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How will UK and EU courts treat jurisdiction and enforcement following the end of the Brexit Implementation Period?

  • United Kingdom
  • Europe
  • Brexit
  • Litigation and dispute management


The Brexit Implementation Period has now ended so what rules will govern jurisdiction and enforcement in cross-border commercial disputes after 1 January 2021? The EU has not (yet) given its consent for the UK to accede to the Lugano Convention 2007, and the deadline for the UK to accede with effect from 1 January 2021 passed on 1 October 2020. The UK deposited a new instrument of accession to the Hague Convention on Choice of Court Agreements 2005 (Hague 2005) on 28 September 2020. This means that from 1 January 2021 and until further notice, Hague 2005 will apply as between the UK and EU. Our flow-charts guide you through how the UK and EU courts will treat jurisdiction and enforcement.

Making sense of enforcement - UK

Making sense of enforcement - EU

Making sense of jurisdiction