How to Recover a Debt from the United Kingdom If the Debtor Has Moved to the EU?

What Brexit changed for debt recovery

Until the end of 2020, judgments between the UK and EU states were recognised under EU rules. That route no longer applies after Brexit, and the UK has so far not been able to join the Lugano Convention. In practice, whether a UK judgment can be enforced in the debtor's country now depends mainly on two Hague conventions and on the national law of the state where the debtor has assets (including any bilateral treaty between that state and the UK).

• Hague Convention of 2005 on Choice of Court Agreements - the UK has applied it in its own right since 1 January 2021. It covers exclusive choice-of-court clauses, and its scope is narrower than the former EU rules (HCCH - status table).
• Hague Convention of 2019 on the Recognition and Enforcement of Judgments - in force for the UK since 1 July 2025 and covering judgments given in proceedings started on or after that date; the judgment must meet the convention's requirements, so recognition is not automatic (HCCH - status table of the 2019 Convention).

For claims under older contracts and proceedings, or without an exclusive jurisdiction clause, enforcement depends on the law of the debtor's country, so find out early where the debtor has assets or bank accounts.

Where to start proceedings

• A court in the UK - possible where the contract points to the English courts or other grounds of jurisdiction exist. The judgment must then be recognised and enforced in the debtor's country, under the Hague conventions or national law.
• A court in the debtor's country - a judgment of that court is enforced locally, which can be simpler in terms of enforcement, but proceedings follow local rules, usually with a local lawyer.

The choice depends on the contract (jurisdiction clause, governing law), where the debtor's assets are and the cost. Legal assessment is for a lawyer qualified in the relevant jurisdiction (solicitor, advocate, legal adviser) - this article cannot replace it.

Time limits - do not delay

In England and Wales a claim founded on a simple contract is time-barred six years after the cause of action accrued - usually the date of breach (Limitation Act 1980, s. 5); for contracts made as a deed the period is 12 years (s. 8). In other countries the limits can be shorter or counted differently, so in a cross-border case check the limit for each country separately.

What to prepare before a demand for payment

• the contract or order, payment terms and any choice-of-court clause,
• invoices, correspondence and proof that the service or delivery was performed,
• for deliveries of goods - transport and customs documents (CMR consignment note, declarations with an MRN) proving delivery; see documents for exports from Poland to the UK and import from the UK to Poland,
• current details of the debtor: company name and registration number or home address, the new EU address, and information on assets and accounts.

Common debt collection mistakes are covered in 5 biggest debt collection mistakes.

How we can help

We are a customs agency, not a law firm. We can help organise transport and customs documents and refer the matter to cooperating debt-collection and legal partners. Support includes, among other things:

• amicable debt collection (demand for payment, negotiations with the debtor),
• court proceedings and bailiff enforcement in the UK or an EU country - through qualified local representatives,
• recovery of transport debts (unpaid invoices for freight and carriage of goods),
• debtor monitoring and consultation on next steps.

Describe your case through the contact form and we will tell you which documents are needed for an assessment.

Frequently asked questions