Enforcing a Netherlands judgment in Poland – step by step

A Dutch logistics company obtained a money judgment against its Polish distribution partner in the District Court of Amsterdam. The amount exceeded EUR 850,000. The Dutch creditor held an enforceable title – yet the debt remained unpaid. The Polish debtor had assets in Poland: a warehouse in the Mazowieckie region and receivables from domestic clients. The question was not whether the judgment was valid. The question was how to convert it into a Polish enforcement order before the debtor moved those assets.

A Netherlands court judgment is enforceable in Poland directly under Regulation (EU) 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. The creditor presents the judgment, together with a certificate issued by the originating court, to a Polish bailiff (komornik) and may proceed to enforcement immediately. The entire process – from filing to first enforcement action – can be completed within 30 to 60 days if the documents are in order.

This case study traces the steps taken in an anonymised matter. It covers the procedural framework, the strategy chosen, the obstacles encountered, and the lessons that apply to any creditor enforcing a Dutch judgment in Poland. Readers familiar with the parallel French enforcement route will find useful points of comparison in our guide on enforcing a French judgment in Poland.

What legal framework governs enforcement of Netherlands judgments in Poland?

Both the Netherlands and Poland are EU Member States. Brussels I Recast – in force since January 2015 – abolished the exequatur procedure for judgments in civil and commercial matters. A judgment creditor no longer needs a Polish court to declare the foreign judgment enforceable before approaching a bailiff. This is the single most important procedural fact for any Dutch creditor holding a money judgment against a Polish debtor.

The creditor must obtain a certificate from the originating Dutch court confirming that the judgment is enforceable in the Netherlands. That certificate, issued on the standard Annex I form, travels with a certified copy of the judgment. Polish law then requires a sworn translation into Polish of both documents. The translation cost typically ranges from PLN 400 to PLN 800 per page, depending on the translator and document complexity.

One practical boundary matters here. Brussels I Recast covers civil and commercial matters. It does not cover insolvency, arbitration, or family law. If the Dutch judgment arises from insolvency proceedings, a different framework applies – see our separate analysis of cross-border insolvency involving Poland and the Netherlands. In this case, the judgment was a straightforward commercial debt claim. The regulation applied without qualification.

The National Court Register (Krajowy Rejestr Sądowy, KRS) confirmed the debtor's registered address and legal status. That search took one day and cost PLN 0 – the KRS is publicly accessible online. Knowing the debtor's KRS data is essential before selecting the competent bailiff district.

How did the enforcement strategy address the debtor's asset structure?

Strategy precedes filing. The debtor operated a warehouse in the Mazowieckie region and maintained trade receivables from three Polish retail clients. Both asset categories were visible from public sources and standard due diligence. The creditor's priority was speed: a debtor aware of incoming enforcement may transfer assets or encumber them within days.

We secured interim protective measures – a freezing order over the debtor's bank accounts – before the formal enforcement file was opened. Under Polish civil procedure, a creditor holding an enforceable foreign title may apply to the district court (sąd rejonowy) for a zabezpieczenie (interim measure) on an ex parte basis. The court issued the order within 7 days. The order covered accounts at two banks identified through the debtor's KRS filings and publicly available VAT records.

We obtained interim measures protecting assets worth over EUR 850,000 for a Dutch creditor's claim against a Polish distribution company in the Mazowieckie region (winter 2026). The freezing order was served on both banks before the debtor received any notification. That sequencing – freeze first, notify second – proved decisive. By the time the debtor's counsel responded, the accounts were already blocked.

Simultaneously, we filed the enforcement application with a Warsaw-area bailiff. The bailiff's fee for enforcement of a money judgment is calculated as a percentage of the recovered amount, capped under Polish enforcement law. For a claim of this size, the advance fee payable by the creditor was approximately PLN 8,000 – recoverable from the debtor upon successful enforcement. The bailiff opened the file within 5 working days of receiving the complete document set.

What obstacles arose during the enforcement process?

Three obstacles emerged. Each is common in cross-border enforcement matters of this complexity. Understanding them in advance shortens the timeline significantly.

First, the debtor challenged the enforceability of the judgment before the Regional Court (Sąd Okręgowy) in Warsaw. Under Brussels I Recast, a debtor may apply to refuse enforcement on limited grounds: manifest breach of public policy, irreconcilable judgments, or procedural defects in service of process in the original proceedings. The debtor argued that service of the Dutch proceedings had been defective. The Regional Court examined the Dutch court file – obtained via the European Judicial Network – and dismissed the challenge within 6 weeks. The public policy exception is narrow. Polish courts apply it sparingly.

Second, the debtor's warehouse turned out to carry a prior mortgage registered in the Polish Land and Mortgage Register (Księga Wieczysta). That mortgage, held by a Polish bank, ranked ahead of the creditor's claim in any forced sale. Enforcement against the warehouse was therefore deprioritised. The receivables and bank accounts became the primary enforcement targets.

Third, one of the debtor's trade debtors disputed the underlying receivable. That sub-dispute required a separate legal assessment. We advised the creditor to proceed against the uncontested receivables and the bank accounts while the disputed receivable was parked. The creditor recovered EUR 620,000 within 4 months of the interim order. The balance remained under enforcement against the warehouse.

What lessons does this matter offer for future Netherlands-Poland enforcement?

Four transferable lessons emerge from this case. They apply to any creditor holding a Dutch commercial judgment against a Polish debtor.

• Obtain the Annex I certificate immediately after the Dutch judgment becomes enforceable – delays of even 2 weeks create room for asset movement.
• Commission sworn Polish translations before filing; incomplete document sets stall bailiff proceedings by 10 to 20 working days.
• Run a KRS and Land Register search before choosing the enforcement strategy – asset structure determines whether interim measures or direct enforcement is faster.
• Treat the public policy challenge as a predictable delay, not a genuine threat – prepare a procedural rebuttal in advance.

Sanctions compliance deserves a separate note. Where the Dutch judgment debtor is a company with cross-border ownership, counsel must screen the debtor and its beneficial owners against EU and Polish sanctions lists before accepting enforcement instructions. Enforcing a judgment in favour of a sanctioned entity – or against one in a way that releases frozen assets – carries serious regulatory risk. Our analysis of sanctions screening obligations for Polish companies sets out the applicable thresholds and the role of the Polish Financial Supervision Authority (Komisja Nadzoru Finansowego, KNF) in oversight.

A second micro-case reinforces the lesson on timing. We assisted a German investor in recovering a judgment debt of over PLN 3.2m from a Polish IT subcontractor in the Silesia region (spring 2025). The creditor had waited 11 weeks after the German judgment became final before instructing Polish counsel. During that window, the debtor transferred its main receivable to a related entity. Interim measures were eventually granted, but the recovery timeline extended by 5 months compared to cases where freezing applications are filed within 2 weeks of the foreign judgment becoming enforceable.

The lesson is structural. Brussels I Recast removed the legal barrier to enforcement. It did not remove the commercial risk of delay. Speed of instruction to local counsel is the variable that most directly determines recovery outcome – more so than the size of the claim or the strength of the underlying judgment.

For a tailored enforcement strategy covering your specific asset recovery situation in Poland, contact info@kordeckipartners.com. Our disputes team will assess the debtor's asset position, prepare the document set, and file for interim measures within the shortest practicable timeframe.

Frequently asked questions

Q: Does a Netherlands judgment need to be approved by a Polish court before a bailiff can act?

A: No. Under Brussels I Recast, which applies between all EU Member States, the exequatur procedure was abolished for civil and commercial judgments. A creditor presents the judgment and the Annex I certificate directly to a Polish bailiff. No prior court approval is needed. The bailiff opens the enforcement file once the documents – including sworn Polish translations – are complete.

Q: How long does enforcement of a Dutch judgment in Poland typically take?

A: Timeline depends on asset type and debtor cooperation. Bank account enforcement following an interim freezing order can produce recovery within 30 to 90 days. Real property enforcement through forced sale takes significantly longer – commonly 12 to 24 months. Receivables enforcement falls between those ranges. Instructing Polish counsel immediately after the Dutch judgment becomes enforceable is the single most effective way to shorten the timeline.

Q: Can a Polish debtor successfully block enforcement of a Dutch judgment on public policy grounds?

A: Rarely. Polish courts interpret the public policy exception narrowly and consistently with EU case law. The exception applies only where enforcement would manifestly violate a fundamental principle of Polish legal order – not merely because the outcome differs from what a Polish court might have decided. Procedural challenges based on defective service are more common, but courts require concrete evidence of a breach that actually prejudiced the debtor's right of defence. A well-documented Dutch judgment file leaves little room for a successful challenge.

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, interim measures, and commercial dispute resolution. 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.