Enforcement of a foreign judgment (fuldbyrdelse af udenlandsk dom)
Also known as recognition of a foreign judgment, brussels i, lugano convention, anerkendelse af udenlandsk dom, bruxelles i, lugano-konventionen
Enforcement of a foreign judgment means having a judgment from one country enforced in another — within the EU it happens without a fresh court case.
In practice
Within the EU, judgments are recognised across borders. A Danish judgment can be enforced against a debtor in Germany without the case having to be run again from the start.
Outside the EU the picture is different. There is no equivalent automatic route, and a Danish judgment may have no effect at all — in which case the case has to be brought in the debtor’s own country from scratch. That is one of the reasons why credit to customers outside the EU should be assessed separately.
Where it commonly goes wrong
- A claim outside the EU is treated like a claim inside the EU. Enforcement is an entirely different exercise.