A Slovak manufacturing company had obtained a final judgment against its Polish distributor in Bratislava district court. The debt exceeded EUR 180,000. Back in Warsaw, the Polish debtor was still trading – assets were reachable. The question was not whether the judgment was valid. The question was how to turn a foreign court order into enforceable title under Polish law, and how quickly.

A judgment issued by a Slovak court is enforceable in Poland under Rozporządzenie Bruksela I bis (Brussels I bis Regulation, EU 1215/2012), which applies directly between EU member states. No separate recognition procedure is required. The creditor may apply directly to a Polish bailiff (komornik) for enforcement, provided the judgment carries the EU enforcement certificate issued by the Slovak court. The entire process – from filing to first enforcement action – typically takes between four and ten weeks.

This case study walks through the four stages our team managed: verifying the enforcement basis, preparing the Polish enforcement package, engaging the National Court Register (KRS) to locate debtor assets, and handling the debtor's opposition. Each stage produced lessons that apply to any creditor enforcing a Western or Central European judgment in Poland.

What was the background, and which instrument applied?

The Slovak creditor – a mid-size component supplier – had litigated for fourteen months before the Bratislava court issued a final payment order for EUR 182,400, including contractual interest. The Polish distributor had participated in the proceedings, so there was no service or due-process issue. That fact matters: Brussels I bis withholds enforcement only where the debtor had no proper notice of the original proceedings.

Our first task was confirming the instrument. Because both Slovakia and Poland are EU member states and the judgment postdated January 2015, Brussels I bis applied automatically. Under that regulation, a judgment bearing the standard EU enforcement certificate (Form I in the annex to the regulation) is treated as a domestic enforceable title in every other member state. No exequatur – no Polish court declaration of enforceability – is needed. This removed at least six weeks from the timeline compared to the older Brussels I framework.

One practical complication arose early. The Slovak court had issued the certificate in Slovak only. Polish enforcement rules require that documents in a foreign language be accompanied by a sworn translation into Polish. We commissioned a certified translation within five working days. Budget approximately PLN 800–1,200 per page of dense legal text – a minor cost against the claim value, but a step creditors frequently overlook.

  • Confirm the judgment is final and enforceable under Slovak law before any Polish filing
  • Obtain the EU enforcement certificate (Form I) from the issuing Slovak court
  • Commission a sworn Polish translation of all certificate pages
  • Verify that the debtor participated in the Slovak proceedings

How did we structure the Polish enforcement strategy?

With the translated certificate in hand, we filed directly with a Warsaw-district bailiff (komornik sądowy) chosen for territorial jurisdiction over the debtor's registered address. The application named four enforcement channels simultaneously: bank account seizure, seizure of receivables owed to the debtor by its own customers, a charge over commercial vehicles registered to the company, and a mortgage-style charge over a warehouse the KRS search had revealed. Filing all four channels at once is standard practice for experienced dispute lawyers; a single-channel application gives the debtor time to move assets between the first and second enforcement steps.

The bailiff issued enforcement notices to the debtor's main bank within three business days. The bank was required to freeze funds up to the claim amount within 24 hours of receiving the notice. That freeze produced an immediate result: EUR 61,000 equivalent in PLN was blocked before the debtor's management even knew enforcement had begun. Speed is the primary strategic variable in cross-border enforcement – not legal complexity.

We simultaneously requested a KIO appeal-style protective measure (zabezpieczenie) to prevent the debtor from disposing of the warehouse. Under Polish civil procedure, a court may grant interim asset protection within 24 hours on an ex parte basis where the creditor demonstrates a real risk of dissipation. The court granted the measure within two days. For a detailed analysis of how cost recovery interacts with enforcement steps, see our guide on cost recovery rules in Polish civil proceedings.

What obstacles did the debtor raise, and how were they resolved?

The Polish debtor filed a formal objection (zarzuty) within the statutory 14-day window, arguing two grounds. First, it claimed the Slovak judgment had not yet become final under Slovak procedural law. Second, it alleged the enforcement certificate contained a translation error that misrepresented the interest calculation. Neither argument succeeded, but each required a targeted response within strict deadlines.

On the finality point, we obtained a certificate of enforceability (potwierdzenie wykonalności) from the Bratislava court within eight days – faster than the debtor expected. The Polish enforcement court dismissed the objection on this ground within three weeks. On the translation error claim, we filed a corrected sworn translation and a comparative analysis showing the interest figure was identical in both language versions. The court found no material discrepancy. Both objections were dismissed within 35 days of filing.

A secondary complication involved the debtor invoking a pending Slovak appeal that it claimed suspended enforceability. Under Brussels I bis, a pending appeal in the state of origin does not automatically suspend enforcement in the enforcing state. The Polish court may, at most, stay enforcement pending the outcome of that appeal – but only if the creditor's position would be adequately protected. The court declined to grant a stay, noting the creditor had already provided a partial security deposit. This outcome aligns with how Polish courts have consistently applied the regulation in recent years.

We secured enforcement of EUR 182,400 plus accrued interest for the Slovak creditor, with full recovery achieved within four months of the initial filing. The matter was handled from our Warsaw office (winter 2025–2026). For cross-border employment matters involving Slovak nationals working in Poland – a related compliance area – see our briefing on posted workers from Slovakia to Poland and A1 certificates.

What lessons transfer to future cross-border enforcement?

Four transferable lessons emerge from this matter. Each addresses a recurring failure point we observe in cross-border enforcement files handled by creditors without local Polish counsel.

  • Obtain the EU enforcement certificate before leaving the originating jurisdiction. Creditors who arrive in Poland without it lose two to four weeks obtaining it retrospectively.
  • File all enforcement channels simultaneously. Sequential filing forfeits the element of surprise and risks asset dissipation within the 24-hour window between notices.
  • Budget for sworn translations from day one. A single-page EU certificate may run to four translated pages; factor PLN 3,000–5,000 into the enforcement cost estimate.
  • Monitor the Slovak proceedings for any appeal that could affect enforceability. A pending appeal does not block Polish enforcement, but it generates procedural skirmishes that consume time and fees.

The broader point is that Brussels I bis has made cross-border enforcement within the EU genuinely fast – faster than many creditors realise. The legal mechanism is not the bottleneck. Preparation and local execution are. A creditor who arrives in Poland with a complete, translated enforcement package and engages a Warsaw dispute lawyer on day one can realistically freeze debtor assets within one week of filing. That speed forecloses the debtor's primary defence: moving funds before the bailiff acts. For a full overview of our dispute resolution practice, including arbitration Poland mandates and sanctions compliance matters, visit our disputes practice page.

To discuss how this enforcement framework applies to your specific cross-border judgment, email info@kordeckipartners.com.

Frequently asked questions

Q: Does a Slovak judgment need to be recognised by a Polish court before enforcement?

A: No. Under the Brussels I bis Regulation, which applies between all EU member states, a Slovak judgment accompanied by the standard EU enforcement certificate is treated as an enforceable title in Poland without any separate recognition or exequatur procedure. The creditor applies directly to a Polish bailiff. The only pre-filing requirement is a sworn Polish translation of the certificate.

Q: How long does the entire enforcement process take, and what does it cost?

A: In straightforward cases with a complete enforcement package, the first asset freeze typically occurs within one to two weeks of filing. Full recovery depends on the debtor's asset position and any objections filed. In the matter described above, full recovery took four months. Enforcement costs include the bailiff's statutory fee (generally 10% of the amount recovered, capped at PLN 50,000 per proceeding), sworn translation fees, and legal counsel fees. These costs are recoverable from the debtor if enforcement succeeds.

Q: Can the debtor block enforcement by filing an appeal in Slovakia after the Polish proceedings have started?

A: A pending appeal in Slovakia does not automatically suspend enforcement in Poland. Under Brussels I bis, the Polish enforcement court may grant a stay only in exceptional circumstances – typically where enforcement would cause irreversible harm and the creditor's position is already secured. In practice, Polish courts rarely grant such stays where the creditor has already obtained partial recovery or provided security. The debtor's correct remedy is to pursue the appeal in Slovakia and then apply to the Polish court with the outcome.

About KORDECKI & Partners

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 dispute resolution and judgment enforcement. 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.