Why The UK May Consider Taking The Swiss Approach

With question marks over the UK as a place of jurisdiction, one option would be to replace the present arrangements with the Lugano Convention

The Brussels Regulation

The Brussels Regulation (1215/2012) determines which EU member state court has jurisdiction in a dispute and ensures that judgements will be recognised and enforced without the need for separate proceedings in EU member states. Once the UK formally exits the EU the Brussels Regulation will cease to apply for the UK. It is not clear what approach the UK will follow to replace the Brussels Regulation. What does this mean for litigants?

Jurisdiction clauses

If the UK does not comprehensively replace the Brussels Regulation the recognition and enforceability of English judgements in Europe may depend on the national laws of the country where recognition and enforcement is being sought. As a result, the process of recognising and enforcing English judgements in European countries may take longer, cost