A French judgment does not enforce itself outside France. It has to be admitted there. Everything depends on the country where the debtor’s assets are: within the European Union, a certificate issued by the court office is enough; in Switzerland, Norway and Iceland, a simplified declaration of enforceability is still required; in the United Kingdom, the 2019 Hague Convention applies to proceedings instituted since 1 July 2025; elsewhere, one needs a bilateral treaty or, failing that, proceedings before the foreign court under its own law. The strategy is decided before suing, not after winning.
A Bordeaux wine merchant has obtained, after two years of litigation, judgment against its London importer for 640,000 euros of invoices plus compensation for termination. The judgment of the Bordeaux commercial court is provisionally enforceable, an appeal has been lodged, and the importer has no assets in France. It does have a bonded warehouse in Kent, bank accounts in London and a Hong Kong subsidiary that collects its Asian sales. The merchant thought the hard part was over. He discovers that he is starting a second case, in another country, and that the date of his claim form, issued in March 2024, changes everything.
The site has a series of articles on enforcing foreign judgments in France, country by country. This page takes the opposite route: that of the French creditor who has won at home and must recover elsewhere. It covers the title to prepare in France, then the regimes in order of simplicity: the European Union, the Lugano Convention States, the States party to the 2019 Hague Convention, countries with a bilateral treaty with France, and countries with no treaty, before turning to documents and strategy.
1. Preparing the title in France
The foreign court works only with what the creditor brings. From the day judgment is given, the creditor should assemble a file no foreign court can call incomplete: a certified copy bearing the enforcement formula, proof of service of the judgment on the debtor, proof of service of the document instituting proceedings if the debtor did not appear, and, depending on the country, a certificate of non-appeal or the appeal judgment. Since 1 January 2020, first-instance judgments are provisionally enforceable by operation of law for proceedings instituted after that date (Code of Civil Procedure, art. 514). Many foreign States nevertheless require a final judgment, and the creditor must know, country by country, whether French provisional enforceability will be recognised there.
Service of the claim deserves particular care. Everything turns on it. It is the first argument the foreign debtor will raise, under every regime without exception. A defendant established in another Member State must have been served under the EU Service Regulation; a defendant outside the EU, under the Hague Convention of 15 November 1965 if its country is a party, or under the applicable bilateral treaty. A default judgment obtained after service on the public prosecutor without effective transmission will be refused everywhere.
2. Within the European Union: a certificate and service
For proceedings instituted since 10 January 2015, Regulation (EU) No 1215/2012, known as Brussels I bis, abolishes exequatur: a judgment enforceable in France is enforceable in the other Member States without a declaration of enforceability (art. 39). The creditor asks the chief clerk of the court that gave judgment for the certificate under Article 53 (Code of Civil Procedure, art. 509-1, I), serves it on the debtor with the judgment before the first enforcement measure (art. 43), and applies directly to the enforcement authority of the requested State. The debtor may only apply for refusal of enforcement on exhaustively listed grounds (arts. 45 and 46), and never obtain a review of the substance (art. 52). Denmark applies the Regulation under a special agreement concluded in 2005.
The regime is so simple that creditors forget it has a protective side. An enforceable judgment carries by operation of law the power to take any protective measures available under the law of the requested State (art. 40), and Regulation (EU) No 655/2014 allows the debtor’s bank accounts in another Member State to be traced and frozen. These tools are presented in the article on recovering a debt in the EU without exequatur.
3. Switzerland, Norway, Iceland: the Lugano Convention and its residual exequatur
The Lugano Convention of 30 October 2007 mirrors the old Brussels I Regulation, not Brussels I bis. Exequatur has therefore not disappeared: the creditor must obtain in the requested State a declaration of enforceability, issued on application, without adversarial debate at first instance, on the basis of the judgment and the certificate provided for by the Convention. In France, that certificate is also requested from the chief clerk (Code of Civil Procedure, art. 509-1, I). The grounds for refusal are only examined if the debtor appeals. In Switzerland, the declaration is a matter for the competent cantonal court, and the creditor may, in the same application, seek an attachment (séquestre) of the debtor’s assets, combining exequatur and protective measure. The Swiss mechanism is described, in the other direction, in the article on Swiss judgments.
4. United Kingdom: the 2019 Hague Convention, and the date that decides everything
Since Brexit, a French judgment no longer circulates in the United Kingdom under Brussels I bis. For more than four years, outside an exclusive choice-of-court clause within the Hague Convention of 30 June 2005, the creditor’s only route was a common law action, in which the foreign judgment is treated as a debt that an English court must be asked to endorse. That has changed: the Hague Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters, in force for the European Union since 1 September 2023, has been in force for the United Kingdom since 1 July 2025.
The Convention only applies, however, to judgments given in proceedings instituted when it was in force in both the State of origin and the requested State (art. 16). That is the trap in the Bordeaux case. The claim having been issued in March 2024, before 1 July 2025, the Bordeaux judgment does not benefit from it, and the merchant will have to act in England at common law: he sues the importer in the High Court on the French judgment and seeks summary judgment, showing that the French court had jurisdiction in the English sense (presence of the defendant or submission to the jurisdiction, notably by appearing or by agreement). The debtor can only raise fraud, public policy or breach of natural justice. The procedure is effective, but it assumes that the London importer appeared in France or accepted French jurisdiction; otherwise indirect jurisdiction is open to argument.
For a claim issued after 1 July 2025, the regime is quite different. And simple. The judgment is recognised if it rests on one of the jurisdictional bases listed by the Convention, including the defendant’s habitual residence in the State of origin, a branch whose activities gave rise to the claim, appearance without contesting jurisdiction, or the place of performance of the contractual obligation in question (art. 5). Grounds for refusal are limited (art. 7), review of the merits is excluded (art. 4), and the creditor produces a complete certified copy of the judgment, proof of service of the document instituting proceedings in case of default, documents establishing enforceability, and a translation where necessary (art. 12). In England, the judgment is registered in the High Court. The Convention also binds Ukraine, Uruguay, Albania, Montenegro and Andorra; the United States, Israel and Russia have signed without ratifying.
5. Countries bound to France by a bilateral treaty
Since the 1950s, France has concluded judicial assistance treaties providing for the recognition of judgments with most North African and French-speaking African States, and with several States in Asia and the Middle East. Each has its own conditions, documents and sometimes a simplified procedure. They work both ways, and a French creditor who must enforce in Casablanca, Tunis, Algiers, Beijing or Dubai will find the applicable regime in the site’s articles on those countries, all of which cover the reverse route: Morocco (1957 convention), Tunisia (1972 convention), Algeria (1964 convention), China, United Arab Emirates and the OHADA States.
One observation applies to all of them. Ignoring it is costly. These treaties are applied by judges who know their provisions poorly, and the creditor must arrive with the text, its publication in the Journal officiel, and a note explaining why each condition is met. A file that merely invokes “the Franco-Moroccan convention” without citing its articles loses months.
6. Countries with no treaty: United States, Canada, Singapore and others
For all other countries, the French judgment is a fact the local court assesses under its own law. The regimes vary widely. None is automatic. In the United States, the matter is one of state law; most states have adopted one of the two uniform acts on the recognition of foreign money judgments, of 1962 or 2005, and New York aligned Article 53 of its Civil Practice Law and Rules with the 2005 version in 2021. The creditor brings an action there, often by way of a motion for summary judgment, and the court checks the French court’s jurisdiction, due process and public policy, without a reciprocity requirement in most states. In Canada, Quebec applies Articles 3155 et seq. of its Civil Code, while the common law provinces require an action on the judgment, time-barred in Ontario after two years; these rules are set out in the article on Canada. In Singapore, in the absence of a bilateral treaty, a French judgment is enforced by a common law action, except where it was given under an exclusive choice-of-court agreement within the 2005 Hague Convention, to which Singapore and the EU are parties.
In these countries two questions always come up. The first is indirect jurisdiction: the foreign court assesses the French court’s jurisdiction by its own criteria, and jurisdiction based solely on the claimant’s French nationality, once permitted by Article 14 of the Civil Code, will not be recognised. The second is time: foreign limitation periods for an action on a judgment are often far shorter than the ten years a creditor has in France to enforce a title (Code of Civil Enforcement Procedures, art. L. 111-4). A creditor who lets a judgment sleep loses it abroad long before losing it in France.
7. Documents, apostille and translations
Outside the EU, the judgment and the certificate of non-appeal must in principle be legalised. The Hague Convention of 5 October 1961 replaces legalisation with an apostille for all States parties, including the United States, the United Kingdom, China since November 2023 and Canada since January 2024. Many creditors are still unaware of this: since 1 May 2025, apostilles are no longer issued by the public prosecutors’ offices of the courts of appeal but by the French notarial profession, through an online platform or at the regional notarial councils, pursuant to Ordinance No. 2020-192 of 4 March 2020 and Decree No. 2021-1205 of 17 September 2021. Legalisation, required for countries that have not joined the Convention, has followed the same route to the notarial profession, before the document goes to the consulate of the destination State.
Translation is into the language of the requested court, by a translator approved in the destination State where its law so requires. The cost is heavy for a long judgment: it is often possible to limit translation to the operative part and the relevant reasons, provided local law allows it. Within the EU, the debtor may require a translation of the judgment in order to challenge enforcement (Brussels I bis, art. 43), and it is wise to anticipate this.
8. Strategy is decided before suing
The Bordeaux case teaches the most useful rule in this field: enforcement abroad is prepared when choosing one’s court. Had the merchant known, in March 2024, that his chances of recovery lay in London and Hong Kong, he would have weighed differently the choice between suing in Bordeaux, where he comfortably won a judgment that would then have to be endorsed at common law, suing directly in London, where he would have obtained a title immediately enforceable against the Kent warehouse at the price of more expensive proceedings, or deferring by a few months a claim that was not urgent so as to fall within the 2019 Convention, and he would have checked, in each case, that the importer would appear or had accepted French jurisdiction through enforceable general terms, since that point, and that point alone, is where the High Court could have refused to follow him. He would also, from the moment he issued proceedings, have asked the English court for a freezing injunction, which the High Court can grant in support of foreign proceedings. None of this was done. None of it is lost yet.
For future contracts, the safest solution remains arbitration. An award made in Paris is enforceable in more than one hundred and seventy States under the New York Convention of 10 June 1958, through a procedure almost everywhere faster and more predictable than enforcing a judgment, Hong Kong included. For an exporter whose customers have no assets in Europe, that choice is worth more than all the regimes described above. The issues are discussed in the article on enforcing ICC awards.
The firm assists French creditors in enforcing their judgments abroad, coordinating the work of local counsel, and advises them before litigation on the forum most useful for recovery. Its page on enforcement of judgments describes this work, and the contact form allows a case to be outlined in a few lines.
Frequently asked questions
How is a French judgment enforced in another EU country?
For proceedings instituted since 10 January 2015, the creditor simply asks the chief clerk of the court that gave the judgment for the certificate under Article 53 of the Brussels I bis Regulation, serves it on the debtor with the judgment, then applies to the enforcement authority of the State concerned. No exequatur is needed, and the debtor can only resist enforcement on the grounds exhaustively listed in Article 45.
Is a French judgment enforceable in the United Kingdom after Brexit?
It depends on when the proceedings were instituted in France. If the claim was issued on or after 1 July 2025, the Hague Convention of 2 July 2019 applies and the judgment is registered in the High Court under a simplified procedure. If earlier, the creditor must bring a common law action in England, unless there is an exclusive choice-of-court clause within the 2005 Hague Convention.
Who issues in France the certificate needed for enforcement abroad?
The chief clerk of the court that gave the decision, for the certificates under the Brussels I bis Regulation and the Lugano Convention (Code of Civil Procedure, art. 509-1, I). Certification of a decision as a European Enforcement Order for an uncontested claim is, however, requested from the judge who gave it (art. 509-1, II).
Can a French judgment be enforced in the United States?
Yes, but there is no treaty between France and the United States, and the matter is governed by each state’s law. Most have adopted a uniform act on the recognition of foreign money judgments. The creditor brings an action before the court of the state where the assets are located, which checks the French court’s jurisdiction, due process and public policy, without reviewing the merits.
Does a French judgment to be enforced abroad need an apostille?
Outside the European Union, generally yes. For States party to the Hague Convention of 5 October 1961, the apostille replaces consular legalisation; since 1 May 2025 it has been issued by the French notarial profession rather than the courts of appeal. For other States, legalisation is required, followed by the consulate of the destination country. Some bilateral treaties waive all formalities, which should be checked first.
On the same subject: recovering a debt in the EU without exequatur; governing law and jurisdiction, the clause that decides the case; the six points that decide whether a foreign title is enforceable in France.