{"id":2145200,"date":"2026-10-11T13:01:17","date_gmt":"2026-10-11T11:01:17","guid":{"rendered":"https:\/\/kohenavocats.fr\/2026\/10\/11\/british-english-judgment-france-exequatur-proof-challenge-brexit\/"},"modified":"2026-10-11T13:01:17","modified_gmt":"2026-10-11T11:01:17","slug":"british-english-judgment-france-exequatur-proof-challenge-brexit","status":"publish","type":"post","link":"https:\/\/kohenavocats.fr\/en\/2026\/10\/11\/british-english-judgment-france-exequatur-proof-challenge-brexit\/","title":{"rendered":"Your English Court Judgment in France After Brexit: Exequatur Routes, Proof the Paris Courts Require, and How to Challenge Enforcement"},"content":{"rendered":"

You won in England. A County Court has ordered the other side to pay you damages and costs, or the High Court has placed a company into administration, and the money or the assets sit in France: a house in the Dordogne, a bank account in Paris, a French insurer that refuses to pay. Since the United Kingdom left the European Union, that English judgment has no automatic effect on French soil. It must pass through a French judicial filter called exequatur<\/em> (the court order that declares a foreign judgment enforceable in France) before any commissaire de justice<\/em> (the enforcement officer, formerly known as huissier de justice<\/em>) can seize assets or compel payment. The good news, proved by three recent French decisions examined for this guide, is that Paris and Montpellier judges are granting exequatur to English judgments when the file is properly built. Part I maps the three routes still open after Brexit: the Franco-British convention of January 1934, the Hague Convention of 2 July 2019 in force for the United Kingdom since 1 July 2025, and the French common-law test in the absence of any treaty. Part II is strictly practical: which tribunal judiciaire<\/em> (the ordinary civil court of first instance) to seize, what evidence Paris judges actually require, how much translation and costs affect the outcome, and on what grounds enforcement can still be resisted. Every French term is explained when it first appears, and every decisive proposition is linked to its official text or to a judgment whose full wording was verified during the preparation of this article.<\/p>\n

I. Can Your English Judgment Still Be Enforced in France After Brexit?<\/h2>\n

A. The Two Treaty Routes: the 1934 Franco-British Convention and the Hague 2019 Convention<\/h3>\n

Before Brexit, enforcement between British and French courts was nearly automatic under the European Union regulation on jurisdiction and judgments in civil and commercial matters, known as Brussels I bis. That era is over for judgments given by British courts: the simplified European procedure, in which you simply ask the court registry to record the enforceability of a European decision, no longer covers the United Kingdom. The official guidance of the French administration describes that simplified route as a procedure in which you ask the directeur de greffe<\/em> (the head of the court registry) of the tribunal judiciaire<\/em> to certify enforceability, and it states plainly that it consists of asking that officer to confirm the enforceability of a decision given in Europe (Service-public.fr, execution of a foreign civil judgment in France<\/a>). An English judgment is no longer a decision given in Europe in that sense. Paris practice confirms the consequence bluntly: there is no automatic recognition, since enforcement still requires a French judge to examine the file in adversarial proceedings, though without re-trying the case itself. As French commentary on the new Convention explains, the exequatur procedure is adversarial and a foreign judgment is not open to forced execution until the French judgment ordering exequatur has become final (Actu-juridique, entry into force of the 2019 Hague Convention for the United Kingdom<\/a>). Two treaty routes therefore matter, and choosing the wrong one wastes months.<\/p>\n

The oldest route is the bilateral convention on the reciprocal enforcement of judgments in civil and commercial matters signed between France and the United Kingdom in January 1934. Its post-Brexit handling calls for care: commentary notes that only rare Court of Cassation decisions refer to the 1934 convention at all, whether to apply it or to exclude it (Actu-juridique, entry into force of the 2019 Hague Convention for the United Kingdom<\/a>). Yet French courts have in practice applied it to English judgments since Brexit where both sides accepted that framework. In a judgment given on 23 October 2024, the Paris tribunal judiciaire<\/em> recorded that both parties agreed the exequatur application was governed by the Franco-British convention for the enforcement of judgments of January 1934 (Paris tribunal judiciaire<\/em>, Exequatur formation, 23 October 2024, RG 23\/05167, full text verified from the Judilibre open-data record during the preparation of this article). The lesson for a British claimant is practical rather than academic: plead the 1934 Convention expressly in your application, because the Paris court will work with it, but build your file so that it also satisfies the common-law test described below, in case the court prefers that ground.<\/p>\n

What the 1934 Convention requires is set out in its Articles 2 and 3, reproduced verbatim in that Paris judgment. Article 2, as reproduced in that judgment, extends recognition as res judicata<\/em> and enforceability to judgments given by courts sitting on British or French territory, whatever the nationality of the winning or losing party, on the conditions stated in Articles 3 to 8 of the convention (Paris tribunal judiciaire<\/em>, 23 October 2024, RG 23\/05167). Article 3 then lists the only defences available: lack of jurisdiction of the court of origin under the private-international-law rules of the requested country; default judgment where the losing party proves the defendant never learned of the English action in time to respond, even if service complied with English law; contrariety to the public policy of the requested country, illustrated by prior local res judicata<\/em> between the same parties, fraud in obtaining the judgment, lack of amenability to the jurisdiction under public international law; and a pending appeal or opposition in the country of origin. In ordinary language: the English court must have had jurisdiction as French private international law sees it, a defendant condemned in its absence must have known about the case in good time, nothing must offend French international public policy (ordre public international<\/em>, the core values and procedural guarantees France refuses to compromise), and no appeal may still be pending. Each of these four locks is examined in Part II with the facts that opened or closed them in Paris.<\/p>\n

Two limits of the 1934 Convention must be understood before you rely on it. First, commentary on the reported cases stresses that the analysis concerns only judgments ordering the payment of a sum of money, adding that the 1934 Convention further excludes personal status, family relations, successions, bankruptcies and liquidations of legal persons including associations (Actu-juridique, entry into force of the 2019 Hague Convention for the United Kingdom<\/a>). A British reader seeking to enforce an English maintenance order or a family provision award in France therefore needs a different instrument, such as the Hague maintenance conventions or the specific family-law guide to enforcing an English divorce financial order in France (enforcing an English divorce financial order in France<\/a>). Second, where the 1934 Convention does not help, French courts fall back on their own common-law test, which is the subject of the next section, and the analysis concludes that for judgments given before the Hague 2019 Convention took effect, and for judgments given afterwards but in fields outside Hague 2019, the French courts should apply the 1934 Convention (Actu-juridique, entry into force of the 2019 Hague Convention for the United Kingdom<\/a>).<\/p>\n

The newest route is the Hague Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters. Its dates are now officially settled. The Hague Conference on Private International Law announces that the Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters entered into force for the United Kingdom on 1 July 2025, following deposit of its instrument of ratification on 27 June 2024 (HCCH, 2019 Judgments Convention enters into force for the United Kingdom<\/a>). On the French side, the Convention now operates between the United Kingdom and the European Union contracting parties, France included, as the British government describes common rules applying between the United Kingdom and the other contracting parties including the European Union (GOV.UK, government response on joining Hague 2019<\/a>). The British government, for its part, explained that the United Kingdom joining Hague 2019 would supply a set of common rules for the recognition and enforcement of civil and commercial judgments between the United Kingdom and the other contracting parties including the European Union, giving assurance that qualifying British judgments would be recognised and enforced across the Convention area and vice versa (GOV.UK, government response on joining Hague 2019<\/a>). In scope, however, is doing real work in that sentence.<\/p>\n

Hague 2019 does not cover everything. It applies to civil and commercial judgments but with significant exclusions: significant exclusions covering tax, customs and administrative matters, personal status and family-law matters, arbitration and insolvency, plus further notable exclusions such as the carriage of passengers and goods, defamation and privacy, and intellectual property and competition (Actu-juridique, entry into force of the 2019 Hague Convention for the United Kingdom<\/a>). The same commentary adds that Article 5 of the Convention lays down an indirect-jurisdiction condition for the court that gave the judgment, providing thirteen alternative criteria, with an exclusive test for immovable property. Even inside its scope, enforcement depends on at least one of the Convention’s indirect-jurisdiction filters being met: the British government response describes the Article 5 indirect-jurisdiction grounds as offering wider possibilities for recognition and enforcement in some circumstances while setting clear thresholds that parties must meet (GOV.UK, government response on joining Hague 2019<\/a>). A British consumer with a straightforward English money judgment against a defendant domiciled in England, for example, will normally pass those filters; a British claimant who sued in England on an exotic jurisdictional basis may not. As for procedure, the Convention sends you back to French procedural law, with French law itself remaining unchanged on the French side (Actu-juridique, entry into force of the 2019 Hague Convention for the United Kingdom<\/a>). In practice that means an assignation<\/em> (a writ served by an enforcement officer summoning the opponent before the court) before the tribunal judiciaire<\/em>, exactly as under the older routes, with the Convention supplying the legal basis instead of the 1934 text or the common-law test. Ask your solicitor and your French avocat<\/em> (the regulated legal representative who alone can plead before the French court) to check three points before choosing Hague 2019: the date of the English judgment, because transitional provisions protect pending situations; the subject matter, against the exclusions above; and at least one Article 5 filter, evidenced in the papers.<\/p>\n

B. When No Treaty Helps: the French Common-Law Test Since Cornelissen<\/h3>\n

Where neither the 1934 Convention nor Hague 2019 supplies a basis, English judgments are examined under French judge-made law, and the starting point is a single sentence of the Code of Civil Procedure (Code de proc\u00e9dure civile<\/em>, the rulebook for French civil courts). Article 509 of the Code of Civil Procedure<\/a> provides that “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.” In plain English, judgments given by foreign courts and instruments drawn up by foreign officers are enforceable on French territory in the manner and in the cases provided for by law. That one sentence does two jobs: it states the principle that foreign judgments can be enforced, and it sends the judge to the applicable instrument, treaty or common-law test, to decide how. Contrast this with the European fast track, under which applications for the recording of enforceability are simply lodged with the head registrar of the tribunal judiciaire<\/em> (Article 509-2 of the Code of Civil Procedure, L\u00e9gifrance<\/a>). That registry procedure is reserved for decisions covered by European instruments. An English judgment must go before a judge, in open court, with the other side summoned.<\/p>\n

The modern common-law test was fixed by the Court of Cassation (Cour de cassation<\/em>, France’s supreme court for civil matters) in the leading Cornelissen ruling of 20 February 2007. The court held, in the leading Cornelissen ruling, that outside any international convention the French judge must verify three conditions: the indirect jurisdiction of the foreign court based on the connection between the dispute and the court seized, compliance with substantive and procedural international public policy, and the absence of evasion of the law, adding that the exequatur judge does not check whether the foreign court applied the law designated by the French choice-of-law rule (Cass. 1re civ., 20 f\u00e9vrier 2007, n\u00b0 05-14.082 (Cornelissen), published in the Bulletin civil and available on L\u00e9gifrance). Each word counts. Indirect jurisdiction (comp\u00e9tence indirecte<\/em>, the question whether the foreign court was entitled to hear the case as French conflicts rules see it) turns on a genuine link between the dispute and England, not on whether a French court could also have heard it. International public policy covers both the substance, such as damages that would shock French conceptions of compensation, and the procedure, above all the rights of the defence. Evasion of the law (fraude \u00e0 la loi<\/em>, the artificial manipulation of connecting factors to obtain a favourable forum) is rare in British-French cases but must still be addressed in the papers. And the final clause is a gift to British claimants: the French judge does not re-examine which substantive law the English court applied, so an English judgment applying English law to a French accident is not refused on that ground alone.<\/p>\n

A second old pillar completes the picture: the French judge examines but does not re-try. In the foundational Munzer ruling of 7 January 1964, the Court of Cassation defined the exequatur judge’s review as at once the expression and the limit of his power, with no review of the substance of the foreign decision (Cass. 1re civ., 7 janvier 1964 (Munzer), published in the Bulletin civil and available on L\u00e9gifrance). The defendant cannot therefore invite the Paris court to rehear witnesses, re-weigh expert evidence or substitute French damages for English ones. What the defendant can do is attack the three Cornelissen conditions and the regularity of the papers, which is why the practical section below insists so heavily on proof of service, translation and finality. A Paris judgment of 13 March 2024 shows the test working exactly as written for an English decision. Applying Article 509, the court recalled that to grant exequatur absent an international convention, the French judge verifies the international regularity of the foreign decision against the three conditions of indirect jurisdiction of the foreign court, compliance with substantive and procedural international public policy, and absence of fraud. It then held that the decision before it had been given by a court with jurisdiction, complied with French procedural and substantive international public policy, and was free of fraud, and that it should therefore be declared enforceable on French territory (Paris tribunal judiciaire<\/em>, Exequatur formation, 13 March 2024, RG 23\/05699, full text verified from the Judilibre open-data record during the preparation of this article). The decision concerned an English insolvency measure, an administrator appointment made on 21 September 2021 by the High Court of Justice, Business and Property Courts of England and Wales, and its operative part reads: the court declares enforceable on French territory the appointment of the administrators of the English company. A Montpellier judgment of 18 December 2025 makes the same point for a 1989 decision of the Court of Appeal of England and Wales, holding that the decision complied with French international public policy and was final, with no appeal open or pending, so that the conditions for enforcement on national territory were met under Article 509 of the Code of Civil Procedure, before ordering exequatur of the 27 July 1989 decision of Her Majesty’s Court of Appeal in England and Wales on the corporate-veil and alter-ego point (Montpellier tribunal judiciaire<\/em>, 18 December 2025, RG 25\/02610, full text verified from the Judilibre open-data record during the preparation of this article). Three different English decisions, three grants: the route works when the evidence is there.<\/p>\n

II. How Do You Get an English Judgment Enforced by a French Court?<\/h2>\n

A. Seizing the Tribunal Judiciaire: the Court, the Papers and the Proof Paris Judges Require<\/h3>\n

Start with the right court. The general French rule is stated in Article 42 of the Code of Civil Procedure<\/a>: “La juridiction territorialement comp\u00e9tente est, sauf disposition contraire, celle du lieu o\u00f9 demeure le d\u00e9fendeur.” In plain English, the court with territorial jurisdiction is, unless otherwise provided, the court of the place where the defendant lives. The administration’s guidance confirms that the competent tribunal judiciaire<\/em> is the court of the domicile of the party against whom enforcement is sought (Service-public.fr, execution of a foreign civil judgment in France<\/a>). If the debtor lives in Paris, or the French insurer or company is headquartered there, you sue in Paris, where the tribunal judiciaire<\/em> operates a dedicated exequatur formation with a single judge sitting under the procedure for oral proceedings. That specialisation matters: the two Paris judgments studied here were both handled by that formation, and both show what its judges look for. If the debtor lives elsewhere in France, seize the tribunal judiciaire<\/em> of that place; if only an asset is in France, such as a holiday home owned by a person still domiciled in England, jurisdiction follows the asset and the enforcement measures available against it, a point to have your avocat<\/em> confirm before issuing the writ, because seizing the wrong court costs months.<\/p>\n

In road-traffic and other non-contractual cases, an additional French jurisdictional option helps British claimants establish the English court’s indirect jurisdiction. Article 46 of the Code of Civil Procedure<\/a> allows a claimant to seize, at his choice and in addition to the defendant’s home court, “en mati\u00e8re d\u00e9lictuelle, la juridiction du lieu du fait dommageable ou celle dans le ressort de laquelle le dommage a \u00e9t\u00e9 subi” (in non-contractual matters, the court of the place of the harmful event or the court within whose district the damage was suffered). The Paris court used exactly that reasoning to uphold the jurisdiction of the English County Court of South Shields over a French road accident, finding that part of the damage had materialised in the United Kingdom so that the British courts had a basis of jurisdiction under French domestic rules (Paris tribunal judiciaire<\/em>, 23 October 2024, RG 23\/05167). The facts were those of many British holidaymakers: a British resident injured in the Dordogne on 24 July 2019, repatriated immediately afterwards, treated in England, suffering acute symptoms there for weeks, with most of the loss sustained in England. The English judge had even been invited to apply French law, which the Paris court noted as excluding any evasion. If your case has an English anchor of that kind, plead it explicitly under Article 46: it turns a plausible objection to jurisdiction into your strongest paragraph.<\/p>\n

The papers decide the case. An exequatur application outside the European instruments is brought by assignation<\/em>, served by a commissaire de justice<\/em>, not by a simple registry request, and the file must prove four things at once: that the English decision exists and says what you claim, that it is enforceable in England, that the defendant knew about the English proceedings in good time, and that French public policy was respected. On existence and content, produce the exp\u00e9dition<\/em> (the certified official copy) of the English judgment with a translation by a sworn translator (traducteur asserment\u00e9<\/em>, the court-approved translator whose stamp French judges trust). Translation is not decoration: in the South Shields case the court ordered that costs would include the translation expenses under Article 695, paragraph 2, of the Code of Civil Procedure (Paris tribunal judiciaire<\/em>, 23 October 2024, RG 23\/05167). The underlying rule is that court costs, known as d\u00e9pens<\/em> (the recoverable litigation expenses fixed by law), include “Les frais de traduction des actes lorsque celle-ci est rendue n\u00e9cessaire par la loi ou par un engagement international” (the translation costs for documents where translation is made necessary by statute or by an international undertaking) (Article 695 of the Code of Civil Procedure, L\u00e9gifrance<\/a>). Commission the sworn translation early, keep the invoice, and claim it in your costs schedule: the winning party recovers it.<\/p>\n

On knowledge of the proceedings, the South Shields file is a model of what Paris judges want to see. The claimant produced the document served on the French insurer on 10 June 2021, the English claim form with a detailed schedule of the claim, a blank response form for the defendant, the exhibits, and professional translations of the whole bundle, followed by notice of an adjourned hearing and the hearing bundle. The court concluded that the papers proved the insurer had learned of the proceedings in good time as the Convention requires, and that defence rights, and therefore French international public policy, had been respected (Paris tribunal judiciaire<\/em>, 23 October 2024, RG 23\/05167). Note the double dividend: the same evidence defeats both the default-judgment defence under Article 3(b) of the 1934 Convention and the public-policy defence under Article 3(c). The court added that the English Civil Procedure Rules, Part 52, opened an appeal route, which answered the argument that a default defendant lacks an effective remedy. If your English judgment was given in the defendant’s absence, reconstruct this paper trail before issuing the French writ: every proof of service, every letter before claim, every notice of hearing, each translated.<\/p>\n

On enforceability in England, French judges apply English law as best they can with the help of a certificate of custom (certificat de coutume<\/em>, the opinion of an English-law specialist explaining the foreign procedure to the French court). Two practical points emerge from the cases. First, the English appeal clock matters: the Paris court verified that Article 52.12 of the English Civil Procedure Rules allows 21 days to appeal from the decision, that the period had expired with no appeal claimed, and that the judgment was therefore sufficiently shown to be enforceable (Paris tribunal judiciaire<\/em>, 23 October 2024, RG 23\/05167). Do not file in Paris while the 21-day English appeal window is still open unless limitation pressure forces your hand; file with a sworn statement or counsel’s confirmation that no appeal was lodged. Second, some English procedural objects have no French equivalent, and the court accepts that: in the administration case the Paris judges accepted that Anglo-Saxon law has no equivalent of the French certificate of non-appeal, and granted exequatur on the strength of the High Court order, the custom certificate of 9 February 2023 and the extension notice instead (Paris tribunal judiciaire<\/em>, 13 March 2024, RG 23\/05699). Where the English paper you wish you had does not exist, say so frankly and substitute the closest English evidence with an explanation.<\/p>\n

Two drafting disciplines from the South Shields judgment will protect your claim for costs and keep your file clean. First, the French court only rules on what appears in the operative part of your submissions, known as the dispositif<\/em> (the final section of written pleadings listing the orders sought). A request buried in the reasoning goes nowhere, since the court is seized only of claims stated in the operative part of the pleadings, under Article 768 of the Code of Civil Procedure (Paris tribunal judiciaire<\/em>, 23 October 2024, RG 23\/05167). The underlying rule requires pleadings to set out the claims expressly with the evidence relied on for each, indexed in a schedule (Article 768 of the Code of Civil Procedure, L\u00e9gifrance<\/a>). Put every order you want, translation costs, Article 700 indemnity, enforcement costs, into the dispositif<\/em>, each with its exhibit numbers. Second, claim your irrecoverable costs under Article 700: Article 700 of the Code of Civil Procedure<\/a> provides that “Le juge condamne la partie tenue aux d\u00e9pens ou qui perd son proc\u00e8s \u00e0 payer : 1\u00b0 A l’autre partie la somme qu’il d\u00e9termine, au titre des frais expos\u00e9s et non compris dans les d\u00e9pens” (the judge orders the party liable for costs or who loses the case to pay the other party the sum he determines, in respect of expenses incurred and not included in the costs). In the South Shields case the losing insurer was ordered to pay 2,500 euros on that basis on top of the costs including translation. A judgment must also summarise the parties’ claims and be reasoned, since “Le jugement doit \u00eatre motiv\u00e9.” (the judgment must give reasons) and “Il \u00e9nonce la d\u00e9cision sous forme de dispositif.” (it states the decision in the form of an operative part) (Article 455 of the Code of Civil Procedure, L\u00e9gifrance<\/a>), which is why French exequatur judgments walk through each condition in turn and give you a reasoned precedent to cite next time.<\/p>\n

B. Resisting Enforcement, Appealing, and the Reverse Journey From France to England<\/h3>\n

If you are on the receiving end of an exequatur application, your defences are the mirror image of the claimant’s burden, and the South Shields case shows which objections fail and why. Jurisdiction first: the insurer argued that under Article 46 only Paris, as the defendant’s home, or the place of the accident could hear the case, and never an English court. The Paris judges answered with the damage-suffered-in-England analysis quoted above and held the English court competent. A bare assertion that the English court lacked jurisdiction, without engaging with the French conflicts analysis, will not succeed. Service and fairness second: the insurer complained of late and insufficient service, an unsigned copy differing from the minute of the judgment, counsel’s email exchanges with the English judge, and the absence of a sworn translation. The court examined each point, found service in good time with translations, observed that the content of the two versions of the judgment remained otherwise similar, drew no consequence from counsel’s correspondence with the judge, and held the rights of the defence respected. The message for defendants is strict: raise only objections you can evidence, with your own translations and your own certificate of English procedure, because unproved allegations are swept aside in a paragraph.<\/p>\n

Two further defences deserve attention because defendants instinctively reach for them. The first is loyalty: the claimant argued that the insurer, having stayed silent in England, could not oppose exequatur in Paris without contradicting itself to another’s detriment, a procedural bar known as fin de non-recevoir<\/em> (a plea that the opponent’s claim is inadmissible without examining its merits). The court rejected that plea, holding that opposing exequatur after taking no part in the English proceedings does not show procedural disloyalty, and dismissed the inadmissibility plea accordingly (Paris tribunal judiciaire<\/em>, 23 October 2024, RG 23\/05167). A defendant who ignored English proceedings keeps the full right to contest exequatur in France. The second is the pending-appeal argument under Article 3(d) of the 1934 Convention: it works only if you prove that an appeal, opposition or other challenge was actually brought in England. Asserting that you might have appealed, after letting the 21-day Civil Procedure Rules clock expire without acting, proves nothing, as the South Shields court held. If you intend to appeal in England, lodge the appeal first and prove it in Paris; if the appeal is lodged after exequatur is granted, raise it on appeal in France.<\/p>\n

Losing at first instance is not the end. An exequatur judgment of the tribunal judiciaire<\/em> is given in adversarial proceedings and can be appealed. The general French time limit is short: Article 538 of the Code of Civil Procedure<\/a> provides that “Le d\u00e9lai de recours par une voie ordinaire est d’un mois en mati\u00e8re contentieuse” (the time limit for an ordinary remedy is one month in contentious matters). The administration’s guidance gives the same warning for enforcement decisions, noting that the decision may be challenged by appeal within one month of formal service (Service-public.fr, execution of a foreign civil judgment in France<\/a>), and it confirms that either side may apply to have the foreign decision declared enforceable in France, or to oppose such enforcement (Service-public.fr, execution of a foreign civil judgment in France<\/a>). Diarise the month from signification<\/em> (formal service by an enforcement officer, which starts time running, unlike a simple letter), instruct your avocat<\/em> before the writ arrives if possible, and remember that execution measures taken meanwhile may have to be unwound if the appeal succeeds, which is a further reason to act within days, not weeks.<\/p>\n

The journey also runs in the opposite direction, and British readers with French judgments to enforce in England should understand the symmetry. For money judgments predating Hague 2019, or outside its scope, English courts work with their own statute: commentary records that an Order in Council of 1936 extended the British Foreign Judgments Act 1933 to French judgments following French ratification of the 1934 enforcement convention, with enforcement proceeding through a registration system where the statute applies (Actu-juridique, entry into force of the 2019 Hague Convention for the United Kingdom<\/a>). Since 1 July 2025, Hague 2019 offers a modern channel both ways for judgments within its filters, with the British government expecting it to benefit businesses and consumers living across borders. Whichever direction you travel, the practical core is identical: a court order from home is only paper abroad until a local judge declares it enforceable, and that declaration turns on jurisdiction, knowledge, fairness and proof, never on re-trying who was right.<\/p>\n

Once exequatur is granted, the English decision becomes a French enforcement title. No judgment or instrument may then be enforced without presentation of the certified copy bearing the enforcement formula, since “Nul jugement, nul acte ne peut \u00eatre mis \u00e0 ex\u00e9cution que sur pr\u00e9sentation d’une exp\u00e9dition rev\u00eatue de la formule ex\u00e9cutoire, \u00e0 moins que la loi n’en dispose autrement” (no judgment or instrument may be enforced without presentation of a certified copy bearing the enforcement formula, unless the statute provides otherwise) (Article 502 of the Code of Civil Procedure, L\u00e9gifrance<\/a>). Your commissaire de justice<\/em> serves the exequatur judgment with that formula and may then attach bank accounts, register a judicial mortgage on the French house, or seize and sell assets, with the debtor’s challenges going to the enforcement judge (juge de l’ex\u00e9cution<\/em>, the specialist judge for disputes about forced execution). Keep the English original, the sworn translation, the service trail and the French judgment together as one bundle: the same file that won exequatur will carry the seizure through.<\/p>\n

Conclusion<\/h2>\n

An English judgment does not cross the Channel by itself, but it can cross with preparation. Identify your route first: the 1934 Convention for money judgments where both sides accept it, Hague 2019 for civil and commercial judgments inside its filters since 1 July 2025, and otherwise the three Cornelissen conditions with no re-trial of the merits. Then build the file Paris judges reward: the certified English decision with a sworn translation, complete proof that the defendant knew of the English case in good time, evidence that the 21-day English appeal clock expired without challenge or that any appeal is disclosed, and a certificate explaining the English procedure where it has no French equivalent. Put every order sought, including translation costs and the Article 700 indemnity, in the operative part of your submissions, seize the court of the debtor’s domicile, and move within the one-month appeal discipline on either side. The Paris exequatur formation has shown, twice in these pages, and Montpellier once, that English decisions meeting those standards are declared enforceable on French territory. Meet them, and the County Court order in your drawer becomes the seizure on the French account, the charge on the French house, or the payment from the French insurer that it was always meant to be.<\/p>\n","protected":false},"excerpt":{"rendered":"

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