Enforcing a Foreign Judgment in England and Wales: The Routes, the Documents and What Must Be Translated

Two Polish judgments, identical word for word, can take different roads into an English court. If the Warsaw claim was filed in June 2025, the 2019 Hague Judgments Convention does not apply and, unless the 2005 Convention does, the creditor must sue again in England. If it was filed in August 2025, the Convention's registration route is open. The Convention applies only if it "had effect between" the two states "at the time the proceedings were instituted" (Article 16), and between the UK and the EU that date is 1 July 2025.

Facts like that decide these applications, and they sit in the foreign-language papers: when proceedings began, whether the defendant was served, whether the judgment is final. Below: the routes, the translation rules, what to translate and the registration steps.

Which route applies to my foreign judgment?

The country, when proceedings began and the subject matter decide it:

The country lists for the Acts come from Annex 10 of the King's Bench Guide 2026, except Israel, which the Annex omits although a 1971 Order in Council, amended in 2003, applies the 1933 Act to its courts. Each country's Order sets the courts covered. Section 6 of the 1933 Act makes registration the only way to recover a sum under a judgment it covers. Under the 1920 Act you may sue instead, but section 9(5) denies you the costs of that action unless registration was refused or the court orders otherwise.

What does CPR 74.4 require for the translation?

A translation of the judgment into English, certified in one of two ways. The written evidence must exhibit "the judgment or a verified or certified or otherwise authenticated copy of it" and, "where the judgment is not in English, a translation of it into English (i) certified by a notary public or other qualified person; or (ii) accompanied by written evidence confirming that the translation is accurate" (rule 74.4(1)).

A notary is one option, not a requirement: a qualified translator's certificate can meet limb (i), and limb (ii) allows written evidence, such as a witness statement, confirming accuracy.

The Conventions, which have the force of law in the UK, add their own rule: documents not in an official language of the requested State "shall be accompanied by a certified translation into an official language, unless the law of the requested State provides otherwise" (2019 Convention, Article 12(4); 2005 Convention, Article 13(4)). So the service and enforceability documents that CPR 74.4(6) and (7) call for need certified translations too.

Which documents need translating, and what must the translation show?

Everything the court will rely on, in full:

• The whole judgment, reasons included. The 2019 Convention asks for "a complete and certified copy", and the reasons often record what eligibility turns on, such as where the defendant lived or whether they appeared (Article 5).
• The date proceedings began, wherever it appears, because it decides whether the 2019 Convention applies.
• Finality and enforceability endorsements. A German enforceable copy (vollstreckbare Ausfertigung) ends with the clause "Vorstehende Ausfertigung wird ... zum Zwecke der Zwangsvollstreckung erteilt", signed by the registry official and sealed (ZPO sections 724 and 725), and finality is shown by a separate certificate (Rechtskraftzeugnis, section 706). A Spanish judgment that can no longer be appealed is firme (Civil Procedure Act, article 207). These endorsements prove the judgment "has effect" and "is enforceable in the State of origin" (Article 4(3)), so they are translated word for word, never reduced to "[stamp]".
• Proof of service for a judgment given in default (Article 12(1)(b); CPR 74.4(5)(b)). Under the 1933 Act, registration must be set aside if the defendant did not receive notice "in sufficient time to enable him to defend the proceedings and did not appear" (section 4).
• The exclusive choice of court agreement for a 2005 Convention application (Article 13(1)(b)).
• Interest, costs and certificates: the rate and dates of interest, which the evidence must state (rule 74.4(2)(e)), any costs determination, and any certificate in the Hague Conference's recommended form (Article 12(3)).

Our guide to translated evidence in UK courts covers translator's notes and disputed wording.

How do you register a foreign judgment, step by step?

1. Check scope. Money judgments only under the 1933 Act; superior courts only under the 1920 Act; under the 2019 Convention, civil or commercial matters outside Article 2, which excludes family law, maintenance, succession, insolvency, defamation, privacy, intellectual property and arbitration, among others.
2. Obtain the papers from the court of origin: a certified copy of the judgment, the finality or enforceability certificate and, for a default judgment, proof of service.
3. Have everything not in English translated and certified under rule 74.4(1)(b).
4. Prepare the written evidence: address for service, the debtor's details, the grounds, the unsatisfied amount and interest (rule 74.4(2)), plus the statements for your route (rule 74.4(3) to (7)).
5. Apply to the High Court without notice (rule 74.3), under Part 23. Applications go to the King's Bench Division and may be heard by a Master (PD 74A, paras 4.1 and 4.4).
6. Serve the registration order (rule 74.6). It states the debtor's right to apply to set it aside and the time for doing so.
7. Enforce once that period ends or any application is decided, after filing evidence of service (rule 74.9).

The order usually directs that the costs of the application be assessed and added to the judgment debt (King's Bench Guide, para 25.13), so keep the translation invoice with your costs. For certificate wording across forums, see certified translations for solicitors.

What if no treaty or Act applies?

Sue on the judgment. Where a country has no agreement with the UK, "a fresh action will need to be brought here by claim form based on the judgment of the court of the foreign country" (King's Bench Guide, para 25.7). The English court then asks whether the foreign court had jurisdiction by English standards, for example because the defendant was present in that country when proceedings were instituted or submitted to the jurisdiction by appearing (Rubin v Eurofinance [2012] UKSC 46, paras 6 and 7). So the translations needed are much the same: the complete judgment and the record of service and appearance.

Are arbitration awards different?

Yes, and the translation rule is stricter. To enforce a New York Convention award, section 102(2) of the Arbitration Act 1996 requires "a translation of it certified by an official or sworn translator or by a diplomatic or consular agent", and CPR 62.18(6) requires those documents to be exhibited. The UK has no sworn translators, so ask the lawyer handling the enforcement which translation the court will accept; an official or sworn translator abroad, or a diplomatic or consular agent, meets the wording. Official Translations provides certified translations, not sworn, official or consular ones, so for this step use a translator who meets section 102(2).

How do Scotland and Northern Ireland differ?

In Scotland, registration is in the Court of Session, and Rule of Court 62.3 requires "a translation into English certified as correct by the translator", whose certificate gives their "full name, address and qualification". Unlike England, Scotland also requires a declaration of the sterling equivalent, with the exchange rate and its source (rule 62.2).

In Northern Ireland, applications go to the High Court. For the 1920 and 1933 Acts, Order 71, rule 3 asks for a translation "certified by a notary public or authenticated by affidavit"; for the Conventions, rule 25 also accepts "a person qualified for the purpose in one of the Contracting States".

What about enforcing an English judgment abroad?

Apply under CPR 74.12 for a certified copy with a judge's certificate, in Form 110 for the Acts or the Hague Conference's form for the Conventions (PD 74A, paras 7.1 to 7.7). The foreign court then applies its own translation rules, and many civil-law courts expect their own sworn translators, so ask the lawyer abroad first.

Where a notarised and apostilled translation is accepted, Official Translations can supply one: the certified translation is notarised and then apostilled, and the apostille is attached to the translation, not to the judgment. The FCDO Legalisation Office can separately apostille a sealed English court document. See certified vs notarised translation and our apostille service.

Common mistakes that stall registration

• Translating only the order, without the reasons that show jurisdiction, appearance or service.
• "[Stamp]" in place of the finality endorsement, which is the evidence of enforceability.
• Amounts converted into sterling in the translation or the evidence.
• No proof of service for a default judgment.
• Relying on the 2019 Convention for proceedings begun before it took effect between the two states.
• Suing at common law on a judgment the 1933 Act covers.
• Missing the 12-month window under the 1920 Act without asking for longer.

Checklist: documents for registering a foreign judgment

Questions people ask