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How will EU and UK (including Northern Ireland) courts treat jurisdiction and enforcement after Brexit?

  • Ireland
  • Northern Ireland
  • Brexit

04-11-2020

With six weeks to go until the end of the EU/UK Implementation Period, finally some clarity over which 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 (including Northern Ireland) and EU courts will treat jurisdiction and enforcement after Brexit.

Making sense of enforcement post-Brexit: How will the courts of EU Member States approach enforcement of judgments following a no-deal?

Making sense of enforcement post-Brexit: How will the UK courts approach enforcement of judgments following a no-deal?

Making sense of jurisdiction post-Brexit: How will the courts approach jurisdiction following a no-deal? 

Norman Fitzgerald, Partner
Matthew Howse, Partner

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