This eighteen-page practical guide compares the three regimes that govern the enforcement of a foreign title in France: French ordinary law on exequatur, European and treaty-based private international law, and arbitration law. It is written for exporting companies, legal departments, financial institutions, international arbitration practitioners and advisers dealing with the cross-border enforcement of a title.
It covers the Brussels I bis, Brussels II ter, Succession and Lugano regimes, the Hague Conventions of 2005 and 2019, bilateral conventions, the New York Convention and articles 1514 et seq. of the French Code of Civil Procedure, the reform of 6 August 2026, and immunities from enforcement. It ends with seven preliminary questions, a decision tree and the most common mistakes. August 2026 edition.
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Frequently asked questions
Is exequatur needed to have a foreign judgment recognised in France?
It depends on the effect sought. A foreign judgment on personal status or capacity has effect in France without exequatur, as the courts have accepted since Bulkley of 28 February 1860; exequatur becomes necessary again only for physical enforcement against assets or coercion against persons (Req., 3 March 1930, Hainard). Applying for an unnecessary procedure risks inadmissibility; wrongly doing without one risks the attachment being set aside.
Does a judgment given in another EU Member State still need exequatur?
No, in civil and commercial matters. Regulation (EU) No 1215/2012, known as Brussels I bis, provides for automatic recognition (article 36) and abolishes exequatur (article 39): the creditor enforces directly on production of the decision and the article 53 certificate, and it is for the debtor to apply to the court for refusal, on one of the five grounds exhaustively listed in article 45.
What are the conditions for exequatur under ordinary law, outside any international convention?
Since Cornelissen of 20 February 2007, the French court need only check three conditions: the indirect jurisdiction of the foreign court, conformity with substantive and procedural international public policy, and the absence of evasion of the law. It no longer has to verify that the law applied by the foreign court is the law designated by the French conflict-of-laws rule.
Can an arbitral award set aside in its country of origin still be enforced in France?
Yes. Since Putrabali of 29 June 2007, the Cour de cassation has held that an international award is not anchored in any national legal order: its annulment by the court of its seat has no effect in France. Article 1514 of the French Code of Civil Procedure makes recognition conditional only on the existence of the award and the absence of any manifest conflict with international public policy.
Does the French court review corruption or money laundering in an arbitral award?
Yes, and in depth since Belokon of 23 March 2022: the Cour de cassation held that the review carried out by the set-aside court is neither limited to the evidence produced before the arbitrators nor bound by their findings. Sorelec of 7 September 2022 specified that this complaint is admissible even if it was not raised before the arbitral tribunal.
What is the time limit for challenging an order ruling on recognition or exequatur of an award made abroad?
One month to appeal. The appeal does not suspend enforcement (article 1526 of the French Code of Civil Procedure): a debtor who does not obtain a stay from the First President may see its accounts attached while it prepares its submissions. On the creditor side, the action for exequatur under ordinary law is time-barred, in the absence of a specific text, after the five-year period of article 2224 of the Civil Code, according to the majority view.
While the guide is on its way, the related analyses are freely available. On the regime applicable to each decision: the six points that determine whether your title will be enforceable. By country: US and English judgments, German judgments, Swiss judgments, UAE judgments, Singapore judgments, Chinese judgments, Canadian and Quebec judgments, Tunisian judgments, Moroccan judgments, Algerian judgments and OHADA judgments and CCJA rulings. By asset to be attached: the bank account, real property and the ship. On urgency: securing the debtor’s assets before exequatur. On the debtor’s side: challenging the exequatur of a foreign judgment. And on arbitration: exequatur of an arbitral award.