A German supplier wins a court judgment against its Polish distributor in Frankfurt. The distributor holds assets in Warsaw – receivables, bank accounts, real property. Without enforcement in Poland, the judgment is worth nothing more than paper. The question is not whether enforcement is possible. The question is how fast and at what cost.

Under Rozporządzenie Bruksela I bis (Brussels I bis Regulation, EU Regulation 1215/2012), a judgment issued in one EU Member State is enforceable in Poland without any intermediate declaration of enforceability. The abolition of the exequatur procedure – effective since January 2015 – means the creditor proceeds directly to the Polish enforcement stage. The District Court (Sąd Rejonowy) or Regional Court (Sąd Okręgowy) with jurisdiction over the debtor's assets handles the enforcement application, and a court bailiff (komornik sądowy) executes the award.

This guide walks through each procedural step, from obtaining the Brussels I bis certificate to completing execution in Poland. It covers timelines, court fees, the three most common business scenarios, and the mistakes that cost creditors months of delay.

What does Brussels I bis actually change for creditors enforcing judgments in Poland?

The short answer: it eliminates the most expensive step. Before 2015, a foreign creditor needed a separate Polish court proceeding – exequatur – to declare a foreign judgment enforceable. That added months and cost. Brussels I bis removes the declaration requirement entirely for judgments issued within the EU. The creditor attaches the judgment, the standard certificate from the court of origin, and a translation, then applies directly to the Polish enforcement authority.

Three Polish institutions handle different parts of the process. The National Court Register (Krajowy Rejestr Sądowy, KRS) is relevant when the debtor is a registered company – it confirms the legal entity, its registered address, and its representation structure. The bailiff's chamber (Izba Komornicza) supervises enforcement officers. The district or regional civil court supervises the bailiff's conduct and hears challenges.

The certificate required under Brussels I bis is issued by the court of origin – not by any Polish authority. It confirms the judgment is enforceable in the issuing state. The creditor must present this certificate, the judgment, and a certified Polish translation. Translation costs range from PLN 300 to PLN 800 per page for certified legal translation. A standard 10-page judgment with attachments can cost PLN 5,000 to PLN 8,000 in translation fees alone.

One point creditors regularly miss: Brussels I bis applies only to civil and commercial matters. It does not cover revenue claims, customs matters, administrative decisions, or family law. If the underlying dispute involves any of these areas, the creditor must use a different legal route – either a bilateral treaty or Polish private international law (Kodeks postępowania cywilnego, Code of Civil Procedure, KPC).

  • Confirm the judgment falls within the civil and commercial scope of Brussels I bis
  • Obtain the standard certificate from the court of origin (Form I under the Regulation)
  • Commission a certified Polish translation of both the judgment and the certificate
  • Identify the correct Polish court with territorial jurisdiction over the debtor's assets
  • File the enforcement application with the competent bailiff

What is the step-by-step procedure and realistic timeline in Poland?

The procedure has four stages. Each has a distinct time risk. Understanding where delays accumulate allows the creditor to take protective measures before assets disappear.

Stage one: obtaining the certificate of enforceability from the court of origin. This is done before arriving in Poland. Most EU courts issue the certificate within 2 to 6 weeks. Some jurisdictions – notably those with overburdened civil registries – take up to 3 months. The creditor should request the certificate immediately after the judgment becomes enforceable, not after deciding to enforce in Poland.

Stage two: filing the enforcement application in Poland. The creditor (or Polish counsel) submits the application to the bailiff with territorial jurisdiction over the debtor's assets. The court fee for the enforcement clause is PLN 50. The bailiff's advance fee is typically PLN 300 to PLN 600 for the initial search. The bailiff is required to serve notice on the debtor and, within 14 days of service, the debtor may raise a challenge based on limited grounds – primarily public policy (ordre public) or proof that the judgment has already been satisfied.

Stage three: active enforcement. The bailiff proceeds to levy assets. Bank account seizure is typically completed within 2 to 4 weeks of the enforcement order. Real property enforcement takes significantly longer – between 6 and 18 months from levy to auction completion. Receivables enforcement (garnishment of amounts owed to the debtor by third parties) sits between these extremes, usually 4 to 8 weeks for liquid receivables.

Stage four: distribution and completion. The bailiff distributes recovered funds according to the statutory priority order. The creditor receives payment, minus the bailiff's statutory fee – typically 15% of the recovered amount, subject to a minimum of PLN 200 and a cap of PLN 50,000 per enforcement action.

We secured recovery of a commercial debt exceeding PLN 1.8m for a logistics client in the Mazowieckie region (autumn 2025) by combining immediate bank account seizure with a simultaneous garnishment of receivables – reducing total enforcement time to 11 weeks from application to payment.

How do the three most common business scenarios play out differently?

Brussels I bis is the same regulation for all three scenarios. The practical experience diverges sharply depending on the debtor's asset profile and the creditor's industry.

Manufacturing creditor with a Polish distributor. This is the most common cross-border enforcement scenario in Poland. The debtor typically holds inventory, receivables from sub-distributors, and a commercial bank account. The creditor's priority is speed – inventory depreciates and receivables can be collected by the debtor before enforcement reaches them. Immediate application for bank account seizure, combined with a garnishment notice to the debtor's known customers, is the standard approach. The creditor should also check whether the debtor holds any registered real property through KRS and the Land and Mortgage Register (Księga Wieczysta). If real property exists, the creditor should file a mortgage entry application simultaneously – this protects the creditor's priority position even if the property is not immediately sold.

IT services creditor with a Polish technology company. The debtor's main assets are often intellectual property rights, software licences, and receivables from clients. Tangible assets may be minimal. The enforcement strategy must focus on identifying and seizing receivables. This requires the bailiff to send garnishment notices to the debtor's clients – which requires knowing who those clients are. Polish commercial databases (KRS filings, court records) sometimes reveal the debtor's major commercial relationships. In one case, we identified four garnishable receivables for an IT sector client in Małopolska (spring 2026), recovering EUR 420,000 within 9 weeks of filing.

Foreign investor enforcing against a Polish subsidiary. This scenario involves a parent company or joint venture partner enforcing a judgment against a Polish entity. The complication is that the Polish subsidiary may be in financial difficulty. If insolvency proceedings are imminent, the creditor must act before the insolvency filing date – enforcement completed before the filing date is generally protected. Once insolvency proceedings are opened by the District Court, individual enforcement is stayed. The creditor then becomes a creditor in the insolvency procedure, with recovery dependent on asset realisation. For more detail on the insolvency timeline, see our guide on insolvency proceedings timeline from filing to closure.

What are the most costly mistakes creditors make in Polish enforcement proceedings?

The most expensive mistake is delay. Brussels I bis removed the exequatur barrier, but it did not remove the debtor's ability to dissipate assets. A debtor who learns a judgment has been obtained – even before formal enforcement notice is served – may transfer funds, restructure receivables, or encumber property. Every week between the judgment becoming enforceable and the enforcement application being filed is a window for asset dissipation. The consequence is not a procedural problem – it is a permanent loss of recovery.

The second mistake is incorrect jurisdictional filing. The enforcement application must be filed with the bailiff whose territorial district covers the debtor's assets. If the debtor has assets in multiple districts, the creditor may file with any competent bailiff. However, filing in the wrong district causes the application to be redirected, adding 2 to 4 weeks of delay. This matters most when bank account seizure is the priority enforcement measure.

The third mistake is inadequate translation. Polish courts require a certified translation by a sworn translator (tłumacz przysięgły) registered with the Polish Ministry of Justice. A translation by a general legal translator – even a native speaker – does not satisfy the requirement. Rejected translations require resubmission and add at least 3 weeks. Creditors who prepare translations in advance, using a registered sworn translator, avoid this entirely.

The fourth mistake is failing to monitor the debtor's insolvency risk. If the debtor files for insolvency after enforcement has begun but before the bailiff has completed the levy, the enforcement may be stayed. The creditor should monitor KRS filings and the National Debt Register (Krajowy Rejestr Długów) from the moment the judgment is obtained. For enforcement of Italian judgments specifically, the procedural interaction between Italian and Polish courts under Brussels I bis is addressed in our guide on enforcing an Italy judgment in Poland step by step.

A fifth error – less frequent but severe – is assuming that a Brussels I bis judgment cannot be challenged in Poland at all. The public policy defence remains available. Polish courts have refused enforcement on public policy grounds in cases involving default judgments issued without proper service on the Polish defendant. If the original proceedings had service irregularities, the debtor will raise this. The creditor should audit the service record before filing in Poland.

What to prepare before filing:

  • Certified copy of the judgment with the Brussels I bis certificate (Form I)
  • Sworn Polish translation by a registered tłumacz przysięgły
  • KRS extract confirming the debtor's current registered address and representatives
  • Asset search results: bank accounts, real property, known receivables

For creditors holding judgments from non-EU jurisdictions – such as UAE arbitral awards – the procedure differs significantly. Our guide on enforcing a UAE judgment in Poland step by step covers the recognition procedure under Polish private international law.

Each creditor's situation carries specific risks that compound over time. A debtor with liquid assets today may have none in 60 days. Delay forfeits recovery that the judgment itself already secured.

To discuss how Brussels I bis enforcement applies to your specific judgment and debtor profile, contact info@kordeckipartners.com. We will assess the debtor's asset position, identify the correct enforcement route, and manage the Polish proceedings from application to payment.

Frequently asked questions

Q: Can a debtor refuse enforcement of an EU judgment in Poland on substantive grounds?

A: The grounds for refusal are narrow under Brussels I bis. The debtor may apply to the Polish court to refuse or suspend enforcement, but only on specific grounds: the judgment has already been satisfied, it is irreconcilable with a Polish judgment between the same parties, or enforcement would manifestly violate Polish public policy. The Polish court cannot review the merits of the original dispute. The application for refusal must be made within 30 days of service of the enforcement notice, or 60 days if the debtor is domiciled outside Poland.

Q: How long does enforcement actually take, and what does it cost in total?

A: Timeline depends heavily on the asset type. Bank account seizure can produce payment within 4 to 6 weeks of filing. Real property enforcement typically takes 12 to 24 months. Total costs include the court enforcement clause fee (PLN 50), the bailiff's advance (PLN 300 to PLN 600), translation costs (PLN 5,000 to PLN 10,000 for a standard judgment), and the bailiff's statutory success fee (15% of recovered amount, capped at PLN 50,000 per action). Legal representation fees are additional and depend on the complexity of the enforcement and any challenges raised by the debtor.

Q: Does Brussels I bis apply to arbitral awards issued in EU countries?

A: No. Brussels I bis expressly excludes arbitration from its scope. An arbitral award – even one issued in an EU Member State – must be enforced in Poland under the New York Convention (1958), to which Poland is a party. The procedure requires a separate recognition application to the Polish Regional Court (Sąd Okręgowy). The grounds for refusal under the New York Convention are broader than those under Brussels I bis. For disputes involving arbitration Poland proceedings and enforcement, a distinct procedural strategy is required.

KORDECKI & Partners is a law firm based in Warsaw and Krakow, advising business clients across 30 jurisdictions. Our team combines expertise in Polish and international law with a practical approach to cross-border judgment enforcement, commercial litigation, and dispute resolution. We work with Polish entrepreneurs, foreign investors, and in-house legal teams on enforcement proceedings from application through to recovery. To discuss your situation, contact info@kordeckipartners.com.

Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. KORDECKI & Partners assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@kordeckipartners.com.