Since 1 July 2025, English judgments are again recognised across the EU under the 2019 Hague Judgments Convention — but only for proceedings commenced on or after that date. If your case started earlier, you are still in the fragmented post-Brexit regime, and starting fresh in France is often the faster route.
The 1 July 2025 dividing line
Before Brexit, judgments moved freely between the UK and EU member states under Regulation (EU) No 1215/2012. That ended, and for several years UK creditors faced a patchwork of older instruments and common law procedures.
The 2019 Hague Judgments Convention entered into force for the UK on 1 July 2025, following ratification on 27 June 2024. It restores reciprocal recognition between the UK and EU member states — with one critical qualification: it applies to judgments given in proceedings commenced on or after 1 July 2025.
So the practical question for any UK creditor is simply: when were proceedings issued?
On or after 1 July 2025 — your English judgment should be recognisable in France under the Convention, subject to its conditions.
Before that date — the Convention does not apply. You fall back on the pre-existing regime, which for France means older reciprocal enforcement arrangements or proceedings on the judgment. Workable, but slower and less predictable than most creditors expect.
When starting in France is the better option
Even where enforcement of an English judgment is technically available, it is worth comparing routes. For a straightforward unpaid invoice, obtaining a French title directly is frequently faster than litigating in England and then enforcing here.
The injonction de payer requires no hearing and no mandatory legal representation. Where the claim is not seriously disputed, it produces an enforcement title on the strength of documents alone.
And before any court is involved, amicable recovery resolves a substantial share of files. A formal demand from a French firm, in French, citing French law, carries weight that correspondence from a UK creditor does not.
What French law gives you
Where French law governs the contract, Article L441-10 of the Commercial Code makes late payment interest and a fixed €40 recovery indemnity per invoice due automatically. Payment terms between businesses are capped at 60 days from invoice date, or 45 days end of month where expressly agreed.
Under Article L110-4 of the Commercial Code, claims between businesses are generally time-barred after five years.
A deadline that changed on 1 September 2026
Decree No. 2026-96 of 16 February 2026 shortened the time limit for serving an injonction de payer order from six months to three, for orders made on or after 1 September 2026. Missing it voids the order.
Frequently asked questions
Is an English judgment enforceable in France?
Under the 2019 Hague Judgments Convention, yes — provided the proceedings were commenced on or after 1 July 2025, when the Convention entered into force for the UK, and provided the Convention's conditions are met.
What if my proceedings started before July 2025?
The Convention does not apply. Enforcement then depends on the pre-existing arrangements between the UK and France, which are slower and less certain. In many cases, starting fresh in France is the pragmatic choice.
Do I need a French lawyer?
Not for the injonction de payer procedure, where legal representation is not mandatory. We handle the application and the enforcement stage.
How are recovered funds returned?
By transfer, on the 25th of the month following collection.