Insights

On 12 July 2022, the Council of the European Union adopted a decision to accede to the Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters.

The Convention will enter into force one year after two parties deposit an instrument either ratifying, accepting, approving, or acceding to the Convention. The European Union has yet to deposit its instrument of accession, but is on track to be the first part to accede to it. So far Costa Rica, Israel, Russia, Ukraine, the United States and Uruguay have signed the Convention, but they have not yet ratified it.

The Convention will allow EU citizens and business to have judgments of EU Member State courts recognized and enforced in non-EU Member States. Conversely, it will also allow judgments of non-EU Member States to be recognized and enforced within the EU, provided fundamental principles of EU law are respected. It will undoubtedly be a welcome complement to the existing framework within which judgments may circulate, including the Brussels Ia regulation, the Lugano Convention, and the 2005 Hague Choice of Court Convention.