Comparison

Limitation periods for enforcing a foreign judgment or award

Limitation periods for enforcing a foreign judgment or arbitral award are not one number. They range from three years to thirty, and the period that applies depends on what exactly is being enforced and in which jurisdiction, a question covered across our wider review of enforcement of foreign judgments and awards. A judgment enforceable in Germany or Luxembourg carries thirty years to enforce the underlying right. An arbitral award enforced under the US Federal Arbitration Act carries three years from the date of the award. No single figure applies across borders.

What is being compared

Three different things get called a limitation period in this area, and they are not interchangeable. One is the period to apply for recognition or exequatur of a foreign decision. Another is the period attached specifically to a foreign arbitral award, treated differently from an ordinary judgment in several jurisdictions. A third is the period to enforce the underlying right once a judgment or award has already been recognised, often called the executory period.

The comparison below states which of these three periods each registry entry actually covers. A row giving thirty years for enforcing a judgment-confirmed right says nothing about the time allowed to bring the recognition claim itself. This refusal type sits under failure to enforce a foreign judgment; the underlying service is cross-border recognition and enforcement.

The comparison

• United Kingdom. Six years to recognise a foreign judgment, from when it became enforceable in the country of origin (N500). Six years under the statutory regime (N501). Six years for a foreign arbitral award, treated as a claim on a simple contract (N502).
• Switzerland. Ten years to enforce a right already confirmed by judgment, with a new period starting once the judgment becomes final (N505).
• Cyprus. No general period fixed for an application to recognise a foreign judgment (N509).
• Malta. Fifteen years, general period, to enforce a judgment (N510).
• Spain. Five years to bring the enforcement action, from when the judgment becomes final; the same period applies to arbitral awards (N512).
• Portugal. Twenty years, general period, to enforce an obligation confirmed by judgment (N514).
• Germany. Thirty years to enforce a right confirmed by judgment, and the same thirty years for claims arising from an arbitral award (N516, N517).
• Netherlands. Twenty years to enforce a judgment or an arbitral award; five years where the claim is for periodic payments or interest (N520, N521).
• Luxembourg. Thirty years, general period, to enforce a judgment (N524).
• United States, federal. Three years from the date of the award to enforce a foreign arbitral award under FAA §207 (N527).
• New York. The shorter of the period running in the country of origin or twenty years, for a foreign judgment (N528).
• Delaware. Fifteen years, applied where no period is fixed in the country of origin (N530).
• California. The shorter of the period running in the country of origin or ten years (N531).

Where the spread bites

The widest gap sits inside a single country. A foreign arbitral award enforced in US federal courts under FAA §207 carries three years from the date of the award (N527). A judgment enforced in Germany or Luxembourg, once recognised, carries thirty years to enforce the right it confirms (N516, N524). A claimant who expects the German or Luxembourg timeline can lose the US claim entirely before realising the clock has already run.

The three-year US period is also not settled practice. One appellate line allows recognition of a foreign judgment that itself confirmed an arbitration award even after three years; another holds that FAA §207 does not override state law on recognising foreign judgments (N533). Where the underlying asset sits behind an unpaid judgment for crypto, this timing question is discussed in our note on judgments for crypto assets going unpaid, with further background under our insights on non-enforcement of judgments.

What is not established

Cyprus has no general period fixed for the recognition application itself (N509). Where a registry entry does not cover a jurisdiction, the period is determined by the law that applies to that claim and needs verification against the specific facts before any deadline is treated as fixed. An absence of a registry entry is not the same as an absence of a rule.

This page does not state court fees; those are addressed separately under court fees for enforcement. The firm does not work on a success-fee-only basis, and its registration can be checked through the public registry referenced on how to verify a law firm. A paid initial assessment, arranged through contact, is how a limitation question gets answered against a specific set of facts.