Cross-border enforcement

Enforcing a Germany judgment in United Kingdom

A German judgment does not enforce in the United Kingdom automatically. Since Brexit removed the EU route, only three paths apply: Hague 2019 for proceedings started in Germany from 1 July 2025, Hague 2005 for exclusive jurisdiction clauses, or a fresh common law claim on the debt. Which one applies depends on when the German case began and how the contract chose its court.

Applicable regime

Brussels Ia and Lugano no longer apply between Germany and the United Kingdom. Both fell away for the UK after Brexit [N124]. For the wider picture of what replaced them, see enforcement routes into the United Kingdom.

Hague 2019 entered into force for the European Union, including Germany, on 1 September 2023, following the EU's accession on 29 August 2022 [N003][N154]. For how Germany's own outbound position looks across other destinations, see outbound enforcement from Germany. The United Kingdom applies this convention to proceedings instituted in Germany from 1 July 2025 onward [N120]. The convention only reaches a judgment if it was already in force between Germany and the UK when the German proceedings began [N012]. The convention's precise scope for the United Kingdom depends on declarations it has lodged, which have not been resolved as of the review date.

Hague 2005 survived Brexit separately and covers only judgments arising from exclusive choice-of-court agreements [N121]. Outside both conventions, the route is a common law action treating the German judgment as a debt [N123]. Detail specific to this jurisdiction sits in the UK jurisdiction profile.

What the destination court will check

These conditions apply cumulatively. Missing one blocks the whole route.

• The judgment falls within a civil or commercial matter; tax, customs and administrative decisions are excluded [N013].
• The German proceedings that produced the judgment started within the convention's temporal window running between Germany and the UK [N012].
• A judicial settlement approved by a German court, or reached during proceedings and enforceable there, is admitted on the same footing as a judgment [N014].
• Which body actually applies these tests depends on the applicable procedural rules; the competent authority is determined by that rule, not fixed in advance.

What will not go through

Tax, customs and administrative judgments fall outside Hague 2019 entirely [N013]. A judgment from proceedings instituted in Germany before the applicable dates cannot use the convention route [N012][N120]. Non-enforcement of this kind is treated by the firm as its own category, covered separately at non-enforcement as a refusal type.

Non-exclusive jurisdiction clauses are a trap under Hague 2005, which only accepts exclusive choice-of-court agreements [N121]. Hague 2019 carries no such restriction and does not require the jurisdiction clause to be reciprocal, so it can reach asymmetric clauses that Hague 2005 would exclude [N015]. A contract drafted with an asymmetric clause may qualify under one convention and fail under the other.

Documents

The Apostille Convention applies to documents destined for use in the United Kingdom, in force there since 24 January 1965 [N403]. A German judgment authenticated with an apostille does not need a full consular legalisation chain to be produced in UK proceedings. Documents in German will still need translation before a UK court will accept them.

Timing

A claim to recognise a foreign judgment in the UK is subject to a six-year limitation period, running from the date the judgment became enforceable in Germany [N500]. Under the statutory regime the same six years runs from the date of the judgment, or from the last decision on appeal [N501]. A foreign arbitral award carries the same six-year period, treated as a claim on a simple contract [N502]. Comparable periods for other jurisdictions are set out at limitation periods across jurisdictions.

Where that period has already passed, section 24 limitation does not apply to bankruptcy or liquidation proceedings founded on the judgment debt, which can remain a route [N503].

If the primary route is closed

Where none of the treaty routes fit, a common law action on the debt remains open regardless of which convention applies [N123]. Whether a separate statutory recognition scheme also covers this specific pair has not been confirmed; that has to be checked case by case rather than assumed.

Recognition through a third jurisdiction where the debtor holds assets is a separate exercise, governed by that jurisdiction's own rules, not by anything settled here. The reverse direction, enforcing a UK judgment in Germany, follows different conditions entirely and is treated at the reverse route from the UK into Germany. For future contracts, an arbitration clause routes disputes through the New York Convention instead, which reaches further than any court-to-court mechanism used for this judgment [N016].

What to do before filing

Before filing, confirm the debtor still holds assets in the United Kingdom and that nothing has moved out of reach already. A dormant company or a recently sold property changes the calculation. Background on how these gaps appear is at insight on non-enforcement patterns.

Filing fees on a money claim scale reach £10,000 for claims over £200,000; enforcement stages such as a writ or warrant of control carry separate fixed fees [N543][N544]. Interim relief before judgment depends on the case; availability is not assumed either way. This falls under the firm's cross-border recognition and enforcement service.

The firm does not charge a fee contingent solely on recovery, and its registration can be checked against the public register.