Lugano Convention

The Lugano Convention 2007 on Jurisdiction and the Recognition and Enforcement of Judgments in Civil and Commercial Matters extended the Brussels regime to EFTA states (Switzerland, Norway, Iceland, Liechtenstein). The UK's application to accede to the Lugano Convention as an independent party following Brexit was refused by the EU.

In practice

The refusal of the UK's Lugano application means that there is no streamlined enforcement route between the UK and EFTA states. Judgements from Switzerland, Norway, or Iceland must be enforced in England under the common law (fresh proceedings) or, where applicable, bilateral treaties. This gap is one of the reasons the Hague Convention 2019 is seen as increasingly important for post-Brexit cross-border enforcement.