The recognition of UK judgments issued before 1st of July 2025 in the Republic of Cyprus is governed by the Foreign Judgments (Reciprocal Enforcement) Law (Cap. 10) (hereinafter “Cap. 10”) and Foreign Judgments (Reciprocal Enforcement) Rules (1062/1935) (the “Rules”), as amended to date. Furthermore, both Cyprus and the United Kingdom are parties to the Convention of 1 February 1971 on the Recognition and Enforcement of Foreign Judgments in Civil and Commercial Matters – Hague International Convention 1971, which governs exclusive jurisdiction agreements in civil and commercial matters.
For the recognition of UK judgments issued after 1st of July the Hague Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters (Hague 2019) has come to force[1].
Under Article 2 of Cap. 10 “judgment” means a judgment or order given or made by a Court in any civil or criminal proceedings, for the payment of a sum of money in respect of compensation or damages to any injured party.
According to Article 3(3) of Cap. 10,[2] a judgment shall be considered final even if an appeal is pending or may still be filled before the courts of the State in which the original judgment was issued.
Under Article 4 of Cap. 10, a judgment creditor may apply to the District Court for the registration of a foreign judgment at any time within six years from the date of the judgment, or, in the case of an appeal, within six years from the date of the final appellate judgment.
In such proceedings,[3] the application must be supported by an affidavit of facts.
An order granting leave to register the judgment is to be prepared on behalf of the judgment creditor. Every such order must specify the time period within which the judgment debtor may apply to set aside the registration. This application must be brought by summons, supported by an affidavit. According to Rule 11 of the Rules, where an application to set aside registration is pending, no execution of the registered judgment may take place until the application has been finally determined.
It is noted that the subject-matter jurisdiction of the Cypriot Court, pursuant to Cap. 10, is limited to examining whether the conditions for the recognition of the foreign judgment are satisfied and does not extend to a review of the merits of the decision.
Following the successful registration of a foreign judgment in Cyprus, enforcement may be pursued against both movable and immovable property under Article 14 of the Civil Procedure Law. Available enforcement methods include writs of execution for the sale of movables or immovables, charging orders through the registration of a MEMO at the Land Registry, writs of sequestration, possession, or delivery, and various injunctions affecting the debtor’s interests in shares or other assets.
The Cyprus courts may refuse recognition on several grounds, including lack of jurisdiction, fraud, insufficient notice to the defendant, or conflict with public policy. Enforcement is possible but may involve a more detailed review by the Cyprus courts.
For UK judgments issued on or after 01.07.2025, the 2019 Hague Judgments Convention will apply.[4] This provides a more streamlined and predictable regime for civil and commercial matters between the UK and Cyprus. The Convention limits the grounds for refusal and prohibits review of the merits, but it applies only to judgments that meet specific jurisdictional and subject-matter criteria. Judgments involving areas like insolvency, family law, and certain IP rights are excluded, and some jurisdiction clauses may fall outside the Convention’s scope – requiring fallback to Cyprus domestic law.
The filing of a recognition application does not in itself give rise to any automatic consequences in relation to the winding-up application. In particular, the filing of such an application does not imply recognition; rather, a hearing must be conducted, and a judgment must be issued whereby a UK Judgment is recognized, and its enforcement is ordered.
Pursuant to the applicable legal framework in Cyprus, once a foreign judgment is recognized by a Cypriot court, it is deemed to have the same status and legal effect as a judgment issued by a domestic court. Specifically, in accordance with established case law and statutory provisions, a recognition judgment effectively “domesticates” the foreign judgment.
As stated in the case law and in line with the principles embodied in Cap. 10, which governs the recognition and enforcement of UK judgments, such recognition does not involve a review of the merits of the case but is confined to verifying the existence of the legal conditions for recognition (jurisdiction, satisfaction of the judgment, treaty requirements, etc.).
Once these criteria are met and the recognition is granted, the foreign judgment is considered as if it had been issued by a Cypriot court and enjoys the same enforceability and legal weight as any other domestic court judgment. This principle reinforces legal certainty and ensures compliance with Cyprus’s international obligations under various bilateral and multilateral treaties, including the Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil and Commercial Matters (Ratifying Law 11/76).
Maria P. Prokopiou
[1] To enforce a UK judgment in Cyprus under the 2019 Hague Judgments Convention, the UK court must have jurisdiction in accordance with Article 5 (e.g., based on the defendant’s habitual residence or a valid jurisdiction agreement). The judgment must also be final, enforceable in the UK, and fall within the Convention’s scope, which covers civil and commercial matters.
Recognition may be refused only on limited grounds, such as if the defendant was not properly notified or denied due process, if the judgment was obtained by fraud, if it violates Cypriot public policy, if there is an incompatible earlier judgment, or if the subject matter falls outside the Convention’s scope (e.g., family law, insolvency, defamation).
[2] Primary Foreign (Original) Application No. 1/17, BM‑Bank JSC (formerly BM‑BANK and OJSC BANK OF MOSCOW) v. Andrey Valerievich Chernyakov et al., dated 07 July 2017: “Article 3(2)(1) of Chapter 10 states that this part of the Law applies if the judgment for which registration is sought is “final and conclusive as between the parties thereto”, and according to Article 3(3): “3(1) ……………………………… (2) ………………………………. (3) For the purposes of this article, a judgment shall be deemed to be final and conclusive notwithstanding that an appeal may be pending against it or that it may still be subject to appeal in the courts of the country of the original court.” A final and conclusive judgment, notwithstanding the content of Article 3(3) and for the purposes of the present article, is a judgment in respect of which all avenues of substantive review have been exhausted and which is now binding on the parties. This is in accordance with the decision Michalakis Raftopoulos v. Republic (1998) 4 C.L.R. 7. “A prerequisite for the creation of a binding effect is a determination on the substance of the dispute… Binding effect arises from the court’s findings on the essential facts.” For the purposes of the present application, and subject to Article 3(3), a final and conclusive judgment is one in which the court examined the merits and reached findings on the essential facts”.
[3] Foreign Judgments (Reciprocal Enforcement) Rules (1062/1935) are applicable, and the relevant application may be submitted either by summons or ex parte.
[4] It is noted that the HCCH 2019 Judgments Convention does not abolish the Hague Internation Convention of 1971. Instead, it operates as a separate, more modern instrument. Both conventions can coexist, and the Hague Internation Convention of 1971 remains in force for states that are party to it. However, where both conventions apply between the same states, the 2019 Convention will generally take precedence – unless those states agree otherwise – according to Article 23(2) of the 2019 Hague Judgments Convention.
