Recognition and Enforcement of Foreign Judgments: Russia, the European Union and the United Kingdom
Report D-19 examines the changing framework for the cross-border recognition and enforcement of judgments in Russia, the European Union and the United Kingdom in 2026. It identifies two developments occurring simultaneously: broader treaty-based mechanisms for the circulation of ordinary civil and commercial judgments, and additional barriers affecting certain sanctions-related disputes and competing claims to jurisdiction. ARGA_D-19_Foreign_Judgments_EN_…
A central distinction is made between recognition, access to compulsory enforcement and actual recovery. Recognition allows a foreign judgment to produce legal effects, while enforcement provides access to state coercive mechanisms. Neither necessarily results in recovery: the availability and ownership of assets, third-party rights, immunity and sanctions restrictions may still prevent a creditor from obtaining payment. ARGA_D-19_Foreign_Judgments_EN_…
The report gives particular attention to the 2019 Hague Judgments Convention. The Convention entered into force for the United Kingdom on 1 July 2025, providing an additional treaty route for qualifying new proceedings. Russia signed the Convention in November 2021, but the materials reviewed do not record ratification or entry into force for Russia. Hague Conference
For Russia, the analysis considers Articles 248.1 and 248.2 of the Arbitrazh Procedure Code, including sanctions-related jurisdiction and measures restricting foreign proceedings. Importantly, the statutory framework does not amount to a blanket prohibition on the recognition of every foreign judgment. ARGA_D-19_Foreign_Judgments_EN_…
The EU dimension changed further in July 2026. New amendments broadened specific prohibitions on recognising, giving effect to or enforcing certain Russian judicial and administrative decisions connected with sanctions-affected relationships. These rules nevertheless retain defined personal and substantive conditions; they do not establish that every Russian judgment is automatically unenforceable throughout the EU. ARGA_D-19_Foreign_Judgments_EN_… Eur-Lex
The report concludes that enforceability cannot be determined simply by identifying the country in which a judgment originated. The applicable regime, commencement date, jurisdictional basis, procedural fairness, specific statutory prohibitions and the legal status and location of assets must all be analysed separately.
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