Exequatur in France of
judgments rendered in the United Kingdom
Issues and definition
Since Brexit, British judgments no longer benefit from automatic recognition in France. Their enforcement now requires an exequatur procedure before French courts.
The objective is to transform a British decision into an enforceable title in order to allow the implementation of measures on assets located in France.
Conditions and procedures
Recognition is based on French private international law. The judgment must be rendered by a competent jurisdiction, respect the rights of the defense, be final, and comply with international public policy.
The exequatur procedure is initiated before the judicial court (tribunal judiciaire) and requires the production of the judgment, its certified translation, and a legal analysis of the case.
Areas of expertise
British decisions concern commercial, financial, contractual, or international disputes involving assets located in France, such as bank accounts, real estate, equity interests, or receivables.
These assets may be held directly or via complex structures requiring in-depth analysis.
Client support
The firm assists its clients from the recognition of the British judgment to its effective enforcement in France, by integrating necessary protective measures and seizures.
Each case is subject to a global strategy combining asset identification, anticipation of challenges, and effective implementation of enforcement measures.
Frequently Asked Questions
IS A BRITISH JUDGMENT AUTOMATICALLY ENFORCEABLE IN FRANCE?
No, since Brexit, an exequatur procedure is necessary.
HAS BREXIT CHANGED THE RULES?
Yes, British decisions are now subject to the general exequatur regime.
CAN ASSETS BE SEIZED IN FRANCE?
Yes, as a protective measure or once the judgment has been recognized.
IS THE PROCEDURE MORE COMPLEX THAN BEFORE?
It now requires an in-depth legal analysis.
IS A LAWYER REQUIRED?
In practice, these procedures involve the intervention of a lawyer before French courts, both for obtaining an exequatur and for enforcement litigation.
They also imply a strategic approach, beyond just the procedural dimension.
Do you wish to initiate an exequatur procedure in France or analyze the possibilities of asset seizure?
The firm assists you in defining and implementing an adapted strategy.