Brussels Regulation

EU Regulation 1215/2012 (Brussels I Recast) governed jurisdiction and the recognition and enforcement of judgements in civil and commercial matters between EU member states. Following Brexit, the Brussels Regulation no longer applies to judgements given in UK proceedings commenced after 31 December 2020.

In practice

The Brussels Regulation provided near-automatic recognition of judgements across the EU without exequatur. Post-Brexit, English judgements no longer benefit from this regime in EU member states, and EU judgements cannot be enforced in England under it. Creditors must now rely on the Hague Convention 2005 (for exclusive jurisdiction clauses), bilateral treaties, or common law routes. This is one of the most significant practical consequences of Brexit for cross-border enforcement.