International recognition and enforcement of judgments

Copyright © 2026 LexisNexis
This Overview guides practitioners to materials on international recognition and enforcement of judgments in restructuring and insolvency, with links to legislation and case law.

Cross - border effectiveness of court orders is critical to asset recovery, restructurings and creditor protection. Practitioners must identify the applicable framework and its limits. Principal routes include: common law (action on the judgment) with defences of fraud, public policy and breach of natural justice; statutory registration under the Administration of Justice Act 1920 and the Foreign Judgments (Reciprocal Enforcement) Act 1933 for states; and legacy EU rules under the Civil Jurisdiction and Judgments Act 1982 for transitional cases.

In insolvency, the Cross‑Border Insolvency Regulations 2006 (implementing the UNCITRAL Model Law) enable recognition of foreign proceedings but do not create an enforcement regime for foreign avoidance judgments. Section 426 Insolvency Act 1986 permits assistance to courts of designated territories. The EU Insolvency Regulation (recast) (Regulation (EU) 2015/848) continues for proceedings within Withdrawal Agreement scope.

Rubin v Eurofinance confirms that insolvency judgments are enforced at common law; and the rule in Gibbs restricts discharge of English - law obligations by foreign restructurings...

To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.

Existing user? Sign-in TAKE A FREE TRIAL
Powered by Lexis+®
Latest Restructuring & Insolvency News

Insolvency Service publishes August 2026 enforcement outcomes management information

The Insolvency Service has updated its enforcement outcomes management information for August 2026. The data shows that there were 69 director...

Insolvency Service publishes monthly insolvency statistics for August 2026

The Insolvency Service has published its monthly company and individual insolvency statistics for August 2026 for England and Wales. The data shows...

New Practice Note—Public examination of the bankrupt under section 290 of the Insolvency Act 1986—key cases

The LexisNexis Restructuring & Insolvency practical guidance team has published a new Practice Note: ‘Public examination of the bankrupt under section...

Restructuring & Insolvency weekly highlights—17 September 2026

This week's edition of Restructuring & Insolvency weekly highlights includes: updates on the operational and reform priorities for the new Business...

View Restructuring & Insolvency by content type :  
News
Practice notes
Precedents
Q&As

Popular documents

What is the difference between an appeal and a review?

What is the difference between an appeal and a review?What is an appeal?An appeal in insolvency proceedings is no different to an appeal in normal litigation. An appeal will be allowed only if the appeal court is satisfied that the decision of the lower court was 'wrong' or 'unjust because of a

Avoiding invalid floating charges under section 245 of the Insolvency Act 1986

Avoiding invalid floating charges under section 245 of the Insolvency Act 1986Under section 245 of the Insolvency Act 1986 (IA 1986), liquidators and administrators can avoid certain floating charges if:•the floating charge was created at the relevant time•in certain circumstances, the company was

Where proceedings are ongoing and the defendant enters creditors’ voluntary liquidation but the

Where proceedings are ongoing and the defendant enters creditors’ voluntary liquidation but the liquidators refuse to settle proceedings (drop hands) without payment of their costs to date, is there any authority for getting paid costs as an expense of the liquidation or attaching personal liability

Misfeasance claims under section 212 of the Insolvency Act 1986

Misfeasance claims under section 212 of the Insolvency Act 1986What is misfeasance?A claim under section 212 of the Insolvency Act 1986 (IA 1986) operates where a person caught by the section has:•misapplied, retained or become accountable for any money or other property of the company•breached any
What is the difference between an appeal and a review?

What is the difference between an appeal and a review?

What is the difference between an appeal and a review?What is an appeal?An appeal in insolvency proceedings is no different to an appeal in normal litigation. An appeal will be allowed only if the appeal court is satisfied that the decision of the lower court was 'wrong' or 'unjust because of a

Avoiding invalid floating charges under section 245 of the Insolvency Act 1986

Avoiding invalid floating charges under section 245 of the Insolvency Act 1986

Avoiding invalid floating charges under section 245 of the Insolvency Act 1986Under section 245 of the Insolvency Act 1986 (IA 1986), liquidators and administrators can avoid certain floating charges if:•the floating charge was created at the relevant time•in certain circumstances, the company was

Where proceedings are ongoing and the defendant enters creditors’ voluntary liquidation but the

Where proceedings are ongoing and the defendant enters creditors’ voluntary liquidation but the

Where proceedings are ongoing and the defendant enters creditors’ voluntary liquidation but the liquidators refuse to settle proceedings (drop hands) without payment of their costs to date, is there any authority for getting paid costs as an expense of the liquidation or attaching personal liability

Misfeasance claims under section 212 of the Insolvency Act 1986

Misfeasance claims under section 212 of the Insolvency Act 1986

Misfeasance claims under section 212 of the Insolvency Act 1986What is misfeasance?A claim under section 212 of the Insolvency Act 1986 (IA 1986) operates where a person caught by the section has:•misapplied, retained or become accountable for any money or other property of the company•breached any