A Lithuanian company wins a court judgment against a Polish debtor. The debt is real. The Polish assets are there. But without a formal enforcement step in Poland, the judgment is worth nothing more than paper. Time matters here – Polish debtors sometimes move assets once they learn enforcement is coming.

A Lithuanian court judgment can be enforced in Poland directly under EU Regulation No 1215/2012 on jurisdiction and the recognition and enforcement of judgments in civil and commercial matters (Brussels I Recast). No separate declaration of enforceability is required for judgments issued after 10 January 2015. The creditor presents the judgment, a certificate issued by the Lithuanian court, and a translation to a Polish bailiff (komornik) – who then proceeds with enforcement. The entire process, from document submission to first enforcement action, typically takes four to eight weeks.

This alert explains who is affected, what documents are needed, and what deadlines apply. It covers the key procedural steps before a Polish bailiff and the limited grounds on which a Polish debtor can resist enforcement. Two practical scenarios illustrate where the process typically stalls.

Who is affected and what has changed?

Any creditor holding a civil or commercial judgment from a Lithuanian court is directly affected. Brussels I Recast applies to judgments in matters such as unpaid invoices, contractual damages, and loan recovery – provided both Lithuania and Poland are EU member states, which they are. Judgments in family law, insolvency, or arbitration fall outside this framework. The regulation removed the old exequatur procedure, which previously required a separate court order before enforcement could begin. That change – effective since January 2015 – significantly shortened the enforcement timeline.

The threshold question is not the amount of the debt. Brussels I Recast applies regardless of whether the claim is EUR 5,000 or EUR 5 million. What matters is the subject matter: the judgment must concern a civil or commercial obligation. A Lithuanian court ruling on a supply contract dispute qualifies. A Lithuanian administrative decision does not. Creditors who have been waiting for a Polish court to "approve" their Lithuanian judgment under the old system should note that this step is no longer required – attempting it wastes time and court fees.

We recovered enforcement of a judgment exceeding EUR 300,000 for a logistics client based in Vilnius, after their Polish debtor had transferred key assets to a related entity in the Mazowieckie region (autumn 2025). Acting quickly under Brussels I Recast, we secured interim measures within ten days of instruction.

What documents do you need to submit to a Polish bailiff?

The bailiff requires three core items. First, a certified copy of the Lithuanian judgment. Second, a certificate issued by the Lithuanian court under Brussels I Recast – this is a standard form (Form I) confirming the judgment is enforceable in Lithuania. Third, a certified Polish translation of both documents, prepared by a sworn translator registered with the Polish Ministry of Justice. Missing any one of these items causes the bailiff to return the application, adding weeks to the process.

  • Certified copy of the Lithuanian judgment
  • Brussels I Recast certificate (Form I) from the issuing Lithuanian court
  • Certified Polish translation of both documents
  • Bailiff's fee deposit (typically PLN 150 for initiation, with further fees tied to recovered amount)
  • Power of attorney if a Polish lawyer is acting on behalf of the creditor

The bailiff's jurisdiction depends on where the debtor's assets are located. For a debtor with a registered office in Warsaw, the creditor applies to a bailiff operating within the district court (sąd rejonowy) covering that address. Poland's National Court Register (Krajowy Rejestr Sądowy, KRS) allows creditors to verify the debtor's registered address before submitting. If assets are spread across regions, the creditor may engage multiple bailiffs simultaneously – a tactic worth considering when the debtor is known to hold property in more than one voivodeship.

For a related cross-border scenario involving Luxembourg judgments, see our guide on enforcing a Luxembourg judgment in Poland.

What can a Polish debtor do to resist enforcement – and does it work?

Under Brussels I Recast, the grounds for refusing recognition are narrow. A Polish court can refuse enforcement only if it would be manifestly contrary to Polish public policy, if the debtor was not properly served in the Lithuanian proceedings, or if the judgment conflicts with an earlier Polish or EU judgment on the same matter. These are genuine exceptions – not routine defences. Polish courts apply them strictly. A debtor who simply disagrees with the Lithuanian court's findings on the merits cannot reopen those findings in Poland.

The debtor must apply to the Polish court – specifically the district court (sąd rejonowy) at the debtor's domicile – to refuse or suspend enforcement. This application does not automatically suspend the bailiff's actions. The creditor can continue enforcement while the debtor's challenge is pending, unless the court grants an interim suspension. In practice, most debtor challenges fail within 30 to 60 days and do not stop asset recovery. The dispute lawyer handling the creditor's file should monitor the court register (Portal Informacyjny Sądów Powszechnych) for any such application immediately after submitting to the bailiff.

Sanctions compliance is a separate consideration. Where the debtor or its beneficial owners appear on EU or US sanctions lists, the creditor's counsel must assess whether receiving funds from enforcement would itself constitute a sanctions violation. This is not a hypothetical concern – it arises in practice, particularly for creditors with exposure to CIS counterparties.

We assisted a manufacturing client in Silesia (spring 2026) in defeating a debtor's public-policy challenge before the district court in Katowice. The challenge was dismissed within 45 days, and the bailiff completed asset seizure shortly after.

For background on how expert evidence affects contested enforcement proceedings, see our article on expert witnesses in Polish court proceedings.

If your company has a Lithuanian judgment and Polish assets are at risk of being moved, specific action within the next two weeks can protect your position. Waiting forfeits the advantage of surprise and may allow the debtor to restructure asset ownership before the bailiff acts.

To receive an expert assessment of your enforcement position, contact info@kordeckipartners.com. Our disputes team will review your Lithuanian judgment, identify the correct bailiff jurisdiction, and initiate enforcement proceedings on your behalf.

Frequently asked questions

Q: Does a Lithuanian arbitration award follow the same procedure as a court judgment?

A: No. Arbitration Poland enforcement follows a different path. A Lithuanian arbitration award is enforced under the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (1958), not Brussels I Recast. The creditor must apply to a Polish court for a declaration of enforceability before approaching the bailiff. This adds a court stage that typically takes two to four months. Brussels I Recast applies only to state court judgments.

Q: How long does the full enforcement process take from document submission to payment?

A: For straightforward cases – a solvent debtor with identifiable bank accounts or real estate in Poland – the process from bailiff submission to first payment typically takes six to twelve weeks. Cases involving asset tracing, debtor challenges, or multiple enforcement actions across regions take longer. The Lithuanian judgment itself does not expire in Poland, but acting promptly reduces the risk of asset dissipation.

Q: Can a KIO appeal or public procurement dispute affect enforcement of a Lithuanian judgment?

A: A KIO appeal (before the National Appeals Chamber, Krajowa Izba Odwoławcza) is a public procurement remedy and has no bearing on civil enforcement of a Lithuanian judgment. The two procedures are entirely separate. If the Polish debtor is a public entity and the underlying claim relates to a public contract, the creditor should also consider whether the debtor holds receivables from the Polish state – those can themselves be subject to enforcement by the bailiff.

For creditors with Lithuanian operations and Polish tenants or counterparties, our guide on office lease review for Lithuania tenants addresses related cross-border contractual issues.

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, litigation Warsaw, and commercial disputes. 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.