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ARTICLE · 27 APRIL 2026

Enforcement Of Judgments: Clarification From The High Court On NI Judgment Recognition

Dillon Eustace
Dillon Eustace
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Dillon Eustace

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Post-Brexit enforcement of UK judgments in Ireland has become more complex and costly under common law rules. A recent High Court decision clarifies that the Hague Convention on Choice of Court Agreements 2005 applies to default judgments, providing a streamlined pathway for cross-border enforcement when exclusive jurisdiction clauses are in place.

IrelandLitigation, Mediation & Arbitration
Peter Bredin
Peter Bredin
Neil Cowhey
Neil Cowhey
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Post-Brexit, a key concern for parties to cross-border litigation within the EU has been the recognition and enforcement of judgments obtained in the UK and vice versa, particularly in Ireland given its very close ties to both Great Britain and Northern Ireland.

Position Post Brexit

Recognition and enforcement of judgments within the EU is regulated by the Brussels I Regulation (recast) (1215/2012) (Brussels Recast). Brussels Recast provides that in most cases a judgment in any EU Member State will be recognised in other EU Member States without any ‘special procedure’ being required (in particular, without the need for a declaration of enforceability). This greatly reduces the cost, time, complexity and uncertainty of cross-border enforcement within the EU. With Brexit, this reciprocal framework between the UK and EU no longer applies and in the intervening years, a more cumbersome and costly process under common law rules was required.

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