A Cypriot company obtains a judgment against a Polish debtor. The amount is substantial – over EUR 500,000. The debtor's assets are in Poland. The question is not whether to enforce, but how quickly the creditor can act before those assets disappear.

Cyprus is an EU member state. This means a judgment from a Cypriot court is enforceable in Poland under EU Regulation No 1215/2012 on jurisdiction and the recognition of judgments in civil and commercial matters (Brussels I Recast). Under that framework, no separate declaration of enforceability is required. The creditor may apply directly to a Polish enforcement court with the Cypriot judgment and a standard certificate issued by the Cypriot court. Enforcement proceedings in Poland typically take between three and nine months from the date of application.

This alert sets out the three stages every creditor must complete: obtaining the EU certificate in Cyprus, filing with the correct Polish court, and managing the enforcement process through a Polish bailiff (komornik sądowy). Each stage carries its own deadlines and risks. Missing a step does not merely delay enforcement – it can give the debtor time to dissipate assets or trigger insolvency proceedings that preclude individual enforcement altogether.

What legal framework applies when enforcing a Cyprus judgment in Poland?

Brussels I Recast governs this process directly. It applies to civil and commercial matters between parties in EU member states. The Regulation abolished the old exequatur procedure – the requirement to obtain a Polish court declaration before enforcement could begin. That change, effective since January 2015, is the single most important procedural fact for any creditor holding a Cypriot judgment today.

The creditor must obtain a certificate under Annex I of Brussels I Recast from the Cypriot court that issued the judgment. This document – sometimes called the Article 53 certificate – confirms the judgment's authenticity and enforceability in Cyprus. The Cypriot court issues it on application, usually within 14 to 21 days. No hearing is required in Cyprus at this stage. The certificate must be accompanied by a certified translation into Polish before submission to the Polish court.

Two Polish institutions are central to the process. The National Court Register (Krajowy Rejestr Sądowy, KRS) holds data on the debtor's registered seat, which determines which district court (sąd rejonowy) or regional court (sąd okręgowy) has jurisdiction. The Polish Financial Supervision Authority (Komisja Nadzoru Finansowego, KNF) is relevant only if the debtor operates in a regulated sector. For most commercial enforcement matters, the relevant institution is the competent enforcement court and the bailiff attached to it.

Sanctions compliance is a separate layer. Where the Cypriot judgment relates to a transaction involving a sanctioned counterparty or sanctioned assets, Polish enforcement may be blocked regardless of the Brussels I Recast certificate. A sanctions compliance check should be completed before filing – not after. Failure to do so can expose the creditor to regulatory liability in both jurisdictions.

How does the Polish enforcement procedure work in practice?

Once the Article 53 certificate and certified Polish translation are ready, the creditor files an enforcement application (wniosek o wszczęcie egzekucji) directly with a Polish bailiff. No prior court order is needed under Brussels I Recast – the Cypriot judgment with its certificate constitutes an enforceable title in Poland. The bailiff is selected by the creditor from a list maintained by the district court in the debtor's jurisdiction. This choice matters: bailiff workloads vary significantly across Polish regions.

We secured recovery exceeding EUR 300,000 for a Cypriot creditor pursuing assets held by a debtor registered in the Mazowieckie region (autumn 2025). The key was filing simultaneously with the bailiff and requesting an interim asset freeze from the enforcement court within the first 48 hours of proceedings.

The bailiff has authority to seize bank accounts, movable property, and receivables owed to the debtor. For real estate, enforcement requires a separate application to the land and mortgage register court (sąd wieczystoksięgowy). This is a parallel track – it does not pause the main enforcement. Real estate enforcement in Poland takes a minimum of 12 months from the date of the court auction order. Creditors with claims above PLN 75,000 should consider whether initiating both tracks simultaneously is cost-effective given the debtor's asset profile.

The debtor may oppose enforcement by filing a complaint (skarga na czynności komornika) or, in limited circumstances, applying to the Polish court to refuse recognition under Brussels I Recast. Grounds for refusal are narrow: manifest conflict with Polish public policy (ordre public), irreconcilable judgments, or procedural irregularities in the original Cypriot proceedings. A dispute lawyer experienced in cross-border enforcement should assess the likelihood of such challenges before the creditor commits to the enforcement strategy.

For creditors also dealing with KSeF compliance obligations or other Polish regulatory requirements, the timeline of enforcement proceedings should be factored into cash-flow planning. See our KSeF deadline timeline for companies in Cyprus for related planning considerations.

What immediate steps should a creditor take?

Speed is the defining variable in cross-border enforcement. Assets can be transferred, encumbered, or consumed within weeks of a judgment becoming final. The following checklist covers the actions that matter most in the first 30 days after the Cypriot judgment becomes enforceable.

  • Apply to the Cypriot court for the Article 53 certificate within five business days of the judgment becoming final.
  • Commission a certified Polish translation of the judgment and certificate – allow seven to ten business days for a sworn translator.
  • Conduct a KRS search and asset investigation to identify the debtor's registered seat, bank accounts, and real property holdings in Poland.
  • Complete a sanctions compliance review before filing any enforcement documents.
  • File the enforcement application with the selected Polish bailiff and request an interim asset freeze simultaneously.

Our team obtained interim protective measures over assets exceeding PLN 2m for a creditor pursuing a debtor in the Silesia region (spring 2026). The interim freeze was granted within 72 hours of the application. That window – before the debtor could respond – was decisive.

Creditors enforcing judgments from other jurisdictions should note that the process differs materially where the judgment originates outside the EU. For a comparison with non-EU enforcement routes, see our guide on enforcing a Ukraine judgment in Poland. For a full overview of the dispute resolution services available in Poland, visit our disputes practice page. Arbitration Poland proceedings may also be relevant where the underlying contract contains an arbitration clause that was not invoked before the Cypriot litigation commenced.

A KIO appeal – relevant where the debtor is a public entity and the underlying contract arose from a public procurement procedure – follows a separate statutory track entirely. That route is governed by Polish public procurement law, not Brussels I Recast, and requires specialist input from the outset.

Specific situations require tailored assessment. A creditor holding a judgment above EUR 500,000 against a debtor with mixed asset types – real estate, receivables, and shares in a Polish subsidiary – faces a materially different enforcement map than a creditor with a single liquid claim. Choosing the wrong enforcement sequence can forfeit priority over assets that another creditor secures first.

To receive an expert assessment of your enforcement position in Poland, contact info@kordeckipartners.com.

Frequently asked questions

Q: Do I need a Polish court order before instructing a bailiff to enforce a Cyprus judgment?

A: No. Under Brussels I Recast, a Cypriot judgment accompanied by the Article 53 certificate issued by the Cypriot court constitutes a directly enforceable title in Poland. You apply to the bailiff directly, without a prior Polish court declaration. The certificate must be accompanied by a certified Polish translation.

Q: How long does enforcement typically take, and what does it cost?

A: Enforcement of liquid claims – bank account seizures – can produce results within four to eight weeks of filing. Real estate enforcement takes a minimum of 12 months. Bailiff fees in Poland are set by statute and are calculated as a percentage of the recovered amount, subject to a cap. Court fees for interim measures are typically PLN 100 to PLN 300 per application. Translation and legal costs are additional and depend on document volume.

Q: Can the Polish debtor block enforcement by challenging the Cyprus judgment?

A: Grounds for refusal under Brussels I Recast are narrow and rarely succeed. The debtor must demonstrate a manifest conflict with Polish public policy, an irreconcilable Polish judgment, or a fundamental procedural defect in the Cypriot proceedings. A mere disagreement with the outcome does not qualify. Polish courts apply these grounds restrictively, consistent with the Regulation's objective of free movement of judgments within the EU.

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 enforcement, commercial litigation, and arbitration. We work with Polish entrepreneurs, foreign investors, and in-house legal teams. 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.