Instrument

The 2019 Hague Judgments Convention

The 2019 Hague Judgments Convention lets a judgment from one contracting state be recognised and enforced in another, without redoing the case on the merits. It entered into force on 1 September 2023. Whether it applies to a specific judgment depends on which states were bound by the convention when proceedings started in the state of origin, not on where enforcement is sought later. This convention is one route among several for cross-border recognition and enforcement.

Scope

The convention covers judgments in civil and commercial matters. It excludes tax, customs and administrative matters, so a tax assessment or a customs penalty stays outside it even when a court issued it.

Judicial settlements are covered as well. A settlement approved by a court of a contracting state, or reached during proceedings and enforceable as a judgment in the state where it was approved, can be enforced under the same convention rules as a judgment.

A refusal to honour a judgment abroad, including non-enforcement of a foreign judgment, is one of the situations this instrument is built to address, subject to the scope limits above.

Where it applies

Seven parties have joined so far: Albania, Andorra, the European Union, Montenegro, Ukraine, the United Kingdom and Uruguay. Because EU accession binds member states collectively, the convention in practice reaches 32 states, all EU members except Denmark plus the other five parties.

The EU acceded on 29 August 2022, and the convention entered into force for it, and generally, on 1 September 2023.

Coverage keeps shifting as more states join or accede to the EU. Compare this to the narrower 2005 Hague Choice of Court Convention, which runs on a different membership list and different admission rules.

Traps

Timing catches people out. The convention only applies if, when proceedings started in the state of origin, it was already in force between that state and the state where enforcement is sought. A claim filed before that link existed falls outside the convention even if the judgment itself came after entry into force.

Some contracting states have filed declarations narrowing how the convention applies to them. Whether a declaration affects a specific judgment has to be checked against the current declarations list for the states involved, not assumed from the general text.

The convention does not require the jurisdiction clause behind a judgment to be reciprocal, which is why it can reach asymmetric clauses that usually fall outside the 2005 Convention. Anyone presenting this as a fixed, fast timetable for recognition is overstating it, in the same way described in signs of a recovery room.

How it is used in practice

In practice, this convention is one of several routes checked before deciding how to pursue a foreign judgment after non-payment or a refusal to enforce. The mechanics of that check are covered in our cross-border recognition and enforcement service.

Applying it to a specific case means checking whether both states were bound by the convention at the right dates, whether the judgment fits the civil and commercial scope, and whether a declaration narrows the picture for either state. Related scenarios are covered in O8 insights, including a judgment going unpaid against crypto accounts.

We do not charge a fee contingent solely on recovery, and the firm behind this page can be checked against a public register. See how to verify a law firm before relying on any of this.