A London-based technology company obtained a favourable judgment from the High Court of Justice in England and Wales. The debtor – a Polish limited liability company – had assets in Poland but refused to pay voluntarily. The client needed to convert that English judgment into an enforceable title on Polish soil, and quickly.

Enforcing a United Kingdom judgment in Poland after Brexit requires a fresh legal strategy. The UK is no longer part of the European Union, so the Brussels I Recast Regulation no longer applies. Polish courts now assess recognition and enforcement under domestic private international law – primarily the Kodeks postępowania cywilnego (Code of Civil Procedure, KPC) – and the process typically takes between three and twelve months depending on court workload and debtor conduct.

This case study traces the steps we took for that London client: from initial assessment through recognition proceedings before the District Court in Warsaw to final enforcement by a Polish court bailiff. Each section draws a transferable lesson for creditors facing the same post-Brexit challenge.

What changed after Brexit for UK judgment creditors?

Before 31 December 2020, a UK money judgment could be recognised in Poland through the streamlined Brussels I Recast procedure. That route closed with the UK's departure from the EU. Today, no bilateral treaty between the UK and Poland governs mutual recognition of civil judgments. Polish courts therefore fall back on national law – specifically the KPC provisions on recognition of foreign judgments – to decide whether a UK judgment meets the threshold for enforcement.

The National Court Register (KRS) and the Polish bailiff system remain the end-points of enforcement. But to reach them, a creditor must first obtain a Polish court declaration that the foreign judgment satisfies several conditions. The judgment must be final and binding in the country of origin. It must not contradict Polish public policy. The debtor must have been properly served and had a genuine opportunity to defend. And the subject matter must not fall within the exclusive jurisdiction of Polish courts.

One practical consequence: the creditor must obtain a certified copy of the UK judgment and a certificate of finality from the issuing court. The High Court of Justice issues a separate certificate confirming the judgment is enforceable. Both documents require sworn translation into Polish before submission to Warsaw. Translation alone can take two to three weeks and costs between PLN 1,500 and PLN 4,000 depending on document length.

How did we structure the recognition strategy?

We filed the recognition application with the Regional Court (Sąd Okręgowy) in Warsaw, which has territorial jurisdiction over the debtor's registered seat. The application set out the four statutory conditions under Polish private international law and attached the certified judgment, the finality certificate, and sworn Polish translations. We also included a brief on UK procedural law to assist the court in verifying that the debtor had been properly served under English rules.

One early decision mattered enormously. We applied simultaneously for interim asset-freezing measures under the KPC, targeting the debtor's bank accounts. The Regional Court granted the freeze within 48 hours of filing – before the debtor could move funds abroad. We had identified two accounts through a KRS search and a query to the Polish Tax Administration (Krajowa Administracja Skarbowa, KAS). That protective step preserved approximately PLN 800,000 that would otherwise have been at risk.

We secured interim asset protection for a technology client in the Mazowieckie region (winter 2025), preventing dissipation of funds pending the recognition hearing. The debtor's attempt to challenge the freeze failed at the Regional Court level within three weeks.

  • File the recognition application with the Regional Court at the debtor's registered seat.
  • Attach a certified copy of the judgment plus a finality certificate from the issuing court.
  • Include sworn Polish translations of all foreign-language documents.
  • Apply for interim measures on the same day as the main application.
  • Prepare a brief on the foreign court's procedural rules to pre-empt objections.

What obstacles arose during proceedings – and how were they resolved?

The debtor raised a public policy objection. It argued that the English judgment had been obtained through a default procedure that allegedly denied it a fair hearing. This is the most common defence in post-Brexit recognition cases in Poland. The Regional Court must examine whether the foreign proceedings met a basic standard of due process – not whether the Polish court would have reached the same outcome on the merits.

We countered by producing the English service records, the court's file notes confirming the debtor had received notice, and an expert opinion on English civil procedure. The court dismissed the objection within six weeks. It confirmed that the English default judgment procedure is compatible with Polish public policy standards. The recognition order was issued four months after filing – within the faster end of the typical three-to-twelve-month range.

A second complication arose from a parallel insolvency risk. The debtor had filed preliminary restructuring documents with the KRS. For background on how cross-border insolvency between Poland and the UK interacts with enforcement, see our analysis at cross-border insolvency involving Poland and the United Kingdom. We monitored KRS filings daily and moved to enforcement immediately once the recognition order became final, before any insolvency moratorium could block us.

For creditors dealing with comparable Polish-debtor scenarios, our separate guide on enforcing a Polish judgment in Poland step by step explains the bailiff process in detail, including timelines and fee structures that apply once an enforceable title exists.

What are the transferable lessons for UK creditors?

Post-Brexit enforcement in Poland is achievable – but it demands early preparation and a realistic timeline. The absence of a bilateral treaty means the process is more document-intensive than the old Brussels I route. Three lessons stand out from this matter.

First, obtain the finality certificate from the English court before the debtor learns of your enforcement plans. Any delay gives the debtor time to restructure its Polish assets. Second, interim measures are available under Polish law even before the recognition order is final. Filing for a freeze on the same day as the main application is standard practice and costs a court fee of PLN 100. Third, the public policy objection is rarely fatal if the English proceedings were properly conducted. A concise expert brief on English procedural law neutralises most such challenges within weeks rather than months.

We obtained full enforcement of a judgment exceeding PLN 750,000 for a Pomerania-based distribution subsidiary of a UK group (spring 2026). The entire process from filing to bailiff collection took seven months – at the middle of the expected range.

For creditors considering comparable proceedings in neighbouring jurisdictions, our guide on enforcing a Slovak judgment in Poland step by step illustrates how EU-member-state judgments follow a different – and faster – track under Brussels I Recast, providing a useful benchmark.

What to prepare before filing:

  • Certified copy of the UK judgment with apostille or court seal.
  • Certificate of finality and enforceability from the issuing court.
  • Sworn Polish translations of all documents.
  • KRS extract confirming the debtor's current registered address in Poland.

If the debtor is a natural person rather than a company, a PESEL number search through the Polish Ministry of Digital Affairs (Ministerstwo Cyfryzacji) may be needed to establish jurisdiction.

Specific circumstances of your matter – the size of the claim, the debtor's asset profile, and any ongoing Polish proceedings – will determine whether interim measures are worth the additional cost and whether a recognition challenge is likely. Failing to act before a debtor enters restructuring forfeits your priority position and may render enforcement impossible without court approval.

To discuss how this procedure applies to your UK judgment, email info@kordeckipartners.com.

Frequently asked questions

Q: How long does recognition of a UK judgment in Poland take after Brexit?

A: The process typically takes between three and twelve months before the Regional Court. Straightforward cases with no debtor objection can conclude closer to three months. Cases involving public policy challenges or parallel insolvency proceedings may approach twelve months. Interim measures can be granted within 48 hours of filing, independently of the main timeline.

Q: Is there a cost threshold below which enforcement in Poland is not economically justified?

A: Court fees for recognition proceedings are modest – the filing fee is currently PLN 300 and the interim-measures fee PLN 100. Legal fees, translation costs, and bailiff charges typically total between PLN 15,000 and PLN 40,000 for a standard matter. For claims below PLN 100,000, creditors should weigh these costs carefully against the likelihood of recovery given the debtor's asset position.

Q: Does the public policy objection frequently succeed in Polish courts?

A: No. Polish courts apply the public policy reservation narrowly. It is not a mechanism for re-examining the merits of the foreign judgment. The objection succeeds only where the foreign proceedings involved a fundamental procedural violation – for example, no notice to the defendant at all. A properly conducted English default judgment procedure does not meet that threshold. A well-prepared expert brief on English civil procedure will address most objections at the first hearing.

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 sanctions compliance. 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.