You did everything right. You issued the claim through Money Claims Online or at your local County Court, the defendant never filed a defence, and the court handed you judgment in default — a County Court judgment, the CCJ, ordering payment of the debt plus fixed costs and interest. Then the trail went cold: the debtor sold up, stopped answering letters, and resurfaced in France, salary paid into a French bank account, perhaps a house in the Dordogne or a flat in Paris. Your English enforcement options stop at the Channel. A High Court enforcement officer cannot cross into France with a writ of control, an attachment of earnings order does not bite on a French employer, and a third-party debt order cannot touch a bank account in Bordeaux. Since the end of the Brexit transition period, the fast European route is gone too: the Brussels I bis Regulation, which once let an English money judgment circulate in France almost automatically, no longer applies to proceedings started after 31 December 2020.

None of that means the money is lost. France enforces foreign money judgments every day, including English ones, through a court procedure called exequatur (the judicial declaration that makes a foreign judgment enforceable on French soil). Since 1 July 2025 there are even two doors into the French enforcement system instead of one: the Hague Convention of 2 July 2019 on the recognition and enforcement of foreign judgments, which now binds the United Kingdom and France, and the classic French common-law route built by the Cour de cassation around three famous tests. Each door has its own conditions, its own file of supporting documents, and its own traps — and the default CCJ, obtained without the debtor ever appearing, faces one scrutiny above all others, the fairness of the English procedure. Once the French judge stamps your judgment, a second phase begins: choosing between seizing the debtor’s French bank balance, sending a bailiff to seize and sell goods, or forcing the sale of French property. This guide walks a British judgment creditor through both phases in order. The companion general guide to enforcing an English court judgment in France, the three tests and challenging a refusal covers the framework in full; this article answers the concrete question creditors actually ask: my CCJ debtor now lives in France — how do I turn that piece of paper into money?

I. Turn your CCJ into a French enforcement title: the exequatur stage

French law states the starting point in a single sentence. Article 509 of the Code of Civil Procedure provides: “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.” An English judgment, even a final money judgment for a liquidated sum, has no direct executive force in France: no French bank, employer or land registry will act on it until a French court has declared it enforceable. That declaration is the exequatur, and the creditor’s first strategic decision is which legal basis to invoke. The answer depends on the date and nature of the English proceedings, because the Hague Convention of 2019 covers only part of the caseload.

A. The Hague 2019 Convention or the classic three-test route: which door for your CCJ?

The Hague Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters is the newest instrument in this field, and its calendar matters. France has been bound since 1 September 2023 through the European Union’s accession, and the United Kingdom ratified on 27 June 2024, with entry into force between the two on 1 July 2025, as the official status table of the Hague Conference on Private International Law records. In principle, then, an English money judgment given in proceedings started after that date can circulate to France under the Convention rather than through the old case-by-case route. But the Convention is selective: it applies only in civil or commercial matters, it excludes matters such as family law, insolvency, defamation and intellectual property, and — crucially for creditors — the judgment must satisfy one of the jurisdictional filters listed in its Article 5, for example that the defendant was habitually resident in England when the proceedings began, or that the debtor expressly agreed to the English court’s jurisdiction. A straightforward unpaid invoice claim against a customer who lived in Manchester when you issued, and who moved to France only after judgment, fits the paradigm case. A claim where the English court took jurisdiction on a fragile basis, by contrast, may fail the filter even though the judgment is perfectly valid in England.

Everything the Convention does not catch falls back on the French common-law regime — droit commun — built by the Cour de cassation, and this remains the workhorse for most CCJs. Its leading modern statement is recent: in a judgment of 12 March 2025 (First Civil Chamber, appeal no. 23-16.855), the Cour de cassation recalled that “Il résulte de l’article 509 du code de procédure civile que, pour accorder l’exequatur, 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.” Three tests, then, and each one bites on a different weakness of the creditor’s file. Indirect jurisdiction asks whether the dispute genuinely belonged before the English court: domicile of the defendant in England, a contract performed there, a jurisdiction clause, damage suffered there. Most County Court money claims pass comfortably where the debtor lived or traded in England at the time, which is also why you should pin down that fact with evidence — tenancy agreements, invoices showing an English address, the address used for service — before the debtor rewrites history from abroad. Conformity with French international public policy covers both substance and procedure: no punitive damages of a kind French law finds shocking, no judgment obtained by a procedure that offended fundamental fairness. Absence of fraud targets manipulation of jurisdictional rules, for instance suing in England solely to evade the debtor’s natural court where nothing connected the dispute to England.

Two points of that case law directly favour the British creditor chasing a debtor across the Channel. First, you do not need to show that the debtor already holds seizable assets in France to ask for exequatur. The Cour de cassation held on 26 June 2019 (First Civil Chamber, appeal no. 17-19.240) that “la demande de reconnaissance en France d’une décision étrangère n’est pas soumise à l’exigence de la détention sur le territoire français, par le débiteur de nationalité étrangère, non domicilié en France, d’actifs pouvant faire l’objet de mesures d’exécution forcée”, adding that “l’intérêt à agir existe dès lors que le demandeur à l’exequatur est la partie au procès au profit de laquelle la décision étrangère a été rendue”. In plain terms: the winner of the English case always has standing to seek exequatur, and the court cannot turn you away merely because you cannot yet point to a French bank account or property. That matters because asset-tracing usually comes after, not before, the French proceedings — the exequatur judgment itself unlocks the investigation measures that reveal where the money sits.

Second, the objection debtors raise most often against a default CCJ — “I never had my day in court” — is tested against a precise standard, not against rhetoric. The same 12 March 2025 judgment holds that “La contrariété à l’ordre public international de procédure d’une décision étrangère ne peut être admise que s’il est démontré que les intérêts d’une partie ont été objectivement compromis par une violation des principes fondamentaux de la procédure.” A debtor who was properly served with the English claim form, had the full time to file a defence or an acknowledgement of service, and simply ignored the proceedings will struggle to show that his interests were objectively compromised: English default procedure gives the defendant notice and time, and silence is a choice. The danger zone is service. If the claim form was sent to an old address, returned undelivered, or served by a method the debtor can plausibly deny receiving while living abroad, the French judge will examine — as the Cour de cassation requires — whether the defendant genuinely benefited from a fair trial with respect for the rights of the defence, including the adversarial principle. Creditors should therefore assemble the service story as carefully as the debt story: the address used, the method of service, any response or payment proposal from the debtor, and the certificate of service. A CCJ obtained after solid personal or postal service at the debtor’s then English home is a strong file; a CCJ obtained after service at an address the debtor had already left is the file that fails.

B. The file the tribunal judiciaire will demand: certified copy, proof of service, translation and interest computation

Exequatur is applied for before the tribunal judiciaire (the French civil court of general jurisdiction), with the debtor called to the proceedings so that he can raise his objections — there is no rubber stamp. The application stands or falls on documents, and the sensible creditor prepares the English side of the file before instructing French counsel, because every missing paper costs months. Start in England. The Civil Procedure Rules provide a dedicated mechanism for exactly this situation: rule 74.12 of the Civil Procedure Rules states that “A judgment creditor who wishes to enforce in a foreign country a judgment obtained in the High Court or in the County Court must apply for a certified copy of the judgment.” Apply to the court that gave judgment for a sealed, certified copy; the supporting evidence for that application itself shows what the French judge will later want to see, namely the claim form, evidence that it was served on the defendant, the statements of case, confirmation that the judgment has been served and is not subject to a stay, the appeal position, the unsatisfied balance, and the interest position. Gather those exhibits at the same time: the French court will ask, in its own vocabulary, for precisely the same story — what was claimed, how the debtor was informed, what the court decided, and what remains unpaid.

Three practical requirements then convert the English file into a French-ready one. First, proof that the judgment is final and enforceable in England: a judgment under appeal or subject to a stay of execution should not be presented until the English position is settled, since the French judge checks enforceability in the state of origin. If the debtor has applied to set the CCJ aside in England, deal with that application first; an exequatur granted on a judgment later set aside is wasted money. Second, translation. The French court works in French: the judgment, the claim form and the certificate of service need a full translation by a traducteur assermenté (a sworn translator registered with a French cour d’appel), and figures must be translated as carefully as words — principal, costs, interest rate and dates. A cheap summary translation invites the debtor’s counsel to dispute what the judgment actually orders, and a disputed translation can adjourn the case while a court-appointed translator redoes the work at your expense. Third, the money arithmetic. English judgments carry interest — typically 8 per cent a year on the outstanding sum under the County Courts (Interest on Judgment Debts) Order 1991 — and the French judge needs a clear statement of the sterling principal, the accrued interest to a stated date, the daily rate thereafter, and the costs awarded. Set out the computation in a schedule annexed to the application, because that schedule later becomes the décompte (the itemised breakdown of sums claimed) on which the French bailiff’s seizure documents are built.

Two time rules frame the whole exercise. On the French side, Article L.111-4 of the Code of Civil Enforcement Procedures provides that “L’exécution des titres exécutoires mentionnés aux 1° à 3° de l’article L. 111-3 ne peut être poursuivie que pendant dix ans, sauf si les actions en recouvrement des créances qui y sont constatées se prescrivent par un délai plus long.” Once the exequatur converts the CCJ into a French enforcement title, you have ten years to pursue execution — generous, but the clock for obtaining exequatur itself is governed by the limitation rules applicable to the underlying claim, so a creditor sitting on a 2019 CCJ should move rather than assume time is unlimited. On the English side, the judgment debt itself remains enforceable in England for six years for a fresh action on the judgment, and permission is needed to enforce after six years; aligning both calendars avoids the embarrassment of winning exequatur in France for a debt whose English enforcement has gone stale. Finally, anticipate the debtor’s defences instead of discovering them at the hearing: defective service, an argument that the English court lacked jurisdiction, a claim that the sum has been partly paid, or — for larger cases — an allegation that the Hague Convention’s filters are not met. Each defence corresponds to a document in your file. Where the debtor was properly served at his English address, where the contract or the damage anchored the case in England, and where nothing has been paid, the file answers every question before it is asked, and exequatur follows.

II. Get paid in France: seizures, sales and the debtor’s last defences

The exequatur judgment changes the legal nature of your CCJ: it becomes a French titre exécutoire (enforcement title), the key that unlocks the full arsenal of French forced execution. Article L.111-3 of the Code of Civil Enforcement Procedures lists as 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”. From that moment the creditor’s position is governed by a simple principle stated in Article L.111-1: “Tout créancier peut, dans les conditions prévues par la loi, contraindre son débiteur défaillant à exécuter ses obligations à son égard.” All execution is carried out by a commissaire de justice (the enforcement officer, formerly called huissier de justice), never by the creditor himself, and every measure follows a prescribed sequence in which each document must be served correctly. Choosing the wrong measure wastes fees; choosing the right one in the wrong order hands the debtor a nullity argument. The three measures below cover nearly every CCJ-against-expat situation, in ascending order of cost and weight.

A. Bank seizure, seizure of goods or forced sale of property: choosing the right measure

The fastest route to money is the saisie-attribution, the seizure of a debt owed to your debtor by a third party — in practice, the credit balance of the debtor’s French bank account, or sums owed by the debtor’s French employer. Article L.211-1 of the Code of Civil Enforcement Procedures provides: “Tout créancier muni d’un titre exécutoire constatant une créance liquide et exigible peut, pour en obtenir le paiement, saisir entre les mains d’un tiers les créances de son débiteur portant sur une somme d’argent, sous réserve des dispositions particulières à la saisie des rémunérations prévue par le code du travail et par le présent code.” The mechanism is immediate in its effect: the enforcement officer serves the seizure deed on the bank, and the account balance existing that day is frozen to your benefit up to the amount claimed, with the seizure attributed to you directly if nobody contests within one month. No prior warning to the debtor is required — warning would defeat the purpose — but the formalism is strict. Article R.211-1 requires that “Le créancier procède à la saisie par acte d’huissier de justice signifié au tiers”, and that the deed state, among other mandatory particulars, “L’énonciation du titre exécutoire en vertu duquel la saisie est pratiquée” together with a separate account of the sums claimed in principal, costs and accrued interest, plus a provision for interest falling due within the one-month contestation period. In cross-border practice this is where the English interest schedule prepared at the exequatur stage pays for itself: the bailiff converts the sterling balance at a stated rate, adds the English judgment interest, and the deed shows its arithmetic. Two limits must be respected. Certain sums are unseizable — social minima and a protected bank balance (solde bancaire insaisissable) remain with the debtor — and wages follow a special protective procedure rather than the ordinary bank seizure. A debtor paid in cash, banking outside France, or keeping only exempt minima on the account is a poor target for this measure, and the creditor should know the answer before paying for the deed: French banks disclose the seized position only after service, so blind seizures against every high-street bank multiply costs.

Where there is no useful bank balance but the debtor visibly lives well in France — car, furniture, equipment of a trade — the saisie-vente (seizure and sale of tangible movables) applies. Article L.221-1 provides: “Tout créancier muni d’un titre exécutoire constatant une créance liquide et exigible peut, après signification d’un commandement, faire procéder à la saisie et à la vente des biens meubles corporels appartenant à son débiteur, qu’ils soient ou non détenus par ce dernier.” Note the precondition absent from the bank seizure: a commandement de payer (formal order to pay) must first be served, giving the debtor eight days to pay before the officer returns to draw up the inventory. That eight-day window is real — many debtors pay, or propose a plan, once an officer has listed the contents of the living room — and if nothing is paid, the goods are sold at auction, traditionally at the hôtel des ventes. The measure suits mid-size debts where the debtor has a furnished French home; it is useless against a debtor renting an empty flat and poor value for small debts, because removal, storage and auction fees can consume the proceeds. Certain everyday items are exempt as necessary for family life, and goods already seized by another creditor can be joined by opposition, so a prior check for existing seizures avoids paying for an empty inventory.

For substantial CCJs, the heavy artillery is the saisie immobilière, the forced sale of the debtor’s French property. Article L.311-1 states its purpose bluntly: “La saisie immobilière tend à la vente forcée de l’immeuble du débiteur ou, le cas échéant, du tiers acquéreur en vue de la distribution de son prix.” The procedure runs before the enforcement judge (juge de l’exécution) of the tribunal judiciaire where the property sits: commandement to pay served and published at the land registry (service de publicité foncière), orientation hearing fixing the method of sale — amicable sale within a deadline or forced auction — then sale and distribution of the price among registered creditors. It is slow, typically a year or more, and expensive in procedural fees, but it is also the measure the debtor fears most, and its mere publication at the land registry often breaks a stalemate: a debtor who ignored two countries’ courts tends to find money when his house is advertised for auction. It fits debts large enough to justify the cost, typically several tens of thousands of euros, secured in effect against a property with real equity after the French mortgage lender is paid. One interest rule helps every creditor at this stage regardless of measure: Article 1231-7 of the Civil Code provides that “En toute matière, la condamnation à une indemnité emporte intérêts au taux légal même en l’absence de demande ou de disposition spéciale du jugement”, so the French statutory rate protects the creditor against delay even where the English interest computation is disputed — though the English contractual or judgment rate, duly proved, generally remains the better claim.

B. The debtor’s last defences and the creditors’ classic mistakes

A determined debtor has two battlegrounds left, and the creditor should price both before starting. The first is the exequatur judgment itself: the debtor can appeal it, and while the appeal runs, the creditor’s ability to proceed to irreversible measures is constrained — the enforcement title must rest on a decision “non susceptible d’un recours suspensif d’exécution”, in the words of Article L.111-3. In practice, creditors often secure exequatur and then negotiate from that position of strength rather than racing to auction while the appeal clock runs. The second battleground is each enforcement measure, contested before the juge de l’exécution within one month of service. The judge’s powers on contestation are fenced: Article R.121-1 recalls that “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. Toutefois, après signification du commandement ou de l’acte de saisie, il a compétence pour accorder un délai de grâce.” The debtor cannot ask the enforcement judge to retry the English case — the merits are closed — but he can plead nullities in the seizure documents, claim exemptions, and above all request time: a délai de grâce (a court-granted grace period of up to two years for a debtor in genuine difficulty) suspends the sale while preserving the seizure. Creditors who keep their documents formally perfect and their interest computations transparent give the judge no nullity to find, leaving only the hardship plea, which a debtor who organised his own insolvency by moving assets abroad will struggle to sustain.

The creditors’ mistakes, seen file after file, are depressingly predictable. The first is sending English enforcement machinery to France: paying a High Court enforcement officer for a writ of control, or a process server to “serve” English enforcement papers on a French address, achieves nothing and the fees are unrecoverable. Only the French route — exequatur, then commissaire de justice — moves money. The second is launching exequatur against a judgment that is not yet solid in England: a CCJ the debtor is genuinely applying to set aside, a sum already partly paid without receipt, or an appeal pending. The French judge will find out, usually through the debtor’s counsel, and the creditor pays both sides’ costs of the lesson. The third is currency sloppiness: claiming a round euro figure “equivalent” to the sterling judgment without stating the rate, the date of conversion and the continuing English interest. French enforcement documents require an exact, checkable breakdown, and a vague conversion is the easiest nullity a debtor’s lawyer ever pleads. State the sterling principal, the rate applied and its date, the English interest accrued to a fixed date with its daily running rate, and the costs — then let the bailiff’s deed mirror those figures. The fourth is ignoring the economics: exequatur plus a bank seizure is proportionate for a few thousand euros; a forced property sale is not. Match the weapon to the debt, and consider that a well-served commandement or a published property seizure often produces payment without going to the end. The fifth and most expensive is delay without investigation. Debtors who move countries restructure: accounts empty, property transferred to a new partner, income rerouted through a foreign company. The years between the CCJ and the exequatur application are the years in which traces fade. Instruct asset enquiries early, preserve the service file from the English proceedings, and move while the paper trail is warm.

Conclusion

A County Court money judgment does not die at Dover. Since Brexit it travels by exequatur rather than by European passport, and since 1 July 2025 the Hague Convention of 2019 offers a second, convention-based door alongside the classic three-test route restated by the Cour de cassation in March 2025 — indirect jurisdiction of the English court, conformity with French international public policy in substance and procedure, and absence of fraud. The creditor who arrives with a sealed and certified copy of the judgment, clean proof that the debtor was served and chose not to defend, a sworn translation and a rigorous sterling-to-euro computation gives the tribunal judiciaire everything it needs and the debtor’s counsel nothing to work with. Standing requires no prior proof of French assets: the winner of the English case is entitled to seek exequatur, and the resulting French enforcement title keeps its force for ten years. From there, French execution law offers a graduated response — the bank seizure that freezes an account overnight, the seizure and sale of movables after the eight-day commandement, and the forced sale of French property for the largest debts — each surrounded by strict formalities that reward the careful creditor and punish the improviser. Debtors move; judgments, properly domesticated, follow. The creditors who recover are not those with the biggest claims but those who treat enforcement as a second procedure in its own right: the right door, the complete file, the proportionate measure, and no English shortcuts on French soil.