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In today’s global market, commercial disputes frequently cross borders. It is vital for businesses and individuals—whether in the UK, Poland, or elsewhere in Europe - to ensure that a court decision or judgment issued in one country is recognised and enforceable in another.

The rules for recognition and enforcement have changed significantly following the United Kingdom’s withdrawal from the European Union, making professional legal guidance more necessary than ever.

Prior to 31 December 2020, recognition and enforcement of commercial judgments between the UK and other EU Member States were governed by the Brussels Ia Regulation (Regulation (EU) No 1215/2012), which simplified the process and allowed, for example, a British or Polish court judgment to be recognised and enforced across the EU without special proceedings.

During the Brexit transition period, EU law—including the Brussels Ia Regulation—continued to apply to the UK, meaning that commercial judgments in proceedings begun before 31 December 2020 still benefit from those simplified mechanisms. This includes the recognition of judgments in contract disputes, torts, and related matters, whether issued in the UK or the EU, so long as the relevant claim or application was filed before the transition deadline.

However, for proceedings initiated after 31 December 2020, the automatic application of the Brussels Ia Regulation ceased. This means that the procedures for recognition and enforcement of judgments between the UK and EU Member States are now determined either by international agreements—such as the Hague Convention on Choice of Court Agreements—or, where no such treaty exists, by the domestic law of the relevant countries.

Crucially, if a judgment arises from an agreement between parties that specifies exclusive jurisdiction for a particular court, the UK will generally recognise and enforce that judgment under the Hague Convention, provided all requirements are satisfied. The situation can be more complex where no exclusive jurisdiction is agreed, or where cross-border commercial disputes arise without a clear contractual basis.

As the UK is no longer party to the 2007 Lugano Convention, which previously provided another route for recognition, claims relating to business or contract disputes may now face additional procedural requirements, heightening the importance of specialist legal advice. Moreover, future developments—including any new UK-EU agreements—could further affect recognition processes, so monitoring the legal landscape is vital for all international businesses.

Polit Law LTD provides expert legal guidance and representation in all aspects of recognition of commercial judgments, including:

• Assessing whether your claim falls under the Brussels Ia Regulation (based on start date), Hague Convention, or domestic law
• Advising on the correct procedure for enforcing UK or EU judgments in cross-border commercial, contractual, and tort cases
• Preparing all required documents, supporting evidence, and court applications for recognition and enforcement
• Assisting with complex situations, such as non-EU claims or where forum non conveniens issues arise
• Liaising with foreign courts, legal professionals, and businesses to ensure the best outcome for your interests
• Providing ongoing updates on changing UK and EU regulations related to enforcement

If you are uncertain whether your foreign court judgment can be recognised or need help with any stage of cross-border commercial enforcement, contact Polit Law LTD for clear, practical advice. We serve both British and Polish companies, contractors, and individual clients, ensuring that your rights are protected on both sides of the Channel.