Exequatur

A judicial order authorising the enforcement of a foreign judgement in the jurisdiction where enforcement is sought. In many civil law countries, exequatur proceedings are the standard method for giving effect to foreign judgements. The concept is broadly equivalent to the registration procedure used in England and Wales.

In practice

While English law does not use the term "exequatur", practitioners dealing with cross-border enforcement frequently encounter it. When enforcing an English judgement abroad, the creditor may need to obtain an exequatur from the foreign court. Conversely, a foreign creditor seeking enforcement in England will use the statutory registration routes or commence fresh proceedings at common law.