At midnight on 31 December, marking New Year's Day in
Brussels and 11pm in London, the transition period provided for by
the Brexit Withdrawal Agreement came to an end, cutting the UK
loose from the EU almost a year after its formal departure.
Up to this date, EU rules, set out in what is generally
known as 'the Recast Brussels Regulation', governed the
enforceability of UK judgments in EU Member States (and vice
versa). Now that the UK is no longer a party to this Regulation,
how can Irish judgments be enforced in the UK (and vice versa)?
Options post-Brexit
Regrettably, the EU-UK Trade and Cooperation Agreement does not
deal with jurisdiction and enforcement of judgments.
Therefore, one must turn to the Lugano Convention, the Hague
Convention and common law rules.
