{"id":148652,"date":"2026-09-03T12:43:21","date_gmt":"2026-09-03T12:43:21","guid":{"rendered":"https:\/\/my.legal500.com\/guides\/?post_type=comparative_guide&#038;p=148652"},"modified":"2026-09-03T13:12:29","modified_gmt":"2026-09-03T13:12:29","slug":"cyprus-enforcement-of-judgments-in-civil-and-commercial-matters","status":"publish","type":"comparative_guide","link":"https:\/\/my.legal500.com\/guides\/chapter\/cyprus-enforcement-of-judgments-in-civil-and-commercial-matters\/","title":{"rendered":"Cyprus: Enforcement of Judgments in Civil and Commercial Matters"},"content":{"rendered":"","protected":false},"template":"","class_list":["post-148652","comparative_guide","type-comparative_guide","status-publish","hentry","guides-enforcement-of-judgments-in-civil-and-commercial-matters","jurisdictions-cyprus"],"acf":[],"appp":{"post_list":{"below_title":"<div class=\"guide-author-details\"><span class=\"guide-author\">Michael Kyprianou &amp; Co. LLC<\/span><span class=\"guide-author-logo\"><img src=\"https:\/\/my.legal500.com\/guides\/wp-content\/uploads\/sites\/1\/2020\/10\/Kyprianou_Logo-2023.jpg\"\/><\/span><\/div>"},"post_detail":{"above_title":"<div class=\"guide-author-details\"><span class=\"guide-author\">Michael Kyprianou &amp; Co. LLC<\/span><span class=\"guide-author-logo\"><img src=\"https:\/\/my.legal500.com\/guides\/wp-content\/uploads\/sites\/1\/2020\/10\/Kyprianou_Logo-2023.jpg\"\/><\/span><\/div>","below_title":"<span class=\"guide-intro\">This country specific Q&amp;A provides an overview of Enforcement of Judgments in Civil and Commercial Matters laws and regulations applicable in Cyprus<\/span><div class=\"guide-content\"><div class=\"filter\">\r\n\r\n\t\t\t\t<input type=\"text\" placeholder=\"Search questions and answers...\" class=\"filter-container__search-field\">\r\n\t\t\t<\/div>\r\n\r\n\t\t\t\r\n\r\n\r\n\t\t\t<ol class=\"custom-counter\">\r\n\r\n\t\t\t\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What international conventions, treaties or other arrangements apply to the enforcement of foreign judgments in your jurisdiction and in what circumstances do they apply?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Cyprus law does not provide a uniform framework for the recognition and enforcement of foreign judgments. Instead, several procedural routes are available, depending primarily on the country in which the judgment sought to be recognised and enforced was issued.<\/p>\n<p><strong><u>EU regulations <\/u><\/strong><\/p>\n<p>Regulation (EU) No. 1215\/2012 of the European Parliament and of the Council of 12\u00a0December 2012 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters (recast) (\u2018the Recast Regulation\u2019) applies in Cyprus. Judgments issued in EU member states after 10\/1\/2015 are now enforceable in all other EU member states.\u00a0 The Recast Regulation also applies to the recognition and enforcement of judgments issued by UK courts if proceedings commenced before 31\/12\/2020. It is noted that Council Regulation (EC) No. 44\/2001 of 22 December 2000 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters still applies to judgments issued prior to 10\/1\/2015.<\/p>\n<p>The Lugano Convention 2007 applies when final judgments issued by the courts of Iceland, Norway or Switzerland are to be recognised and enforced in Cyprus.<\/p>\n<p>In addition, the following EU regulations bind Cyprus in relation to the recognition and enforcement of judgments issued by courts of other EU member states:<\/p>\n<ul>\n<li>Council Regulation (EC) No 1346\/2000 of 29 May 2000 on insolvency proceedings.<\/li>\n<li>Regulation (EC) No 805\/2004 of the European Parliament and of the Council of 21 April 2004 creating a European Enforcement Order for uncontested claims.<\/li>\n<li>Regulation (EC) No 1896\/2006 of the European Parliament and of the Council of 12 December 2006 creating a European order for payment procedure.<\/li>\n<li>Regulation (EC) No 861\/2007 of the European Parliament and of the Council of 11\u00a0July 2007 establishing a European Small Claims Procedure.<\/li>\n<li><strong><u>Bilateral treaties <\/u><\/strong>With regard to non-EU member states, Cyprus has entered into several bilateral agreements concerning legal and judicial cooperation, including, but not limited to agreements with the Russian Federation, Syria, Egypt and Ukraine.In cases concerning judgments issued by countries with which Cyprus has concluded bilateral agreements providing for their recognition and enforcement, the Law on Decisions of Foreign Courts (Recognition, Registration and Enforcement) (\u2018Law 121(I)\/2000\u2019) applies. Pursuant to article 5 of Law 121(I)\/2000, the process is initiated by filing an application by summons before the Cyprus courts, supported by an affidavit, seeking the recognition and enforcement of the judgment issued by the foreign court.\n<p><strong><u>Multilateral conventions <\/u><\/strong><\/p>\n<p>In addition, Cyprus is a party to several multilateral conventions concerning the recognition and enforcement of foreign judgments. Accordingly, judgments falling within the scope of such conventions may be recognised and enforced in Cyprus in accordance with the procedures and requirements set out therein. These include:<\/p>\n<ul>\n<li>Foreign Judgments (Reciprocal Enforcement) Procedural Regulation (1062\/1925);<\/li>\n<li>Convention of 1 June 1970 on the Recognition of Divorces and Legal Separations;<\/li>\n<li>The Hague Convention of 1 February 1971 on the Recognition and Enforcement of Foreign Judgments in Civil and Commercial Matters and supplementary protocol thereto;<\/li>\n<li>The European Convention on Certain International Aspects of Bankruptcy;<\/li>\n<li>Convention of 19 October 1996 on Jurisdiction, Applicable Law, Recognition, Enforcement and Co-operation in Respect of Parental Responsibility and Measures for the Protection of Children;<\/li>\n<li>Convention of 30 June 2005 on Choice of Court Agreements (\u2018the HCCH\u2019)<\/li>\n<\/ul>\n<p>The Hague Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters entered into force on 1 September 2023 and establishes a framework for the recognition and enforcement of foreign civil and commercial judgments among its Contracting Parties. The Convention applies between the European Union, which is bound on behalf of all EU Member States except Denmark, and Ukraine, thereby facilitating the cross-border recognition and enforcement of judgments falling within its scope between the EU Member States and Ukraine.<\/p>\n<p><strong><u>Statutory framework<\/u><\/strong><\/p>\n<p>The Foreign Judgments (Reciprocal Enforcement) Law (Cap. 10) is of particular significance following Brexit as it provides a statutory mechanism for the recognition and enforcement of certain judgments issued by the courts of the United Kingdom after 31 December 2020 in Cyprus.<\/p>\n<p><strong><u>Common law <\/u><\/strong><\/p>\n<p>Where recognition and enforcement in Cyprus is sought in respect of a judgment issued by a country which is neither an EU Member State nor covered by an applicable bilateral or multilateral treaty or statutory regime, the judgment may be recognised and enforced pursuant to common law principles.<\/p>\n<p>In order for a foreign judgment to be recognised and enforced in Cyprus under common law, the following requirements must be satisfied:<\/p>\n<ul>\n<li>the foreign judgment must be final and conclusive;<\/li>\n<li>the judgment must be for a definite sum of money or a debt; and<\/li>\n<li>the foreign court must have had jurisdiction under Cyprus conflict-of-laws rules to issue the judgment.<\/li>\n<\/ul>\n<p>Where these requirements are satisfied, an action before the Cyprus courts based on the foreign judgment may be filed. The Cyprus courts will then determine, in accordance with the applicable common law principles, whether the foreign judgment should be recognised and enforced in Cyprus.<\/p>\n<p><strong><u>Recognition and enforcement of foreign arbitral awards<\/u><\/strong><\/p>\n<p>Furthermore, Cyprus has acceded to the Convention on the Recognition and Enforcement of Foreign Arbitral Awards, concluded in New York on 10 June 1958, which provides the principal international framework governing the recognition and enforcement of foreign arbitral awards in Cyprus.<\/p>\n<p>Accordingly, the applicable procedure for the recognition and enforcement of a foreign judgment in Cyprus will depend primarily on the jurisdiction in which the judgment was issued and whether the judgment falls within the scope of an applicable EU regulation, bilateral or multilateral convention, statutory regime or, in the absence of such instruments, the common law.<\/li>\n<\/ul>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What, if any, reservations has your jurisdiction made to such treaties?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The HCCH forms part of EU law and is therefore directly applicable to Cyprus. As a general rule, insurance contracts are excluded from the HCCH. However, section 2 of the EU Declaration of 11 June 2015 explicitly states the distinct cases of insurance contracts whereby the HCCH is applicable.<\/p>\n<p>Further, pursuant to article 19(1) of the Hague Convention on the Recognition of Divorces and Legal Separations, Cyprus has reserved the right to refuse recognition of a divorce or legal separation between two spouses who, at the time of the divorce or legal separation, were both citizens of the Republic of Cyprus and of no other State, where a law other than that indicated by the rules of private international law applicable in Cyprus was applied, unless the result reached is the same as that which would have been reached by applying the law indicated by those rules.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Can foreign judgments be enforced in your jurisdiction where there is not a convention or treaty or other arrangement, e.g. under the general law?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Common law principles apply in Cyprus in the absence of a bilateral or multilateral treaty in relation to the recognition and enforcement of a foreign judgment subject to the satisfaction of the following requirements:<\/p>\n<ul>\n<li>the foreign judgment must be final and conclusive;<\/li>\n<li>the judgment must be for a definite sum of money or a debt; and<\/li>\n<li>the foreign court must have had jurisdiction under Cyprus conflict-of-laws rules to issue the judgment.<\/li>\n<\/ul>\n<p>If the above requirements are met, an action may be filed before the courts of Cyprus, where the foreign judgment for which recognition and enforcement is sought will form the basis of the claim. The above procedure for the recognition and enforcement of a foreign judgment is subject to the Cypriot courts having jurisdiction to issue judgment.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What basic criteria does a foreign judgment have to satisfy before it can be enforced in your jurisdiction? Is it limited to money judgments or does it extend to other forms of relief?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The criteria that must be satisfied for a foreign judgment to be recognised and enforced in Cyprus depend on the country of origin of the judgment and, consequently, on the applicable treaty, convention or Regulation.<\/p>\n<p>If the foreign judgment is to be recognised and enforced under the Recast Regulation, article 2 of the Recast Regulation defines a judgment as \u2018any judgment given by a court or tribunal of a Member State, whatever the judgment may be called, including a decree, order, decision or writ of execution as well as a decision on the determination of costs or expenses by an officer of the Court. Judgment also includes provisional, including protective measures ordered by a court or tribunal which by virtue of this Regulation has jurisdiction as to the substance of the matter. It does not include a provisional, including protective, measure which is ordered by such a court or tribunal without the defendant being summoned to appear unless the judgment containing the measure is served on the defendant prior to enforcement.\u2019 Any judgment falling within this definition will be recognised in Cyprus without the need for any special procedure.<\/p>\n<p>Further, recognition and enforcement of a foreign judgment via bilateral treaties or international conventions usually require that foreign judgments should be final and conclusive, ordering the payment of a specified amount. In certain bilateral treaties, foreign judgments of a declaratory nature may also be eligible for recognition in Cyprus.<\/p>\n<p>Under Cap. 10, a foreign judgment can be recognised and enforced if the judgment is final and conclusive and regards a sum of money, other than a sum payable in respect of taxes or other charges of similar nature or in respect of a fine or other penalty.<\/p>\n<p>In the event that common law principles apply, the requirements set out in question 3 need to be satisfied for such foreign judgments to be recognised and enforced in Cyprus.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What is the procedure for enforcement of foreign judgments pursuant to such conventions, treaties or arrangements in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p><strong><u>Regulation (EU) no. 1215\/2012 (Brussels I (Recast) Regulation)<\/u><\/strong><\/p>\n<p>Judgments issued by the courts of an EU member state are generally directly enforceable in Cyprus according to the provisions of Brussels I (Recast) Regulation and no declaration of enforceability is required. In practice, the applicant must present to the District Court in which enforcement is sought the documents provided for in Article 42 of the Regulation, that is a copy of the judgment which satisfies the conditions necessary to establish its authenticity and the certificate of enforceability pursuant to Article 53 of the Regulation. The District Court will then provide the applicant with a Cypriot case number, in the context of which the applicant may take enforcement measures.<\/p>\n<p><strong><u>Bilateral or multilateral treaties<\/u><\/strong><\/p>\n<p>Relevant to the procedure of enforcement of judgments issued by the courts of a country with which Cyprus is connected by a bilateral or multilateral treaty is the Foreign Courts (Recognition, Registration and Enforcement pursuant to a Treaty) Law no. 121(I)\/2000. Article 5 of Law 121(I)\/2000 provides that an application must be filed by the person who seeks enforcement of the foreign judgment together with an affidavit in which the relevant facts and the grounds for recognition and enforcement must be described. Additional requirements may apply according to the specific provisions of the relevant bilateral or multilateral treaty, for example documents which must be presented before the Cypriot Court and which, in that case, are attached to the affidavit. The application is served on the judgment debtor who may object to the recognition and enforcement. In that case, the Court issues its judgment pursuant to a hearing on whether recognition and enforcement should be allowed under the circumstances. If the Court approves the application for recognition and enforcement, the judgment creditor is free to take all available enforcement measures.<\/p>\n<p><strong><u>Cap. 10<\/u><\/strong><\/p>\n<p>In cases where the Mutual Recognition of Certain Judgments of the Courts of Commonwealth Countries Law, Cap. 10, applies, the person who seeks enforcement must file an application with the Cypriot Court together with an affidavit setting out all relevant facts and the grounds for recognition and enforcement. The judgment debtor has the right to file a set aside application, before any enforcement measures are taken by the judgment creditor.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">If applicable, what is the procedure for enforcement of foreign judgments under the general law in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Where neither the Brussels I (Recast) Regulation nor Cap. 10 applies and where no bilateral or multilateral treaty exists between Cyprus and the country in which the foreign judgment has been issued, that judgment may be enforced in Cyprus according to the general principles of common law (\u2018common law enforcement\u2019). In particular, the judgment creditor must file a new court action with the relevant District Court, the cause of action being the foreign judgment. In the context of the action, the Court will examine whether the requirements for recognition and enforcement are met.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What, if any, formal requirements do the courts of your jurisdiction impose upon foreign judgments before they can be enforced? For example, must the judgment be apostilled?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The formal requirements for the recognition and enforcement of a foreign judgment vary depending on the instrument or method under which the recognition and enforcement is sought.<\/p>\n<p>When enforcement is sought under the Brussels I (Recast) Regulation, the formalities required are provided for by Article 42 of the Regulation. In particular, the applicant must provide an authentic copy of the judgment and the certificate of enforceability as per Article 53 and Annex I of the Regulation, certifying that the judgment is enforceable in the country of origin. The Regulation does not require that the foreign judgment be apostilled. However, a Greek translation of the judgment may be needed.<\/p>\n<p>In case of an application for recognition and enforcement under the provisions of a bilateral or multilateral treaty, the formal requirements provided for by that treaty must be complied with. Such requirements usually include a certified or duly authenticated copy of the foreign judgment and a certified translation thereof but there is no general requirement that the foreign judgment should be apostilled.<\/p>\n<p>Cap. 10 also provides that a verified or certified or otherwise duly authenticated copy of the foreign judgment must be attached to the affidavit supporting the application for recognition and enforcement. A certified translation of the foreign judgment should also be attached. The same formal requirements must be met in the case of \u2018common law enforcement\u2019.<\/p>\n<p>It must be noted that, while there is no general requirement that the foreign judgment should be apostilled, in practice most applicants choose to have the certified copy of the foreign judgment apostilled in order to reinforce their position in relation to proper certification.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How long does it usually take to enforce or register a foreign judgment in your jurisdiction? Is there a summary procedure available?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>With the exception of foreign judgments which can be enforced pursuant to the provisions of the Brussels I (Recast) Regulation, an application for the recognition and enforcement of a foreign judgment may typically take 6 \u2013 8 months to be fully adjudicated. However, this timeframe may be prolonged depending on the complexity of the case, for example where the applicant applies for interim relief in the context of the registration and enforcement proceedings. In that case, the proceedings for recognition and enforcement may take 12\u201318 months to be completed.<\/p>\n<p>A summary procedure is not generally available in relation to an application for recognition and enforcement of a foreign judgment. However, a summary procedure may be available in the case of a court action in the context of \u2018common law enforcement\u2019.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is it possible to obtain interim relief (e.g. an injunction to restrain disposal of assets) while the enforcement or registration procedure takes place?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>According to Article 32(A1) of the Courts of Justice Law of 1960 (Law 14\/1960), an application to the court for interim relief may be made either before the commencement of, or during the course of, or after the issuance of a judgment, in relation to judicial or arbitral proceedings that took or are taking or will take place in Cyprus or abroad. Therefore, it is possible to apply for interim relief pending the registration and enforcement proceedings.<\/p>\n<p>Orders restraining the disposal of assets (\u2018freezing\u2019 or \u2018Mareva\u2019 injunctions) as well as ancillary orders for the disclosure of assets are usually sought in the context of registration and enforcement proceedings. Worldwide freezing orders are also available and may extend to assets of the judgment debtor which are located outside Cyprus. Freezing orders may under certain circumstances be issued against third persons who may have at their possession certain assets of the judgment debtor (\u2018Chabra orders\u2019). \u00a0The general requirements for granting interim relief are the following: (a) there is a serious issue to be tried, (b) there is a visible possibility of success in the main claim (i.e. in the registration and enforcement proceedings), and (c) that unless the requested relief is granted, it will be difficult or impossible to do justice at a later stage. This last requirement, in the context of a requested freezing injunction is considered to mean that there is a risk of dissipation of assets by the judgment debtor. If the judgment creditor applies for interim relief on an ex-parte basis, the judgment creditor must additionally prove urgency or other special circumstances why prior notice should not be given to the judgment debtor and there is also a duty to make full and frank disclosure of all relevant facts.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What is the limitation period for enforcing a foreign judgment in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>According to the Limitation of Actions Law 66(I)\/2012, Article 10, the limitation period for an action in relation to a court judgment is 15 years from the date on which that judgment becomes final. Therefore, the limitation period for an action for a \u2018common law enforcement\u2019 of a foreign judgment is 15 years.<\/p>\n<p>In cases where enforcement is sought under the provisions of Cap. 10, an application for recognition and enforcement may be filed within 6 years from the date of the foreign judgment, or if an appeal has been filed, from the date of the latest judgment that was issued in the context of those proceedings.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">On what grounds can the enforcement of foreign judgments be challenged in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The grounds on which enforcement may be challenged depend on the applicable enforcement regime, including EU instruments, international conventions, bilateral treaties and, where applicable, common-law principles. Common grounds for refusal of recognition or enforcement include:<\/p>\n<p>a)\u00a0 lack of jurisdiction of the foreign court;<\/p>\n<p>b)\u00a0 failure to satisfy the requirements of the applicable convention or statutory framework;<\/p>\n<p>c)\u00a0 fraud in obtaining the judgment;<\/p>\n<p>d)\u00a0 pending proceedings involving the same cause of action and parties;<\/p>\n<p>e)\u00a0 breach of the defendant&#8217;s right to a fair hearing, including inadequate service of the originating process if the judgment was given in default of appearance;<\/p>\n<p>f)\u00a0 the existence of a prior or conflicting judgment between the same parties; and<\/p>\n<p>g)\u00a0 incompatibility with Cypriot public policy.<\/p>\n<p>&nbsp;<\/p>\n<p>Where Regulation (EU) No. 1215\/2012 (Brussels I (Recast) Regulation) is applicable, the grounds on which recognition or enforcement may be challenged are significantly restricted and are, in essence, limited to paragraphs (e), (f) and (g) above.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Will the courts in your jurisdiction reconsider the merits of the judgment to be enforced?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Cypriot courts will not review the substantive merits of a foreign judgment. The court&#8217;s role is limited to examining whether the requirements of the applicable enforcement regime have been satisfied and whether any of the recognised grounds for refusal of recognition are present. It is therefore not open to the defendant to relitigate the underlying dispute or challenge the factual or legal findings of the foreign court.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Will the courts in your jurisdiction examine whether the foreign court had jurisdiction over the defendant? If so, what criteria will they apply to this?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Jurisdiction is one of the principal matters that may be examined by Cypriot courts when recognition or enforcement is sought. The extent of the review depends on the terms of the specific international treaty pursuant to which recognition and enforcement is sought. Where recognition and enforcement are sought pursuant to Regulation (EU) No. 1215\/2012 (Brussels I (Recast) Regulation), the jurisdiction of the court of origin cannot generally be reviewed by the Cypriot courts.<\/p>\n<p>In cases falling within international conventions or statutory schemes, the court will consider whether the jurisdictional requirements of the relevant instrument have been satisfied. Under the Hague Judgments Convention, recognition and enforcement are generally available only where one of the jurisdictional filters set out in Article 5 is met, such as the defendant&#8217;s habitual residence in the State of origin, consent or submission to that court&#8217;s jurisdiction, or a sufficient connection between the dispute and the State of origin. Specific jurisdictional bases are also provided for particular categories of disputes, including certain property and trust matters.<\/p>\n<p>Outside treaty-based regimes, Cypriot courts are able to examine whether the foreign court exercised jurisdiction on a basis recognised by Cyprus conflict-of-laws principles. Relevant connecting factors may include the defendant&#8217;s presence or residence in the foreign jurisdiction, submission to the jurisdiction of the foreign court, or a valid jurisdiction agreement in favour of that court.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Do the courts in your jurisdiction impose any requirements on the way in which the defendant was served with the proceedings? Can foreign judgments in default be enforced?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>No specific requirements are imposed as to the way the defendant was served in the foreign proceedings. However, the Cypriot courts will examine whether the defendant received proper and adequate notice of the proceedings in accordance with the applicable law, convention, treaty or procedural framework, and whether the defendant had a reasonable opportunity to present its case.<\/p>\n<p>&nbsp;<\/p>\n<p>Foreign default judgments are not automatically excluded from enforcement. They may be recognised and enforced in Cyprus provided that the applicable statutory or treaty requirements are satisfied, including those relating to jurisdiction, service and procedural fairness. However, if the default judgment was obtained without proper notification of the proceedings or in breach of the defendant&#8217;s right to be heard, enforcement is likely to be refused.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Do the courts in your jurisdiction have a discretion over whether or not to recognise foreign judgments?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Where the requirements of the applicable enforcement regime have been satisfied and no recognised ground for refusal exists, Cypriot courts do not enjoy an unfettered discretion to refuse recognition or enforcement. The relevant statutory provisions, conventions and EU instruments establish specific conditions for recognition and specific grounds on which enforcement may be refused.<\/p>\n<p>&nbsp;<\/p>\n<p>That said, certain refusal grounds, particularly those relating to public policy, may involve the exercise of judicial evaluation in determining whether the circumstances of the case justify refusal. Such exceptions are applied restrictively.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any types of foreign judgment which cannot be enforced in your jurisdiction? For example can foreign judgments for punitive or multiple damages be enforced?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>There are no specific categories of foreign judgments that are automatically excluded from recognition or enforcement in Cyprus. Whether a foreign judgment will be recognised or enforced is determined on a case-by-case basis, having regard to the applicable enforcement regime and the particular circumstances of the case, including whether any of the recognised grounds for refusal apply. In particular, Cypriot courts may refuse recognition or enforcement where doing so would be manifestly contrary to Cypriot public policy.<\/p>\n<p>&nbsp;<\/p>\n<p>Cyprus does not have a general statutory prohibition against enforcing foreign judgments awarding punitive, exemplary or multiple damages. Whilst such awards may be subject to closer scrutiny under the public policy exception, recognition or enforcement will not be refused merely because the damages are characterised as punitive, exemplary or multiple. Rather, the court will consider the particular circumstances of the case and whether the award is so excessive, penal in nature or otherwise incompatible with fundamental principles of Cypriot law as to offend Cypriot public policy.<\/p>\n<p>&nbsp;<\/p>\n<p>For completeness, certain matters, such as criminal penalties, fines, taxes and other public law claims, may fall outside the scope of the principal civil and commercial enforcement instruments and therefore may not be enforceable through the ordinary foreign judgment recognition procedures.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Can enforcement procedures be started in your jurisdiction if there is a pending appeal in the foreign jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. According to Article 3(3) of the Foreign Judgments (Reciprocal Enforcement) Law, Cap. 10, a judgment shall be deemed to be final notwithstanding that an appeal may be pending against it, or that it may still be subject to appeal in the courts of the country of the original court. However, a stay application may be lodged against enforcement based on Article 38(a) of Brussels I Recast Regulation.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Can you appeal a decision recognising or enforcing a foreign judgment in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. A decision of the District Court recognising or refusing to recognise and enforce a foreign judgment may be appealed to the Court of Appeal within 42 days, in accordance with the general rules on civil appeals under Cypriot procedural law. The filing of an appeal does not automatically suspend enforcement; a stay of execution pending the appeal must be sought separately and is granted at the court&#8217;s discretion.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Can interest be claimed on the judgment sum in your jurisdiction? If so on what basis and at what rate?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. According to Article 4(6) of the Foreign Judgments (Reciprocal Enforcement) Law, Cap. 10, a judgment can be recognised and enforced for the principal sum including any interest which by the law of the original court becomes payable under the judgment up until that time.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Do the courts of your jurisdiction require a foreign judgment to be converted into local currency for the purposes of enforcement?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>No. A foreign judgment expressed in a foreign currency may be recognised and enforced in Cyprus in that same currency, without the need for prior conversion into euro. Conversion, where it becomes necessary for the purposes of actual payment or satisfaction of the judgment, is typically carried out at the prevailing exchange rate at the time of payment or execution, rather than at the date of the judgment itself.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Can the costs of enforcement (e.g. court costs, as well as the parties\u2019 costs of instructing lawyers and other professionals) be recovered from the judgment debtor in your jurisdiction?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>In general, costs are required to be paid by the unsuccessful party to the proceedings, unless the Court orders otherwise. These include court costs, as well as costs of instructing lawyers. These will be taxed according to specific court scales based on minimum and maximum charges based on each claim\u2019s value. The new CPRs of 2023 stipulate under Part 39.13(4) that on taxation of costs, the Registrar shall allow all such costs, charges, and expenses as they deem necessary or proper for the attainment of justice or for the defence of the rights of any party and shall not allow costs which they deem to have been incurred or increased through over-caution, negligence, or mistake, or by the payment of special fees to a lawyer or special charges or expenses to witnesses or other persons, or other unusual expenses.<\/p>\n<p>As an exception, such costs may be allowed against the party who caused them. Therefore, as regards other professionals, this will depend on further evaluation and whether costs were reasonably and necessarily incurred for the attainment of justice and defence of the rights of the party. In addition, it is noteworthy that Part 34.1(1) of the new CPRs of 2023 imposes a duty to restrict expert evidence to that which is reasonably required to resolve the dispute that is the subject of the court proceedings.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are third parties allowed to fund enforcement action in your jurisdiction? If so, are there any restrictions on this and can third party funders be made liable for the costs incurred by the other side?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>A recent Court of Appeal judgment (Civil Appeal No. E.56\/2022) has recognised that third parties are allowed to fund enforcement actions. Third-party funding is strictly restricted to prevent abuse and the doctrines of maintenance and champerty, requiring agreements to be made in good faith and not contrary to public policy so that they do not promote frivolous litigation and pertain to unethical or illegal content. In that case, where the underlying dispute originated from an English court judgment, third-party funders, upon being made parties to the proceedings, were eventually made liable for the costs incurred by the other side. The Court of Appeal judgment upheld the recognition and enforcement of that judgment.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What do you think will be the most significant developments in the enforcement process in your jurisdiction in the next 5 years?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The most significant practical development is likely to be the growing relevance of the Hague Judgments Convention 2019. As more states accede, the roster has been expanding gradually, Cyprus is likely to see increasing use of the Convention route as an alternative to common-law or bilateral-treaty-based recognition, particularly for judgments from non-EU states. A notable example is the United Kingdom&#8217;s accession: since Brexit, enforcement in Cyprus has generally relied on the older Foreign Judgments (Reciprocal Enforcement) Act, Cap. 10, or common law action on the judgment debt, both slower and less predictable routes. The Convention&#8217;s entry into force between the United Kingdom and the European Union is expected to give United Kingdom judgment creditors a more structured, treaty-based alternative going forward.<\/p>\n<p>Also, Cyprus is currently working towards legislative reform aimed at making enforcement more effective in practice, through a proposed Civil Procedure (Amendment) Law of 2025. The bill is built around three main pillars: tightening protection over seized movable property and improving access to information on a debtor&#8217;s assets \u2014 including direct access for court bailiffs to state-held records, and a new statutory channel through which public authorities and other bodies can report asset-related information to judgment creditors, subject to data protection safeguards; strengthening the debtor&#8217;s own declaration obligations, with supplementary reporting on asset disposals and bank details; and introducing a new institution of a court-appointed Receiver-Manager, an independent officer of the court empowered to take possession of, manage and realise movable property and collect income towards satisfaction of the judgment. Together, these measures aim to close existing gaps in asset visibility and give judgment creditors more effective practical tools for enforcement in Cyprus.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Has your country ratified the Hague Choice of Courts Convention 2005, and if so when did it (or will it) come into force? If not, do you expect it to in the foreseeable future?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. The European Union approved the Convention on behalf of its Member States (Council Decision 2014\/887\/EU), and it entered into force for the European Union, including Cyprus, on 1 October 2015. Cyprus has therefore been bound by the Convention since that date, and Cypriot courts apply it to give effect to exclusive choice-of-court agreements in civil and commercial matters and to recognise\/enforce resulting judgments from other Contracting States.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Has your country ratified the Hague Judgments Convention 2019, and if so when did it (or will it) come into force? If not, do you expect it to in the foreseeable future?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. Cyprus is a European Union Member State, and the European Union approved the Convention on behalf of its Member States (Council Decision (EU) 2022\/1206), and it entered into force for the European Union, including Cyprus, on <strong>1 September 2023<\/strong><strong>.<\/strong><\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\r\n<div class=\"word-count-hidden\" style=\"display:none;\">Estimated word count: <span class=\"word-count\">5329<\/span><\/div>\r\n\r\n\t\t\t<\/ol>\r\n\r\n<script type=\"text\/javascript\" src=\"\/wp-content\/themes\/twentyseventeen\/src\/jquery\/components\/filter-guides.js\" async><\/script><\/div>"}},"_links":{"self":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/comparative_guide\/148652","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/comparative_guide"}],"about":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/types\/comparative_guide"}],"wp:attachment":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/media?parent=148652"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}