How to Enforce a UK Court Judgment in Spain: A New Era Under the Hague Convention
Since the UK’s departure from the European Union, the automatic recognition and enforcement of UK court judgments in Spain, which was previously handled under the EU’s Brussels I Recast Regulation, came to an end. This required many judgment creditors to rely on the often lengthy and complex Spanish domestic exequatur procedure for recognition.
A significant simplification has now arrived with the introduction of the Hague Convention of 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters (the “Hague Judgments Convention”). This international treaty establishes a clear, uniform framework for the circulation and enforcement of civil and commercial judgments between Contracting States.
As Spain is bound by the European Union’s accession to the Convention, and the UK’s ratification became effective on 1 July 2025, this new framework applies to the enforcement of judgments given in proceedings commenced on or after that date, fostering greater predictability and reducing transactional costs in cross-border disputes.
The Enforcement Process in Spain
The primary benefit of the Hague Judgments Convention is that it obligates Spanish courts to recognise and enforce eligible UK judgments without conducting any review of the merits of the original decision.
The broad steps for enforcing a UK judgment in Spain under this framework are:
1. Eligibility Review: The judgment must be in a civil or commercial matter (with certain exclusions) and must be final and enforceable in the UK (the State of origin).
2. Application Filing: The interested party presents an application for recognition and enforcement before the competent Spanish Courts of First Instance.
3. Documentation: Key documentation required includes a complete and certified copy of the UK judgment, evidence confirming its enforceability in the UK, and a certified Spanish translation of the judgment and relevant accompanying documents.
4. Review and Recognition: The Spanish court reviews the application solely against a set of strictly limited grounds for refusal specified in the Convention. These grounds are primarily procedural, such as a judgment being obtained by fraud, or if recognition would be manifestly incompatible with Spanish public policy.
5. Execution: Once the Spanish court issues the order confirming recognition, the UK judgment gains the same legal status as a domestic Spanish judgment and can be enforced through the normal Spanish enforcement system, including securing assets or recovering debts.
GB Abogados: Your Specialist in Cross-Border Enforcement in Spain
At GB Abogados, we are English-speaking lawyers with extensive experience in the practical application of Spanish law for an international clientele. We guide both international individuals and client companies through the complexities of the Spanish legal system, ensuring their UK judgments are recognised and effectively executed against assets in Spain.
We provide clear, practical, and easy-to-follow guidance, managing all aspects of the enforcement process—from preparing the necessary cross-border legal documentation to representing you in court and overseeing the final execution of the court order.
If you have a UK court judgment that you need to enforce in Spain, contact our team to discuss your specific circumstances. Take advantage of a free, no-obligation consultation to find out how we can help you navigate this process and achieve a successful outcome.
