You won in France. After months of procedure before the French court, the judgment orders your former tenant to pay the arrears, or your builder to refund the deposit, or your ex-business partner to repay the loan. There is only one problem: the debtor has gone back to England, and the money, the wages and the house are there. Before Brexit, the answer was routine: a European regulation moved civil judgments between France and the United Kingdom almost automatically. That bridge is gone. Since the end of the Brexit transition period, a French judgment no longer circulates in England under European rules, and a new bridge had to be built. That bridge is the Hague Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters, known as Hague 2019. It entered into force for the United Kingdom on 1 July 2025, and the British government describes it as the first new agreement to apply in this area of law between the United Kingdom and the European Union since EU Exit (Ministry of Justice statement of 2 July 2025). For a British resident in France holding a French judgment against a debtor with assets in England and Wales, this changes everything: instead of starting the whole case again in London, you can ask the English High Court to register your French judgment and enforce it there. This article explains which French judgments qualify, how to make your French decision ready for England, how registration works, and how the debtor will try to resist.

I. The new bridge: which French judgments can cross to England

A. What Hague 2019 covers, and the cases it leaves on the French side

Hague 2019 is a practical instrument, not a universal one. It applies to judgments in civil or commercial matters, and it lists at length the subjects it does not touch. Family breakdown, maintenance payments, wills and succession, insolvency, defamation, privacy claims and intellectual property are all outside the Convention. The official text (HCCH 2019 Judgments Convention, Articles 2 to 16) states that the Convention shall not apply to maintenance obligations, to other family law matters including matrimonial property regimes, to wills and succession, to insolvency and to defamation, among others. A British reader should absorb this limit early: a French divorce order, a maintenance decision or a succession ruling cannot travel under Hague 2019, however final it is. Money judgments in contract, tenancy arrears for a French letting, compensation for faulty building work, an unpaid invoice between businesses and damages for personal injury or property damage sit squarely inside the bridge, provided one of the Convention’s jurisdictional bases is met.

The most useful basis for a British claimant in France is also the simplest. A judgment is eligible when the person against whom enforcement is sought was habitually resident in France at the time that person became a party to the French proceedings. In plain terms, if you sued in France someone who lived in France when the case started, the resulting judgment can normally be recognised in England. The Convention says exactly this: a judgment is eligible for recognition and enforcement if the person against whom recognition or enforcement is sought was habitually resident in the State of origin at the time that person became a party to the proceedings in the court of origin. Companies are covered by equivalent tests, since a business counts as habitually resident where it has its statutory seat, its central administration or its principal place of business. Other bases matter for classic British-in-France disputes: a judgment on a contractual obligation qualifies when it was given by the court of the place where the obligation was or should have been performed, which covers the English builder who renovated your Dordogne house under a French contract; a judgment on a lease of immovable property qualifies when given where the property sits, which covers arrears on your French rental; and a judgment on death, physical injury or damage to tangible property qualifies when the act causing the harm occurred in France, which covers the road accident or the defective works that damaged your home. Two connected limits deserve attention. First, judgments about rights in rem in immovable property, meaning ownership itself as opposed to money claims, are recognised if and only if the property is situated in France. Second, interim protective measures, the urgent orders a French judge can grant before trial, are not judgments under the Convention at all: the text defines a judgment as a decision on the merits and adds that an interim measure of protection is not a judgment. So a provision ordering payment by way of advance may struggle, while the final condemnation travels. Consumers and employees get extra shelter: against them, some bases such as the place of contractual performance do not apply, and consent to jurisdiction must have been addressed to the court. A French lender enforcing a consumer credit contract against a borrower now back in Manchester should check this filter before spending money on registration.

Timing is the second gate, and it is strict. The Convention applies to the recognition and enforcement of judgments if, at the time the proceedings were instituted in the State of origin, the Convention had effect between that State and the requested State. Between France and the United Kingdom, the Convention has had effect since 1 July 2025, the date it entered into force for the United Kingdom; on the French side the European Union, which acceded by Council Decision (EU) 2022/1206, has been bound since the Convention entered into force on 1 September 2023 (HCCH status table). The practical reading is therefore simple: French proceedings started on or after 1 July 2025 produce judgments that can use the Convention route, while cases started before that date fall outside it and must use the old English common-law route, meaning fresh proceedings in England suing on the French judgment as a debt, with the extra cost and delay that implies. If your French case is still running and was started before July 2025, discuss with your French lawyer whether any new claim or new proceedings started now could produce a Convention-compatible judgment; do not assume, and do not let limitation periods drift while you decide.

B. Making your French judgment enforceable at home before sending it across the Channel

England will only enforce a French judgment that is already enforceable in France. The Convention says so twice: a judgment shall be recognised only if it has effect in the State of origin, and shall be enforced only if it is enforceable in the State of origin. Your preparation must therefore start in France, and it has four checkpoints: notification, expiry of appeals, enforceability and the file of documents. Each checkpoint corresponds to a French text you can verify.

First, the judgment must have been brought to the debtor’s knowledge. French law provides that judgments cannot be enforced against those to whom they are opposed until they have been notified to them, unless enforcement is voluntary. Notification by a judicial officer, in France a commissaire de justice, formerly huissier de justice, is called signification: the Code states that notification effected by a judicial officer is a signification, and that notification may always take that form even where the statute provided for another. The signification of a judgment must also, in highly visible terms, state the time limit and the procedure for opposition, appeal or cassation where such a remedy lies, and warn that an abusive or dilatory remedy can lead to a civil fine and damages. If the debtor already lives in England, service follows the cross-border channel: an act to be notified to a person habitually resident abroad is handed to the parquet, the French prosecution office attached to the court, except where a European regulation or an international treaty allows direct transmission, and the United Kingdom remains a party to the 1965 Hague Service Convention whose official status table is kept by the Hague Conference. A defective service in France becomes, months later, a refusal ground in England, because the Convention lets the English court refuse recognition where the document instituting the proceedings was not notified in sufficient time and in such a way as to let the defendant arrange a defence. Pay for proper service now rather than losing registration later.

Second, watch the appeal clock. In France the time limit for an ordinary remedy is one month in contentious matters, and that period runs from notification of the judgment, even against the party who served it. Read together, these two rules mean signification both unlocks enforcement and starts the debtor’s appeal period: one month from service in an ordinary civil case. If the debtor appeals, enforcement becomes fragile, because the Convention allows the English court to postpone or refuse enforcement where the judgment is under review in France or where the time limit for ordinary review has not yet expired. The safest file is therefore a judgment served, with the one-month period expired and no appeal lodged, or an appeal judgment that is itself final.

Third, confirm enforceability. A first-instance French judgment is enforceable once it has become final, has the force of res judicata, unless the debtor enjoys a stay or the creditor has provisional enforcement. Since the reform that took effect on 1 January 2020, first-instance decisions are provisionally enforceable as of right unless the statute or the decision itself provides otherwise. In practice this means many recent French judgments can be enforced immediately despite an appeal, which also makes them candidates for English registration, but you must still prove that enforceability with documents. Only decisions of the courts that have enforceable force count as enforcement titles under French law, which lists among enforceable titles the decisions of the judicial courts where they have enforceable force. Ask the court registry, the greffe, for an enforceable copy, and keep the certificate showing that no appeal was lodged if that is your situation.

Fourth, assemble the Convention file before instructing anyone in London. The Convention requires the applicant to produce a complete and certified copy of the judgment, plus, for default judgments, proof that the instituting document was notified to the absent party, plus any documents needed to show the judgment has effect or is enforceable in France. The applicant may add the model certificate issued by the French court in the form recommended by the Hague Conference, and anything not in English needs a certified translation. Commission a sworn translator, a traducteur assermenté, for the judgment, the signification slip and the enforceability proof: a cheap summary translation invites an objection that the English court cannot verify that the Convention’s conditions are met, in which case the court may demand further documents. Finally, remember the French clock: enforcement of judicial enforceable titles can in principle only be pursued for ten years, unless the underlying claim has a longer limitation period. A 2016 French judgment enforced in England in 2026 is vulnerable on this ground alone, so check the date before spending on translations.

II. Registering in England and defeating the debtor’s defences

A. Registration at the High Court: no retrial, only checks

England does not retry your French case. The Convention forbids review of the merits: there shall be no review of the merits of the judgment in the requested State, with only such consideration as is necessary to apply the Convention. The English procedure is therefore a registration system, not a retrial. Under the Civil Procedure Rules, applications to register foreign judgments for enforcement in England and Wales must be made to the High Court and may be made without notice, meaning the debtor is not heard at that first stage. The Rules expressly cover the 2019 Hague Convention, defined as the Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters concluded on 2 July 2019 at The Hague (CPR Part 74, Section I, rules 74.2 to 74.4). Your English lawyer files the certified French judgment with its translation and written evidence exhibiting the judgment or an authenticated copy, plus a translation where needed. Costs follow the judgment: the Convention counts a court’s determination of costs as part of the judgment where it relates to a decision on the merits that qualifies, and the English Rules likewise treat the determination of costs by an officer of the court as part of a foreign judgment. A French order that condemns the debtor to pay 40,000 euros in damages plus 3,000 euros under article 700 of the French Code of Civil Procedure, the provision on irrecoverable costs, therefore arrives in London as a single enforceable sum, not as two separate claims.

What the judge checks at registration is mechanical but unforgiving. Is it a decision on the merits from a French court, not an interim measure? Does it have effect and is it enforceable in France on the documents you produce? Was it given in proceedings started when the Convention was in force between France and the United Kingdom, meaning on or after 1 July 2025? Does at least one jurisdictional basis fit, most often the debtor’s French habitual residence when the proceedings began? Is the subject inside the Convention, meaning no maintenance, family, succession, insolvency, defamation or excluded matter lurking inside the operative part? A mixed judgment needs care: where a non-covered matter arose merely as a preliminary question and not as the object of the proceedings, the judgment is not excluded, and the mere fact that such a matter was raised by way of defence does not exclude it either. So a French court that notes incidentally, while condemning an unpaid invoice, that the debtor’s divorce is pending does not contaminate the money order. Once registered, the judgment is enforced like an English judgment, using the English enforcement toolkit chosen with your English lawyer against the debtor’s wages, bank accounts or property in England and Wales. Readers coming from the opposite direction, with an English county court judgment against a debtor who moved to France, face the mirror procedure before the French courts, described in our guide to enforcing an English CCJ in France through exequatur and seizure: how a British creditor enforces an English CCJ against a debtor who moved to France.

B. The six defences your debtor will raise, and how a clean French file defeats them

Refusal under Hague 2019 is exceptional: recognition or enforcement may be refused only on the grounds specified in the Convention. Those grounds are six, plus a pending-proceedings rule, and each maps to a precaution you can take in France today.

The first defence is defective notification. The English court may refuse where the instituting document was not notified in sufficient time and manner for the defendant to arrange a defence, unless the defendant appeared and argued without contesting notification where French law allowed it, or where notification in England used a method incompatible with English fundamental principles on service. This is why the signification chain described above matters so much: a French assignation served on a London defendant through the proper cross-border channel, with proof of delivery and time to respond, closes this door. Keep the huissier’s return slips, the certificate of service and evidence of the response time the defendant actually had.

The second and third defences are fraud and public policy. A judgment obtained by fraud can be refused, and recognition that would be manifestly incompatible with English public policy, including proceedings incompatible with fundamental principles of procedural fairness or involving infringements of security or sovereignty, can also be refused. These are high bars, not relitigation devices. French case law on the mirror question shows how strictly judges police the boundary: the First Civil Chamber of the Cour de cassation held in a Bulletin-published judgment of 28 June 2023 that for exequatur the French judge must verify three conditions, namely the indirect jurisdiction of the foreign court based on the link between the dispute and that court, compatibility with international public policy as to substance and procedure, and the absence of fraud. The same court added in a Bulletin-published judgment of 16 September 2020 that there can be no clash with international procedural public policy unless it is shown that a party’s interests were objectively compromised by a breach of fundamental procedural principles. Read the full reasoning at the Cour de cassation: Cass. 1re, 28 June 2023, No 21-19.766 and Cass. 1re, 16 September 2020, No 19-11.621. An English judge applying Hague 2019 reasons the same way: unfairness must be concrete and demonstrated, not a disagreement with French procedure. A debtor who was duly served, appeared through a French avocat, exchanged pleadings and lost on the evidence will struggle to turn public policy into a second appeal.

The fourth defence is a jurisdiction or trust clause pointing elsewhere: proceedings in France contrary to an agreement, or a designation in a trust instrument, sending the dispute to another State’s courts. British families using trusts for French property should note this one, since our trust guide explains how French tax treats the structure: the practical lesson is to check dispute-resolution clauses in loan, building and commercial contracts before suing in France, because a valid English jurisdiction clause can later block the French judgment in London.

The fifth and sixth defences concern conflicting judgments: inconsistency with an English judgment between the same parties, or with an earlier foreign judgment on the same subject that qualifies for English recognition. Parallel litigation is therefore dangerous. If the debtor has already sued you in London on the same contract, or has an earlier enforceable judgment from another country, your French victory may be stopped at registration. The Convention adds a related pending-proceedings rule: enforcement may be postponed or refused where the same dispute between the same parties was already pending before the English court, first seised, with a close connection to England. Before starting in France, search for English proceedings, act quickly, and avoid racing the debtor to two judgments at once. French domestic law states the background principle that foreign judgments are enforceable in France in the manner and cases provided by statute: article 509 of the French Code of Civil Procedure. Under Hague 2019 the logic is mutual: each side enforces the other’s regular judgments and each side may refuse the irregular ones on the same closed list.

Three final precautions decide most cases. First, serve immaculately and keep every slip, because notification is the most litigated ground. Second, register while the French judgment is enforceable and the appeal position is clean, since review pending in France justifies postponement. Third, translate everything by a sworn translator and attach the French court’s certificate of enforceability, because the English court verifies Convention compliance on the papers. The direct legal anchors for each step are public: enforceability from the moment of finality in article 501 of the French Code of Civil Procedure; prior notification in article 503; provisional enforcement as of right in article 514; appeal time running from notification in article 528 with the one-month period in article 538; signification by judicial officer in article 651; mandatory appeal information in article 680; service abroad through the parquet in article 684; enforceable titles in article L111-3 of the Enforcement Procedures Code; and the ten-year enforcement window in article L111-4.

Conclusion

A French judgment against a debtor in England is no longer a trophy without value. Since 1 July 2025, Hague 2019 gives a British resident in France a defined route: secure a final, duly served and enforceable French decision in proceedings started after that date, assemble the certified file with sworn translations, and apply to the English High Court for registration without notice, leaving the debtor to raise one of six closed defences. Cases started earlier, judgments about family, succession or maintenance, and interim orders stay outside the bridge and need different strategies. The decisive work happens in France, long before London: proper cross-border service, a clean appeal position and complete proof of enforceability. Built that way, a French money judgment crosses the Channel intact; built carelessly, it fails at the first English checkpoint.