You sued in London, you won, and the debtor now lives in France or keeps money there. Before Brexit you could take that English judgment to France through a European fast lane that made recognition almost automatic. That lane is closed. Since 1 January 2021 the United Kingdom is a third state for civil justice cooperation, which means your High Court or County Court order has no direct force on French soil until a French court says so. That French green light is called exequatur, a word you will meet in every letter from your French lawyer: it is the declaration by which a French court makes a foreign judgment enforceable in France. Without it, no French enforcement officer will touch a bank account in Lyon, no land registry will record a charge over a flat in Nice, and any payment you extract remains voluntary. With it, your English debt becomes a French enforcement title you can use like any French creditor. This guide explains, for a British reader, exactly how to get there after Brexit: why the old European regulation no longer helps, which French court hears your application, the three tests the judge applies to your English judgment, when the new 2019 Hague Convention on foreign judgments gives you a shorter road since 1 July 2025, how to freeze French assets before they disappear, and how debtors try to resist. Every decisive statement below is anchored in the French codes on Légifrance, two landmark rulings of the Court of Cassation (Cour de cassation) on exequatur, and the official positions of the Hague Conference on Private International Law and GOV.UK. French legal words are explained the first time they appear.
I. Your English judgment has no force in France by itself: why exequatur is compulsory since Brexit
A. Why the old European fast lane is gone and which French court hears you now
Until 31 December 2020, an English money judgment circulated in France under Regulation (EU) No 1215/2012, known as Brussels I bis (the European rule on jurisdiction, recognition and enforcement in civil and commercial cases). Recognition was automatic and enforcement needed only a simple registration with the local court clerk. Brexit ended that. The United Kingdom did not rejoin the Lugano Convention, the parallel treaty that gives Switzerland, Norway and Iceland a similar fast lane, because the European Union refused its accession application. The result is blunt: for proceedings started after the transition period, there is no European shortcut left between London and Paris. Your judgment is treated like a judgment from New York or Sydney, governed either by a Hague convention where one applies or, everywhere else, by the French common law of exequatur built up by the Court of Cassation since the 1960s. The starting principle is written in article 509 of the Code of Civil Procedure, which states that “Les jugements rendus par les tribunaux étrangers et les actes reçus par les officiers étrangers sont exécutoires sur le territoire de la République de la manière et dans les cas prévus par la loi.” In plain English: a foreign judgment is enforceable in France only in the manner and cases provided by law, which in practice means after exequatur unless a convention says otherwise. That single sentence is the legal wall your debtor hides behind, and your whole case consists of getting through it.
One transitional question comes first, because it still traps creditors in 2026. Judgments in proceedings instituted before 1 January 2021 remain governed by the Withdrawal Agreement’s tail: Brussels I bis continues to apply to recognition and enforcement of judgments handed down in proceedings begun before the end of the transition period. If your London claim form was issued in 2019 or 2020, tell your French lawyer immediately, because you may still benefit from the old registration route before the clerk (greffe) of the tribunal judiciaire, the main first-instance civil court, instead of a full exequatur action. Everything else, meaning any County Court or High Court claim started in 2021 or later, goes through the post-Brexit routes described below. Check the issue date on your claim, not the judgment date, because that is what decides the regime. Creditors regularly lose months by applying under the wrong procedure, so this dating check is the first thing a careful practitioner does.
The competent court for a post-Brexit exequatur of an English civil or commercial money judgment is the tribunal judiciaire (the ordinary civil court of first instance) of the place where the debtor lives or where enforcement will happen, typically where the bank account, wages or flat are situated. For Paris that means the Paris tribunal judiciaire; for a debtor in the Dordogne it means the local tribunal judiciaire of that area. The application is brought by writ (assignation) against the debtor, not by a quiet one-sided petition, because the debtor has the right to argue. You will need a French lawyer (avocat) to draft and serve it, plus a commissaire de justice, the enforcement officer formerly called huissier de justice, to serve the writ and later to enforce. Budget realistically: court and lawyer costs for a straightforward uncontested exequarch usually run into a few thousand euros, while a contested case with an appeal can cost several times more and last eighteen months to three years. Ask for a written fee estimate before you start, and compare that cost with the amount actually recoverable in France, because pursuing a 4,000-pound debt against a debtor with no visible French assets can be throwing good money after bad, whereas a 60,000-pound judgment against a debtor who owns a French house is plainly worth pursuing.
Your file must be litigation-ready in French form. The English judgment needs a certified copy with proof that it is final and enforceable in England, usually a sealed order plus a certificate or statement on appeal status, together with a sworn translation into French by a traducteur assermenté (sworn translator registered with a French court of appeal). If the English court decided by default because the debtor never turned up, keep the proof that the claim was properly served under English rules, because French judges look hard at service fairness, as explained below. Documents from the United Kingdom no longer benefit from the European exemption from legalisation, but the United Kingdom and France are both parties to the 1961 Hague Apostille Convention, so an apostille from the Foreign, Commonwealth and Development Office on the English documents normally suffices. Start gathering these papers while you are still in contact with your English solicitor, because chasing a sealed order and an apostille from France adds weeks. A tidy file signals seriousness to the French judge and to the debtor, who often settles once a well-prepared assignation lands.
B. The three tests your English judgment must pass before the French judge stamps it
French judges do not retry your London case. There is no révision au fond, meaning no review of the merits: the tribunal judiciaire will not ask whether the English judge interpreted the contract correctly or awarded too much. What it checks instead are three conditions of international regularity laid down by the Court of Cassation in the Cornelissen ruling of 20 February 2007 and repeated ever since. The official summary of that landmark decision, appeal No. 05-14.082, states the rule in one sentence: “pour accorder l’exequatur hors de toute convention internationale, le juge français doit s’assurer que trois conditions sont remplies, à savoir la compétence indirecte du juge étranger, fondée sur le rattachement du litige au juge saisi, la conformité à l’ordre public international de fond et de procédure et l’absence de fraude à la loi”. Fourteen years later the Court restated the same trio in a case about an American judgment, holding that “Pour accorder l’exequatur à un jugement étranger, le juge français doit, en l’absence de convention internationale, s’assurer que trois conditions sont remplies, à savoir la compétence indirecte du juge étranger fondée sur le rattachement du litige au juge saisi, la conformité à l’ordre public international de fond et de procédure ainsi que l’absence de fraude” (Court of Cassation, First Civil Chamber, 3 March 2021, appeal No. 19-19.471). Those two quotations are the whole examination paper. Every argument you make, and every objection the debtor raises, fits into one of those three boxes, so understand each box before you file.
The first box is the indirect jurisdiction of the English court (compétence indirecte): was London a sensible forum for this dispute in French eyes? The French judge does not apply English jurisdiction rules; it asks whether the dispute had a characterised link with England, such as the debtor living there, the contract being performed there, or the harmful event happening there. A London judgment against a person domiciled in England for a debt payable in England passes easily. A judgment against a lifelong French resident who never set foot in England, based only on a small-print clause the French judge regards as exorbitant, is vulnerable. Exclusive French jurisdiction is fatal to you: disputes about ownership of French land, for example, belong to French courts, because article 3 of the Civil Code provides that “Les immeubles, même ceux possédés par des étrangers, sont régis par la loi française”, and the French courts claim exclusive power over rights in rem over French immovable property. So an English order purporting to transfer title to a Dordogne farmhouse will not get exequatur for that part, whatever its merits. Frame your application around a payment obligation, not a declaration about French land, and show the concrete English links: domicile, place of performance, choice-of-court clause actually agreed, correspondence showing the debtor accepted London. Documentary links win this box; bare assertions lose it.
The second box is compatibility with French international public policy (ordre public international), in substance and in procedure. In substance, the English outcome must not shock the foundations of French law: a straightforward damages award for breach of contract or an unpaid loan passes without difficulty, but a manifestly disproportionate penalty, punitive damages with no compensatory function, or an order enforcing a contract French law treats as illegal may stumble. United States-style mega punitive awards are the textbook problem; ordinary English compensatory damages with interest are normally fine. In procedure, the French judge checks that the debtor could actually defend himself: proper service in time to prepare a defence, a real opportunity to be heard, an impartial tribunal, and respect for the rights of the defence. Default judgments are not automatically excluded, English county court defaults are enforced every month, but you must prove the debtor was duly served and told what was at stake. Keep the certificate of service, the claim form, and any acknowledgment of service. If the debtor took part in London, appealed, or settled part of the claim, say so and exhibit it, because participation destroys most procedural objections. If your case involved a consumer, an employee or an insured party as the weaker side, expect closer scrutiny, since French courts protect weak parties against forum clauses imposed on them. Anticipate the debtor’s story: “I never received anything”, “I could not travel”, “the trial lasted ten minutes”. Answer each with paper, not adjectives.
The third box is the absence of fraud (absence de fraude, sometimes fraude à la loi): neither side may have manipulated jurisdiction or the proceedings to evade the law. The classic example is a creditor who sues abroad only to dodge a mandatory French rule, or parties who fabricate English links to escape French consumer or employment protection. Ordinary forum shopping within legitimate options is not fraud; choosing London because the contract said London is normal commercial life. Manufacturing links, hiding a parallel French case on the same dispute, or obtaining a judgment by deliberately misleading the English court about the debtor’s address crosses the line. The French judge also refuses exequatur to a judgment that contradicts an earlier French decision or a judgment already enforceable in France between the same parties on the same subject, treating that conflict as a form of disorder. Before filing, search honestly: is there a French judgment, pending French proceedings, or an arbitration on the same debt? If so, disclose it and explain why your English judgment should still prevail, for instance because the French case was about something else or was discontinued. Judges punish surprises far more than complications, and a debtor who reveals a hidden French judgment mid-case can turn the whole exequatur around.
A practical consequence of the Cornelissen trio is what the judge will not do. The French court does not check which substantive law the English judge applied, does not second-guess English evidence rules, and does not reduce the amount because French judges would have awarded less. Interest, costs and late-payment penalties included in the English order travel with the principal, subject only to the public-policy ceiling on manifest excess. That is good news for creditors: a well-run London case with clean service and a reasoned order is genuinely hard to stop. It is also a warning: if your English file has a weak spot, service, jurisdiction, parallel proceedings, fix or disclose it before the assignation goes out, because the debtor’s lawyer will aim every arrow at those three boxes and nothing else.
II. From a London order to French money: the Hague 2019 shortcut, freezing assets and breaking resistance
A. When the 2019 Hague Judgments Convention shortens your road and what to file under it
Since the summer of 2025 there is genuinely good news for British creditors. The Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters, known as Hague 2019, entered into force for the United Kingdom on 1 July 2025, after London deposited its instrument of ratification on 27 June 2024. The Hague Conference confirms that the Convention entered into force for the United Kingdom of Great Britain and Northern Ireland on 1 July 2025, following the deposit of the instrument of ratification on 27 June 2024. The British government marked the moment in the same terms, with a Ministry of Justice statement dated 2 July 2025 confirming entry into force for the UK on 1 July 2025 and noting that judgments from United Kingdom courts will be more readily recognised and enforced in the courts of the other contracting states, and vice versa. Because the European Union is itself a party and France is bound through the Union, the London-to-Paris corridor is now covered for qualifying cases. This does not resurrect Brussels I bis, recognition is not automatic and the grounds for refusal are wider than under the old European rule, but Hague 2019 replaces the open-ended Cornelissen discussion with a structured checklist, which in practice means faster, more predictable cases where it applies.
Eligibility has three cumulative keys: timing, subject matter, and the jurisdictional filter. Timing first. Hague 2019 applies in the United Kingdom to judgments given in proceedings instituted after its entry into force for the state of origin, so English judgments from cases started after 1 July 2025 can travel under the Convention, while judgments from cases started earlier stay under the common-law exequatur described above, even if the judgment itself was delivered later. Check your claim number date carefully and put it on the first page of your advice note. Subject matter second. The Convention covers civil and commercial judgments, which includes most money claims British readers care about: unpaid loans, invoices, contractual damages, overpayments, and many tort awards. It excludes family law, wills and succession, insolvency, defamation, privacy, intellectual property, competition, and a list of other sensitive areas, as well as revenue, customs and administrative matters. A straightforward High Court debt judgment qualifies; an English divorce costs order or a libel award does not. The jurisdictional filter third. The English court must have heard the case on one of the Convention’s accepted bases, such as the defendant’s habitual residence in England, a choice-of-court agreement, performance of the contractual obligation in England, or submission by appearing without contesting jurisdiction. A judgment based purely on the temporary presence of the debtor or on claimant-only connections will not pass. Your French lawyer’s first memo should therefore map your London case onto that filter expressly, paragraph by paragraph, rather than assuming any English judgment qualifies.
Where Hague 2019 applies, the practical gains are real. The French court works from a closed list of refusal grounds, centred on due process, public policy, fraud, inconsistent judgments and settlement issues, instead of the broader judicial construction around indirect jurisdiction. You file for recognition or enforcement before the tribunal judiciaire with a complete, certified copy of the English judgment, proof that it has effect and is enforceable in England, and the documents showing the jurisdictional basis is met, plus sworn French translations. There is no review of the merits, and damages that are non-compensatory, including exemplary or punitive damages, can be trimmed to the compensatory level without killing the rest of the award. Where Hague 2019 does not apply, because your case started too early or falls in an excluded subject, you fall back on the Cornelissen common-law route, which remains fully available and succeeds every week for well-prepared files. The two routes therefore cover the field between them: Hague 2019 for recent, qualifying commercial and civil money judgments, Cornelissen for everything else. Never let anyone tell you that a pre-July-2025 English judgment is unenforceable in France; it simply takes the classic road. And never assume a post-July-2025 judgment is automatically enforceable either; it still needs a French enforcement order, only through a more standardised check.
Two related Hague treaties deserve a brief mention because clients confuse them constantly. The 2005 Hague Choice of Court Convention still helps where your contract contained an exclusive choice-of-court clause in favour of English courts: qualifying judgments under that treaty benefit from a dedicated enforcement channel, and many London commercial contracts fall into it. The 2007 Hague Maintenance Convention continues to govern cross-border maintenance obligations, so English child-maintenance and spousal-maintenance decisions travel under their own regime rather than Hague 2019. If your English order mixes a commercial debt with maintenance or family elements, split the analysis element by element and enforce each part under its proper instrument. A mixed order enforced through the wrong channel invites a partial refusal that a little triage would have avoided. Ask your lawyers in both countries to label each head of the English order with its enforcement route before anything is filed in France.
B. How to stop the debtor emptying France while you wait: freezing orders, seizure and the enforcement judge
Exequatur takes months, and a warned debtor can empty a French bank account in an afternoon. French law therefore lets you protect the position before the English judgment becomes enforceable, through protective measures (mesures conservatoires) authorised by a judge. The gateway is article L511-1 of the Code of Civil Enforcement Procedures, which provides that “Toute personne dont la créance paraît fondée en son principe peut solliciter du juge l’autorisation de pratiquer une mesure conservatoire sur les biens de son débiteur, sans commandement préalable, si elle justifie de circonstances susceptibles d’en menacer le recouvrement. La mesure conservatoire prend la forme d’une saisie conservatoire ou d’une sûreté judiciaire.” In plain terms: if your claim looks well founded in principle and recovery looks threatened, the judge can let you freeze assets or take judicial security without warning the debtor first. An English judgment, even before exequatur, powerfully shows that the claim looks well founded, and a debtor with known French assets plus signs of dissipation, transfers to relatives, sudden emptying of accounts, a flat quietly put up for sale, meets the threat test. The order is usually obtained quickly and without the debtor being heard (sur requête), then served by surprise by the commissaire de justice. Typical targets are a saisie conservatoire over a French bank account, which freezes the credit balance up to your claim, and a hypothèque judiciaire provisoire (provisional judicial mortgage) over a French flat or house, which blocks any sale without your charge being paid. These measures do not pay you yet; they hold the assets still while the exequatur runs. Used early, they change the negotiation completely, because the debtor discovers the freeze from his bank, not from you.
Once exequatur is granted, your position transforms. Under article L111-2 of the Code of Civil Enforcement Procedures, “Le créancier muni d’un titre exécutoire constatant une créance liquide et exigible peut en poursuivre l’exécution forcée sur les biens de son débiteur dans les conditions propres à chaque mesure d’exécution.” And article L111-3 expressly lists among enforcement titles “Les actes et les jugements étrangers ainsi que les sentences arbitrales déclarés exécutoires par une décision non susceptible d’un recours suspensif d’exécution, sans préjudice des dispositions du droit de l’Union européenne applicables”. Your English judgment with exequatur therefore becomes what French lawyers call a titre exécutoire (enforcement title), the key that unlocks forced execution. The general principle behind all of this sits in article L111-1: “Tout créancier peut, dans les conditions prévues par la loi, contraindre son débiteur défaillant à exécuter ses obligations à son égard.” From there the commissaire de justice serves a commandement de payer (formal demand to pay) and then chooses the measure that fits the assets found: saisie-attribution (garnishment in the hands of a third party) against bank balances or rent owed to the debtor, for which article L211-1 allows a creditor with an enforcement title for a liquid and due claim to “saisir entre les mains d’un tiers les créances de son débiteur portant sur une somme d’argent”; saisie-vente (seizure and sale) of vehicles, furniture or equipment; saisie des rémunérations (attachment of wages) through the court; or saisie immobilière (judicial sale of land) for larger debts, which is powerful but slow and expensive, so it suits substantial claims against property-rich debtors. Bank garnishment is usually the fastest money: served on the bank, it freezes and then allocates the available balance to you, subject to protected minimums and salary protections the officer must respect.
Every enforcement step is supervised by the juge de l’exécution, the specialist enforcement judge of the tribunal judiciaire, who hears disputes about validity, grace periods, apportionment and abuse. The officer cannot rewrite your title: as article R121-1 of the Code of Civil Enforcement Procedures puts it, “Le juge de l’exécution ne peut ni modifier le dispositif de la décision de justice qui sert de fondement aux poursuites, ni en suspendre l’exécution”, though after service of the demand or seizure act the same judge can grant a délai de grâce (time to pay) where the debtor’s good faith and hardship justify it. Expect the debtor to try the standard defences at this stage: appealing the exequatur judgment to delay finality, applying to the enforcement judge for instalments, claiming the debt was already paid in England, arguing set-off with a counterclaim, or alleging that seized funds are exempt. Some of these only suspend specific measures rather than cancelling the title, and an appeal against exequatur does not always stop protective freezes already in place. Keep paying attention to limitation and interest: English post-judgment interest continues to accrue as ordered, currency conversion uses the rate at the date of actual payment with the exchange risk handled transparently in the officer’s accounts, and your costs of enforcement are added within statutory scales. Insist on detailed statements from the officer after every distribution, reconcile them against the English order line by line, and chase any shortfall promptly rather than letting the file sleep.
Three practical moves separate successful creditors from stuck ones. First, investigate before you sue in France: a quick asset search through French land records (fichier immobilier via a notaire), commercial registry extracts for companies, and banking intelligence your officer can lawfully gather once enforcement starts will tell you whether the debtor actually holds a seizable account, a flat, shares or wages in France. There is no point winning exequatur against an empty pocket. Second, sequence freeze then substance: get the conservatoire in place fast on the strongest asset, then serve the exequatur writ from a position of strength, offering a structured settlement, lump sum with discount or monthly instalments with security, as an alternative to a forced sale. Debtors settle far more readily with a frozen account than with a mere threat. Third, coordinate London and Paris continuously: make sure nothing is still appealable in England without telling France, keep the English enforcement alive so limitation does not bite there, and ensure the sums claimed in France match the English balance after any part-payments, because claiming a penny more than is due destroys credibility and hands the debtor a fraud-flavoured argument. Where the debtor offers to pay in sterling from a London account to avoid French seizure, accept only through traceable transfer with a written allocation across principal, interest and costs, and confirm satisfaction to the French court so the file closes cleanly.
Conclusion
An English money judgment is not worthless in France after Brexit, but it is not self-executing either. The route runs through the tribunal judiciaire, either under Hague 2019 for qualifying recent commercial and civil judgments or under the classic Cornelissen exequatur for the rest, with the same practical core in both: prove the English court was a proper forum, show a fair process and a compatible outcome, exclude fraud and conflicting French decisions, then convert the stamped judgment into French seizures. The creditors who recover are the organised ones: they date their London claim correctly, arrive with sealed orders, apostilles and sworn translations, freeze the French account or charge the French flat before it vanishes, and claim exactly what remains due down to the last pound of interest. If your debtor lives, banks or owns in France, that discipline turns a distant London victory into money in your account. Start the asset check and the paper chase now, because time favours the debtor who moves funds and punishes the creditor who waits.
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