Cross-border debt recovery — recovering money from a French company

The reality of cross-border debt recovery in France

If you are not based in France and a French company owes you money, you face three specific obstacles:

• Distance and language. French court procedures are conducted in French, although a judge may accept exhibits written in English, and the international commercial chambers of the Paris courts allow more use of English under their own protocols. Court documents, formal pleadings, and judgments are produced in French.
• Unfamiliar procedures. French civil procedure has its own logic — different from common-law adversarial procedures. The role of the judge, the use of written submissions over oral argument, and the speed of "fast-track" procedures may surprise you.
• Coordination with judicial officers. Enforcement in France goes through commissaires de justice (formerly huissiers). They are not the equivalent of a US sheriff or marshal — they have a much broader monopoly on official document service and enforcement.

The good news: none of this has to be your problem. Our role is to absorb that complexity. You submit your case in English, in your timezone, and we run the French side of the procedure.

Which procedure for which case

Three categories of foreign creditors face very different path options.

You are an EU member-state creditor

You have access to the full European cross-border toolkit:

• European Account Preservation Order (Reg. 655/2014) — freeze French bank accounts before judgment
• European Payment Order (Reg. 1896/2006) — get an order enforceable throughout the EU except Denmark, no exequatur needed
• European Order for Small Claims (Reg. 861/2007) — for claims up to €5,000 (rarely used by us, given our minimum threshold)
• Standard French national procedures (often the most efficient when assets are clearly in France)

You are a UK creditor (post-Brexit)

You cannot use the EAPO, which the UK never joined, and you lost EPO access after Brexit. Your toolkit is now:

• French saisie conservatoire — the national equivalent of EAPO, slightly different formalities
• French injonction de payer (payment order) — same procedure as before
• French summary judgment / full proceedings — unchanged by Brexit
• Recognition of UK judgments in France: now via the 2019 Hague Judgments Convention (for proceedings started on or after 1 July 2025), or via the 2005 Hague Convention on Choice of Court Agreements where it applies, or via French common law on recognition of foreign judgments (exequatur). We assess case-by-case.

You are a US, Canadian, Australian or non-EU creditor

EU regulations do not apply, but the substantive French toolkit is still fully accessible:

• Formal notice by Paris Bar attorney (€189 ex VAT)
• Standard French saisie conservatoire for asset preservation
• Standard French payment order, summary judgment, full proceedings
• If you already have a US / Canadian / Australian judgment, recognition in France via French common law (more nuanced and case-specific than EU procedures)

The escalating playbook for B2B debt recovery in France

1. Formal notice by attorney — €189 ex VAT, 24-hour drafting and dispatch. ~30% settlement rate. Details →
2. Asset preservation if there is dissipation risk — EAPO for EU creditors, French saisie conservatoire for non-EU. Often around two weeks to an active freeze, depending on the court.
3. Payment order for undisputed claims — injonction de payer. Enforceable order in 3-4 months.
4. Summary judgment if the debtor's objections are not serious — référé provision. Hearing usually a few weeks after the summons, immediately enforceable order.
5. Full action on the merits if there is a serious dispute — assignation au fond. First-instance judgment after several months, sometimes more than a year (appeal possible).
6. Enforcement via French judicial officer — bank garnishment, asset seizure, mortgage on real estate.

What we need from you to start

The 5 documents that move every B2B recovery file forward:

• The signed contract or signed purchase order
• All unpaid invoices
• Proof of delivery or proof of completion (signed acceptance, deliverables, screenshots, emails confirming acceptance)
• Any email or written exchange showing the debtor's awareness of the debt (acknowledgements, partial payments, payment promises, pretexts for delay)
• The debtor's full corporate name (we'll pull the SIRET / RCS records ourselves)

If you have a jurisdiction clause pointing somewhere other than France, send it too — it changes the analysis but rarely closes the door entirely.