A United States judgment is not enforceable in France. There is no treaty between the two countries on the recognition of civil judgments. To recover from a French debtor, you must either settle amicably or obtain a French enforcement title — which means starting proceedings in France.
The treaty gap
The 2019 Hague Judgments Convention was designed to solve exactly this problem. It provides a common framework for recognising and enforcing civil and commercial judgments across contracting states, and it is in force for the European Union, the United Kingdom, Ukraine, Uruguay, Albania and Montenegro.
The United States signed the Convention but has not ratified it. Until ratification, it does not apply. There is likewise no bilateral treaty between the United States and France on the enforcement of civil judgments.
In practice, a French court asked to give effect to a US judgment applies the exequatur procedure — a full review of the foreign decision against French conditions. It is available, but it is slow, adversarial and expensive. For an unpaid invoice, it is almost never the rational route.
What actually works
Start in France, not in the US. For a straightforward unpaid invoice, obtaining a French title directly is faster and cheaper than obtaining a US judgment and then trying to have it recognised here.
Try amicable recovery first. A formal demand issued by a declared French collection firm, in French, citing French law, changes the debtor's calculation. Many French companies ignore correspondence in English from an unfamiliar foreign entity; far fewer ignore a French firm operating under Article R124-1 of the Code of Civil Enforcement Procedures.
Claim 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, without any reminder. These are rarely claimed by foreign creditors.
The French procedures available to you
Injonction de payer. A written application to the court, no hearing, no mandatory lawyer. Suitable where the debt is certain, quantified, due, and not seriously disputed. The resulting order, once served and unchallenged, becomes an enforcement title.
Référé-provision. Where the obligation is not seriously open to challenge, an emergency judge can order an interim payment within weeks, with immediate enforceability.
Assignation au fond. Full proceedings on the merits. Slower and more expensive, but the only route where the debtor raises a serious defence.
A deadline that changed on 1 September 2026
Decree No. 2026-96 of 16 February 2026 reformed the injonction de payer procedure. For orders made on or after 1 September 2026, the creditor has three months — not six — to serve the order on the debtor, failing which it lapses and the procedure must be restarted from the beginning.
This matters particularly for foreign creditors, where coordination delays across time zones and legal teams can easily consume a month.
Frequently asked questions
Is a US court judgment enforceable in France?
Not directly. There is no treaty between the United States and France on the recognition of civil judgments, and the United States has not ratified the 2019 Hague Judgments Convention. Recognition requires a separate exequatur procedure before a French court.
Should I sue in the US or in France?
For an unpaid commercial invoice against a French debtor with assets in France, starting in France is almost always faster and cheaper.
Can I recover in US dollars?
The claim is pursued in the currency of the contract. Recovered funds are remitted by international transfer.
What does it cost me if nothing is recovered?
Nothing on the amicable phase. Court and bailiff costs on the judicial phase are billed at cost and are your responsibility, but they are only incurred with your prior agreement.