You won your case in England. A County Court has ordered the other side to pay you \u00a386,000 in rent arrears, or to compensate you after a road accident in the Dordogne \u2014 and yet the money sits in France, where the debtor lives or holds property. Before Brexit, this was almost a formality: under the Brussels I bis Regulation, an English judgment circulated across the European Union with no middle step. Since 1 January 2021, the United Kingdom has become a third country for judicial cooperation, and that shortcut is gone. To seize a French bank account, instruct a French enforcement officer or force a sale, you must first ask a French court to make the English decision enforceable on French soil. That court order has a name every British claimant should learn: exequatur<\/i>, the judicial decision that gives a foreign judgment force ex\u00e9cutoire<\/i> (enforceability backed, if needed, by the French enforcement authorities). The good news is that Paris judges are already granting it to English orders. On 11 September 2024, the enforcement chamber of the Paris tribunal judiciaire<\/i> (the ordinary civil court of first instance) declared two Central London County Court orders enforceable in France, and on 23 October 2024 it did the same for a South Shields County Court judgment against a French insurer. This guide explains, for a British reader, which enforcement route fits your case, the three tests the French judge applies, the exact filing steps with the papers Paris expects, and what to do if exequatur is refused.<\/p>\nI. Which enforcement route still carries an English judgment into France after Brexit?<\/h2>\n
A. From Brussels I bis to the Hague Conventions and the 1934 treaty: finding the right legal bridge for your order<\/h3>\n
The first question is not whether your English judgment deserves<\/i> enforcement, but which legal bridge still connects London to Paris for your type of case. Start with the date. As French scholars summarise the rupture: from the start of 2021 the Brussels I bis Regulation, along with the other European private-international-law regulations, stopped applying to the United Kingdom, which became a third country to the European Union. Only proceedings instituted before the end of the transition period, on 31 December 2020, kept the old European recognition route under the Withdrawal Agreement’s transitional rules. If your English claim was started in 2021 or later \u2014 the situation of nearly every British reader today \u2014 you must look to the conventions in force between France and the United Kingdom, or fall back on French domestic law.<\/p>\n
The second bridge is the Hague Convention of 30 June 2005 on choice-of-court agreements, to which the United Kingdom is a party. It helps, but only in one narrow situation: judgments given following an exclusive jurisdiction clause that gives the English court sole power to decide. The English Court of Appeal has even refused to apply the 2005 Convention where the foreign court was chosen through a non-exclusive clause. So if your contract gave the London courts exclusive jurisdiction and the judgment follows from that clause, cite the 2005 Convention. In every other commercial or civil case, it will not carry you.<\/p>\n
The third bridge is the Hague Convention of 2 July 2019 on the recognition and enforcement of foreign judgments in civil or commercial matters. it has applied in France since 1 September 2023 and in the United Kingdom since 1 July 2025, after the British signature of 12 January 2024. That sounds like the post-Brexit replacement everyone waited for, but read the small print before celebrating. First, the time rule: what counts is when proceedings were started in the country of origin, and the Convention must already have been in force in both countries on that date. In plain terms, an English action launched before 1 July 2025 cannot travel to France on this bridge, because the Convention was not yet binding on the United Kingdom when the case began. Second, the subject-matter exclusions are wide: beyond the usual carve-outs for tax, customs and administrative matters, sensitive areas such as personal status are excluded. If your order concerns maintenance, divorce or children, different instruments apply \u2014 our guide on British divorce recognition after Brexit<\/a> maps the family route. For the classic money judgment from recent English proceedings, the 2019 Convention will matter more in the coming years than it does for cases already in the pipeline.<\/p>\n The fourth bridge is the oldest one: the Franco-British Convention for the enforcement of judgments signed on 7 January 1934. Both sides in the 23 October 2024 Paris judgment (RG 23\/05167)<\/a> agreed that the exequatur request was governed by it, and the court applied its articles 2 to 8, setting out the article 3 recognition test in full But handle it with care. One Paris chamber, a month earlier, took the opposite view in a similar English-orders case, holding, in the 11 September 2024 Paris judgment (RG 23\/11042)<\/a>, that “Aucune convention bilat\u00e9rale ne r\u00e9git les r\u00e8gles de reconnaissance des d\u00e9cisions judiciaires entre la France et le Royaume-Uni.” And even where the 1934 treaty applies, it only covers judgments ordering payment of a sum of money, while subjects such as personal status, family relations, succession, bankruptcy and the winding-up of legal persons are left out. The practical lesson from Paris is therefore to plead in the alternative: invoke the 1934 Convention where your money judgment fits it, and always argue the French common law (droit commun<\/i>) as a safety net. Under that fallback, the anchor text is Article 509 of the Code of Civil Procedure<\/a>, which provides: “Les jugements rendus par les tribunaux \u00e9trangers et les actes re\u00e7us par les officiers \u00e9trangers sont ex\u00e9cutoires sur le territoire de la R\u00e9publique de la mani\u00e8re et dans les cas pr\u00e9vus par la loi.” The full exequatur framework sits in Articles 509 to 509-9 of the Code of Civil Procedure, built around Article 509<\/a>, and the official service-public.fr guide on enforcing a foreign civil judgment<\/a> confirms the starting point for every non-EU judgment: a ruling from outside the EU has no direct effect in France and must go through exequatur<\/p>\n Whichever bridge you take, the French judge runs the same three checks. The Cour de cassation (France’s supreme court for civil matters) restated them in May 2025 in a 7 May 2025 ruling, First Civil Chamber, appeal no. 23-18.558<\/a>: “Pour accorder l’exequatur, le juge fran\u00e7ais doit, en l’absence de convention internationale et en dehors du champ d’application des r\u00e8glements europ\u00e9ens, s’assurer que trois conditions sont remplies, \u00e0 savoir la comp\u00e9tence indirecte du juge \u00e9tranger, fond\u00e9e sur le rattachement du litige au juge saisi, la conformit\u00e9 \u00e0 l’ordre public international de fond et de proc\u00e9dure ainsi que l’absence de fraude.” The Paris enforcement chamber used the same formula for the English County Court orders in the 11 September 2024 Paris judgment (RG 23\/11042)<\/a>, requiring the foreign decision to satisfy “les conditions de comp\u00e9tence indirecte du juge \u00e9tranger fond\u00e9e sur le rattachement du litige au for saisi, de conformit\u00e9 \u00e0 l’ordre public international de fond et de proc\u00e9dure et d’absence de fraude.” Here is what each test means for a British claimant.<\/p>\n First, the indirect jurisdiction of the English judge: was there a genuine link between the dispute and England? French conflicts rules accept familiar anchors such as the defendant’s domicile, the place of the harmful act or the place where damage was suffered, and the location of leased property. In the September 2024 case, the link was the London flat at the heart of the tenancy, and the court accepted jurisdiction “au regard du lieu de situation du bien immobilier objet du contrat de bail” (11 September 2024 Paris judgment (RG 23\/11042)<\/a>). In the October 2024 case, a British holidaymaker injured in the Dordogne had sued in England; the court held that because part of the damage materialised in the United Kingdom after her medical repatriation, the English courts had a valid basis “au regard des r\u00e8gles internes fran\u00e7aises” (23 October 2024 Paris judgment (RG 23\/05167), \u00a73.1<\/a>). Choose your anchor and prove it with documents: tenancy agreement, accident report, medical records showing treatment in England.<\/p>\n Second, compatibility with French international public policy, on substance and on procedure. The reassuring part is that the French judge does not retry your case. The service-public.fr guide on enforcing a foreign civil judgment<\/a> puts it plainly: the judge does not change the content of the foreign ruling and only checks that it can apply in France What the judge does check is that defence rights were respected: the defendant must have been told about the English claim in good time, with translated documents, and must have had a real chance to respond and to appeal. In the October 2024 case, service of the claim form and detailed particulars on the French insurer on 10 June 2021, all translated by a professional translator, plus a 21-day appeal window under section 52 of the English Civil Procedure Rules, satisfied the court that defence rights \u2014 and therefore French international public policy \u2014 had been respected. The September 2024 case goes further and helps British claimants with typical unreasoned County Court orders: those orders carried no written reasoning, yet exequatur was granted because the claimant filed a letter from his English solicitor explaining the mandatory possession ground, the hearing bundles, and a certificat de coutume<\/i> (a formal opinion on English law and procedure) confirming finality and the expiry of the 21-day permission-to-appeal period. An English order that looks thin on paper can therefore pass, provided you surround it with proper evidence of English procedure.<\/p>\n Third, the absence of fraud. The May 2025 Cour de cassation ruling widens this beyond the classic fraude \u00e0 la loi<\/i> (deliberately shifting the legal relationship only to dodge the normally applicable law): the court held, in the 7 May 2025 ruling, First Civil Chamber, appeal no. 23-18.558<\/a>, that “Le contr\u00f4le de l’absence de fraude ne se limite pas \u00e0 la seule fraude \u00e0 la loi” Hiding decisive facts from the foreign judge \u2014 in that case, concealing a French compensatory award already covering the same pension rights so the German judge granted a double recovery \u2014 is fraud that blocks exequatur. For British litigants the message is symmetrical and protective: run your English case honestly, disclose parallel French proceedings and French decisions to the English judge, and keep proof that you did. That same honesty also protects you if the debtor cries fraud in Paris.<\/p>\n Start with the non-negotiable: you need a French avocat<\/i> (a lawyer admitted to a French bar). The service-public.fr guide on enforcing a foreign civil judgment<\/a> is categorical: only an avocat can seize the tribunal judiciaire with an exequatur application The same applies on appeal, with legal aid (aide juridictionnelle<\/i>) available if your means are limited. Your lawyer seizes the tribunal judiciaire<\/i> by assignation<\/i> \u2014 a formal summons served by a commissaire de justice<\/i> (the enforcement officer formerly called huissier de justice<\/i>) telling the debtor that proceedings are brought and summoning them \u2014 or, in simpler configurations, by joint petition. Which court? The guide designates the tribunal of the place where the defendant lives, if known; otherwise the court of the claimant’s home or the court of their choice if the defendant lives abroad, with the property-location court available for real-estate-linked cases. This mirrors the general territorial rule of Article 42 of the Code of Civil Procedure<\/a>. Where the debtor has French assets but no known French address, your lawyer will pick the forum strategically \u2014 often Paris, whose enforcement chamber handles these cases every week.<\/p>\n Next, assemble the file the way Paris likes it. The two 2024 decisions read like a checklist of what persuades and what nearly sinks an application. The papers: the exp\u00e9dition<\/i> (the certified enforceable copy) of the English judgment; proof that it was notified to the defendant; proof that it is final and enforceable under English law \u2014 in both Paris cases, a solicitor’s certificat de coutume<\/i> confirming the 21-day appeal period and the absence of any appeal did the job; full French translations by a qualified translator (translation costs can be recovered as part of the legal costs under Article 695(2\u00b0) of the Code of Civil Procedure, as the October 2024 court expressly ordered); and, where the order is unreasoned, explanatory English-law evidence such as counsel’s letter and the hearing bundle. One warning from the October 2024 file: the insurer attacked discrepancies between the judgment copy and the court minute and the informality of counsel-judge correspondence. Produce clean, consistent, professionally translated exhibits, and have your English solicitor confirm authenticity in writing. Keep every translator invoice: the October 2024 court expressly ordered that the recoverable costs include translation expenses, under Article 695 of the Code of Civil Procedure<\/a>. And insist that your lawyer place each request \u2014 exequatur itself, interest, costs \u2014 in the operative part of the written submissions, not only in the reasoning. The same October 2024 judgment refused to rule on a challenge to exhibits precisely because it appeared in the reasoning but not in the operative part, recalling that the court decides only on the claims stated there under Article 768 of the Code of Civil Procedure<\/a>.<\/p>\n Two money questions arise in every file. First, interest. The September 2024 claimant asked for the English 8% judicial rate running from the 2022 order; the Paris court refused and applied French law to the effects of the enforced decision, holding that the \u00a392,186.22 total would bear interest at the French statutory rate from the exequatur judgment, under Article 1231-7 of the Civil Code<\/a>. Budget on the French legal rate, not the English judgment rate. Second, costs. Expect the loser-pays logic of Article 700 of the Code of Civil Procedure<\/a>: Paris awarded \u20ac2,000 and \u20ac2,500 respectively against the losing debtors, plus full costs. Finally, note the enforcement edge the 23 October 2024 Paris judgment (RG 23\/05167)<\/a> records: “L’ex\u00e9cution provisoire de ce jugement est de droit en application de l’article 514 du code de proc\u00e9dure civile” \u2014 provisional enforcement as of right, within the framework of Articles 514 and following of the Code of Civil Procedure. In practice, move quickly once granted, but expect the debtor to appeal and to ask for a stay of provisional enforcement while the appeal runs (see Article 514-3 of the Code of Civil Procedure<\/a>).<\/p>\n If exequatur is refused, do not treat the refusal as the end of the road \u2014 treat it as a diagnosis. The Paris decisions show exactly which defects are curable. Service attacked as late or untranslated? Re-serve properly through the correct cross-border channel and re-file with dated proof and sworn translations. Finality doubted? Add the solicitor’s certificate on the 21-day rule and the absence of appeal. Jurisdiction questioned? Rebuild the link \u2014 defendant’s French domicile, situs of the property, place where damage was suffered \u2014 with exhibits rather than assertions. The standard remedy is an appeal (appel<\/i>) to the cour d’appel<\/i>, where representation by an avocat is again compulsory; the appeal re-examines the three tests, and the 2024 Paris files show that courts engage seriously with detailed procedural evidence. Where the 1934 Convention route was the problem \u2014 for example a non-money order or an excluded subject \u2014 reframe under French common law and Article 509 instead of insisting on the treaty. And where the order itself is the problem, consider going back to England first: a properly reasoned Tomlin order, a corrected judgment or a fresh certificate from the English court can transform a weak Paris file into a strong one. Coordinate your French avocat with your English solicitor from day one; exequatur files are won in pairs, not solo.<\/p>\n Once exequatur is granted and final, the English order becomes a French enforcement title like any other. If the debtor still does not pay voluntarily, the official guide points to the next stage: forced execution proceedings through a commissaire de justice<\/i>, such as attachment. Concretely, that means third-party attachment of French bank accounts (saisie-attribution<\/i>), attachment of earnings, or seizure and sale of property, served on the strength of the exequatur judgment. Before spending on seizures, verify the debtor’s footprint: French land registry for property, employment clues for earnings attachment, and any known bank relationships. Every seizure must first have been authorised by a valid title \u2014 which is precisely why, as the service-public.fr guide on enforcing a foreign civil judgment<\/a> stresses, only duly notified foreign judgments can be enforced in France: no notification, no enforcement. Keep the chain clean \u2014 English judgment, proof of service, certified translation, exequatur judgment, service of the exequatur judgment \u2014 and the commissaire de justice can act.<\/p>\n Two traps deserve a final warning. First, limitation and delay. English judgments do not last forever in the eyes of French enforcement law, evidence of English procedure goes stale, and debtors move assets while you hesitate. Start the certificat de coutume and translation work the week the English order becomes final. Second, parallel proceedings. If a French court is already seized of the same dispute between the same parties, or has already ruled, the foreign judgment can be blocked \u2014 under the 1934 Convention’s article 3(c)(1) and under common law through the authority of the French res judicata. Check the French docket before filing, and if the debtor sues in France to pre-empt you, tell your avocat immediately so the race to judgment is managed rather than suffered.<\/p>\n Enforcing an English judgment in France after Brexit takes longer than the old Brussels routine, but the Paris enforcement chamber is showing British claimants a clear, working path. Identify your bridge \u2014 transitional EU rules for pre-2021 proceedings, the Hague 2005 Convention for exclusive English jurisdiction clauses, the Hague 2019 Convention for recent qualifying cases, the 1934 treaty for money judgments, and otherwise the French common law of Article 509. Then pass the three tests the Cour de cassation restated in May 2025: a genuinely connected English judge, defence rights compatible with French public policy, and a file free of fraud. File through a French avocat with certified, translated, fully evidenced papers, budget on the French statutory interest rate, and move fast once exequatur is granted. Handled that way, an English court victory does not stop at Dover: it ends, as it should, with payment in France \u2014 by agreement, or by seizure.<\/p>\n If you are a British national holding an English court judgment that must be enforced in France, or facing enforcement steps after Brexit, our firm offers a telephone consultation within 48 hours with a lawyer of the firm. Call +33 6 46 60 58 22<\/a> or write via our contact page<\/a>. We act in Paris and across \u00cele-de-France as well as throughout France, in English, and coordinate with English solicitors on coutume certificates, translations and parallel proceedings where needed.<\/p>\n","protected":false},"excerpt":{"rendered":" Won in an English court but the money is in France? A British guide to enforcing English judgments after Brexit: exequatur routes, the three tests, filing steps and appeals.<\/p>\n","protected":false},"author":251031309,"featured_media":16384,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_kj_source_type":"","_kj_official_id":"","_kj_official_url":"","_kj_judilibre_id":"","_kj_jur":"","_kj_lieu":"","_kj_chambre":"","_kj_rg":"","_kj_date":"","activitypub_content_warning":"","activitypub_content_visibility":"","activitypub_max_image_attachments":4,"activitypub_interaction_policy_quote":"anyone","activitypub_status":"federated","footnotes":""},"categories":[80312,80314],"tags":[],"class_list":["post-2123955","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-british-desk","category-decryptage"],"yoast_head":"\nB. The three tests every English judgment must pass: competent foreign judge, French international public policy, no fraud<\/h3>\n
II. How do I get exequatur in practice, and what if the court says no?<\/h2>\n
A. Filing your exequatur application step by step: the right court, the right papers and the Paris checklist<\/h3>\n
B. Refusal, appeal and forced execution: challenging a “no”, locking in a “yes” and getting paid<\/h3>\n
Conclusion<\/h2>\n
Need a quick opinion on your case?<\/h2>\n