Two directions, three different rulebooks
Once a judgment exists somewhere, taking it across a border to reach a debtor's assets is a separate legal exercise from winning it in the first place — and creditors are often surprised how much it varies depending on where the judgment came from. It can run either way relative to France:
- Inbound. You already sued at home (or elsewhere) and won, but your French debtor's assets — a bank account, a factory, a debtor's own customers — are in France. You need to bring the judgment in.
- Outbound. You obtained a French judgment through this firm, but the debtor has since moved assets, or trades, outside France. You need to take the judgment out.
Which rulebook applies does not depend on the direction. It depends on where the judgment was given: another EU member state, the United Kingdom, or most other countries. Those three categories currently sit under three genuinely different regimes, subject to a few specific treaties (for example the Lugano Convention for Switzerland, Norway and Iceland).
If your debtor is established in France, French courts almost certainly have jurisdiction to hear the claim directly — see jurisdiction and applicable law. Suing directly in France is often faster and simpler than winning a judgment elsewhere and then importing it, precisely because the import step described on this page adds a procedure of its own. Cross-border recognition matters most when a judgment already exists, or when the claim itself has stronger ties to another country.
Judgments from an EU member state: no import procedure at all
Within the EU, the exercise barely exists. Under the Brussels I bis Regulation (EU No 1215/2012), a judgment given in one member state in proceedings instituted on or after 10 January 2015 is recognised and enforceable in every other member state without any special procedure — the exequatur step that used to exist between EU states has been abolished. For a creditor, that means no separate court case in France: no application, no hearing, no months of waiting.
In practice this reduces to a paperwork step, not a court application:
- The court that gave the judgment issues a standard certificate on request — a form, not a new proceeding.
- That certificate has to be served on the debtor before the first enforcement measure — though protective measures are carved out, so an account can still be frozen without tipping the debtor off first.
- The judgment and certificate then go straight to the local enforcement officer — a commissaire de justice, if the assets are in France — who proceeds exactly as if the judgment were domestic.
The debtor can still resist, but only on a narrow, closed list of grounds — manifest breach of public policy, a default judgment where the defendant was not properly served, a clash with another judgment or, in limited cases, a breach of the Regulation's exclusive or protective jurisdiction rules — and never automatically: the debtor has to apply for refusal, and applying does not by itself halt enforcement. French courts interpret those grounds restrictively. The practical upshot: a German, Belgian, Spanish or Italian judgment against a company with a French bank account reaches that account on essentially the same footing as a judgment from a French court.
Judgments from the United Kingdom: no longer automatic, but no longer full exequatur either
Brexit removed UK judgments from the Brussels I bis regime, and the UK has not been able to rejoin the Lugano Convention that might otherwise have filled the gap. For several years the main route was the general non-EU procedure described below (judgments in proceedings instituted before the end of the Brexit transition period on 31 December 2020 remained under Brussels I bis, and judgments given under an exclusive choice-of-court agreement could, in some cases, rely instead on the Hague Choice of Court Convention of 30 June 2005).
That changed on 1 July 2025, when the Hague 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. France has been bound by it since 1 September 2023, through the EU's accession — but a convention only operates between two countries once it is in force for both, which is why the UK–France route opened on the later date.
It is not the EU regime transplanted. The Convention creates no enforcement procedure of its own — in France, a UK judgment still goes before a French court. What changes is the depth of the review. The court cannot reopen the merits. The judgment must first fall within one of the jurisdictional links the Convention lists (for instance, the debtor was habitually resident in the UK, accepted the UK court's jurisdiction, or the contract was to be performed there); if it does, the court can refuse only on a limited list of grounds set by the Convention, chiefly: defective notice to the defendant, fraud, manifest incompatibility with French public policy, proceedings brought in breach of a jurisdiction agreement, or a clash with another judgment. Materially narrower than the full exequatur review described below — but still a court application, not a formality.
Hague 2019 only covers judgments in proceedings that were instituted at a time when the Convention had effect between the two states concerned. A UK judgment from proceedings issued before 1 July 2025 does not benefit from this route even if judgment was handed down later — it generally falls back to the general non-EU procedure below, unless another instrument applies (for example the Brussels I bis Regulation itself, for proceedings instituted before the end of the Brexit transition period on 31 December 2020, or, in some cases, the Hague Choice of Court Convention of 30 June 2005, where the parties had agreed an exclusive jurisdiction clause). Send us the date the claim was filed, not the date of judgment, so this can be checked properly.
Judgments from the US, Canada, and most other countries: exequatur
The US and Canada are not parties to Hague 2019 — the US has signed but not ratified it, and Canada has not signed it — so a US or Canadian judgment (like one from Australia, or most other non-EU, non-UK jurisdictions) reaches France through the general French procedure for foreign judgments: exequatur, a standalone application to a French court asking it to declare the foreign judgment enforceable in France.
This is not a re-trial of the merits. Since the French Cour de cassation's 2007 Cornelissen ruling, the French court's review is limited to three conditions:
Indirect jurisdiction
The foreign court that gave the judgment had a genuine connection to the dispute — the French judge does not re-run the foreign court's own jurisdiction test, only checks that the link was real.
International public policy
The judgment, and the procedure that produced it, do not offend French international public policy — substantively and procedurally (proper notice, a genuine opportunity to defend).
No fraud
The judgment was not obtained through fraud on the law (fraude à la loi) — for example by artificially steering the case to a particular court to escape the rules that would normally apply.
What is not re-examined
The French court does not check whether the foreign court applied the "correct" law, and does not reopen findings of fact. It is a gatekeeping review, not an appeal.
This is a genuine court proceeding, not a formality: it needs to be filed, the debtor can appear and contest it, and it takes materially longer than the certificate-based routes above — realistically several months. It is, however, a well-established and routinely used procedure, and a properly obtained US, Canadian, or Australian judgment against a company with no serious defence rarely fails it.
The other direction: taking a French judgment out
The same three regimes apply symmetrically. A French judgment obtained through this firm reaches a debtor's assets in Germany or the Netherlands the same way an EU judgment reaches France — via the Brussels I bis certificate, no exequatur. It can reach assets in England or Wales under the Hague 2019 Convention, provided the French proceedings were instituted on or after 1 July 2025. Elsewhere — including the US and Canada — it is generally enforced through that country's own procedure for recognising a foreign judgment, unless a treaty applies (for example the Lugano Convention for Switzerland, Norway and Iceland); that is a question of local law wherever the assets happen to be, not of French law.
Frequently asked questions
In most cases, sue directly in France. Your debtor's French domicile almost always gives French courts jurisdiction (see jurisdiction and applicable law), and doing so avoids the import step described on this page entirely — you go straight to enforcement once you have a French title.
Budget several months rather than weeks — it is a full application before a French court, and the debtor can contest it. It is still generally faster than starting fresh proceedings in France, provided the underlying US judgment is sound and was obtained on proper notice.
No — it is a real improvement over the pre-2025 position, but it still requires a procedure in France to have the judgment declared enforceable and allows a defined set of objections, unlike the near-automatic Brussels I bis regime for EU judgments. And it only covers cases filed on or after 1 July 2025.
No. Under every regime described here, the grounds for objection are specific and limited — a general complaint about the merits is not one of them. An objection can add delay, particularly under exequatur, but it needs a genuine basis to succeed.
The judgment itself, the court that issued it and the country, the date the underlying proceedings were filed (not just the judgment date), and where the debtor's assets are now. That is usually enough for an initial view on which of the three regimes applies and how long it will take.
Related guides
Tell us about your case
Outline your situation — Maître Bensimhon will reply personally within 1 business hour.
Reply within 1 business hour