The End of Uncertainty for British Jurisdictions
Following Great Britain's effective withdrawal from the Lugano Convention, enforcing English court decisions before European Union tribunals carried unprecedented risks of rejection. Since July 2025, the "Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters" officially applies comprehensively to the UK, including Scotland and Northern Ireland.
Securing "Forum Shopping"
This unilateral ratification by the UK firmly re-establishes London's status as the world's safest and most neutral jurisdiction. Judgments handed down by London judges are now immediately opposable under domestic law across the 27 EU member states (and other signatories like Ukraine). Article 4 of the Treaty specifically prohibits a "review of the merits" of the dispute by a third-country court.
Strategic Exclusions: Arbitration and IP
It is critical to note, however, that K&P Legal's Litigation desk highlights certain major corporate fields remain excluded from the Convention: arbitration, insolvency, and intellectual property (IP). For our clients facing highly complex cross-border seizures, this new paradigm—applicable solely to disputes initiated *after* the cutoff date—requires a meticulous review of jurisdictional clauses in ongoing European financing agreements.
