falls under refusal type O8, and the figures below assume recognition and enforcement are scoped as separate stages of the cross-border recognition and enforcement work this firm handles.

The comparison

• Dubai Courts (onshore UAE): execution fee of 2% of the amount on the writ of execution [N535]; review fee at 25% of the first-instance fee, appeal fee at 50%, appellant deposit 1,000 AED [N536].
• DIFC Courts: recognition of a foreign judgment is tariffed as a Part 7 claim, by value [N538]. Enforcement of a judgment issued outside DIFC: 1% of judgment value, minimum 100 USD, capped at 20,000 USD [N537]. Enforcement of DIFC's own judgments: Part 48 RDC application, 300 USD; Part 45 ENF application, 100 USD [N539].
• ADGM Courts: enforcement of a judgment issued outside the UAE: 2% of judgment value, minimum 100 USD, capped at 3,000 USD [N540]. Enforcement applications: Rule 250(1), 500 USD; Rule 250(2)/251(3), 3,000 USD; Writ of Control, 100 USD [N541]. Security for costs is available at the court's discretion, not as a fixed fee [N542].
• England and Wales: claim fee on the money-claim scale, capped at 10,000 GBP for claims above 200,000 GBP [N543]; writ and warrant of control charged at fixed enforcement rates [N544].
• Cyprus: claim fee on a sliding scale by value, roughly 48 EUR for the 1-8,550 EUR band [N546]. The fee sits inside one specific corridor on the Cyprus to UK enforcement route.
• Malta: recognition application fee, typically under 100 EUR [N548].
• Spain: individuals are exempt from court fees [N549]. Legal entities pay a fixed first-instance fee, around 300 EUR for ordinary proceedings and 200 EUR to oppose enforcement [N550]. The fixed appeal fee (800 EUR), cassation fee (1,200 EUR) and the variable quota for legal entities were declared unconstitutional and do not apply [N551].
• Portugal: revisão e confirmação fee, one UC unit equals 102 EUR, roughly 306 EUR unopposed and 612 EUR if opposed, paid in two instalments [N552].
• Germany: exequatur claim fee, a fixed charge under fee table position 1510 [N553].
• Netherlands (2026 scale, legal entities): undetermined value, 735 EUR; up to 100,000 EUR, 3,083 EUR; 100,000-1,000,000 EUR, 7,062 EUR; above 1,000,000 EUR, 10,487 EUR [N554].
• Luxembourg: no proportional court fee system; the dominant costs are the bailiff and the lawyer, not a court tariff [N556].
• United States: filing fees are fixed, not scaled to the value of the claim [N557].

Where the spread bites

The caps at DIFC (20,000 USD) and ADGM (3,000 USD) mean a judgment in the millions costs a few thousand dollars to enforce through either court. The same judgment enforced through onshore Dubai courts at an uncapped 2% costs proportionally far more. The Netherlands' top band works the same way in reverse: above 1,000,000 EUR the fee stops climbing and sits flat at 10,487 EUR, so it behaves like a soft cap even though the scale is nominally proportional. Luxembourg removes the variable altogether, shifting the real cost driver to the bailiff and the lawyer.

For a large judgment, which gateway recognises it can matter more than the fee schedule of the court that eventually enforces it. That choice sits upstream of the fee question and is covered in the broader set of O8 insights, including the mechanics discussed where the underlying asset was held in a crypto account and the judgment went unpaid.

What is not established

• The jurisdiction lists for the 1920 and 1933 statutory recognition schemes, and the list of US states that have adopted UFCMJRA, are not reproduced on this page.
• Where a jurisdiction is not named above, the fee amount is to be confirmed at the time of filing rather than assumed from a comparable jurisdiction.
• Fee schedules change. The figures above carry the source and status shown against each entry, and none of them substitute for checking the current tariff on the filing date.

This firm does not work on a contingency-only basis, and its registration can be checked against the public register. See how to verify a law firm before relying on any figure quoted here, and the privacy policy sets out how information you send is handled.