Unified European Rules on the Recognition and Enforceability of Third-Country Judgments

The Brussels Ia Regulation governs the recognition and enforcement of judgments in civil and commercial matters issued in other Member States. In contrast, it has so far been up to the Member States to determine the conditions under which judgments from third countries can be recognised and enforced in the European Union. This article discusses why it would make sense to create uniform EU rules for third-country decisions as part of the upcoming reform of the Brussels Ia Regulation, how such rules could be designed in detail, and how they would relate to the already existing Hague Conventions on recognition and enforcement.