Enforcing a UK judgment in Spain: which route applies, what it takes and when it pays

A judgment from a court in England and Wales, Scotland or Northern Ireland can be enforced against assets in Spain by two routes, and the date the claim was issued in the UK decides which one applies. Claims issued on or after 1 July 2025 fall under the 2019 Hague Judgments Convention. Claims issued before that date go through Spanish national law, which sets stricter conditions. The date of the judgment itself does not matter: a judgment given in 2026 on a claim issued in 2024 still takes the older route.

Either way, the creditor needs an order from a Spanish court before touching any asset in Spain, and the work starts well before that order. It starts with checking what the debtor owns in Spain, gathering the right documents in the UK and spotting the issues on which Spanish courts refuse recognition. A Barcelona court refused to recognise an English High Court judgment in February 2026, and the reason applies to claims of any size.

Can a UK judgment be enforced in Spain?

Yes, once a Spanish court has granted exequatur. Exequatur is the Spanish procedure that recognises a judgment from outside the EU and authorises its enforcement in Spain. It is needed under every route open to a UK judgment, because none of them allows the judgment to be enforced directly. Three questions decide which conditions the Spanish court applies:

• Was the UK claim issued on or after 1 July 2025? Then the 2019 Hague Judgments Convention applies to most civil and commercial judgments, including county court judgments and High Court money judgments.
• Did the contract give the UK courts exclusive jurisdiction? Then the 2005 Hague Choice of Court Convention may apply, although the EU and the UK disagree about its start date.
• Neither? Then the judgment goes through Ley 29/2015 (the Spanish statute on international judicial cooperation, which governs judgments from countries without an applicable treaty).

The 2019 Convention covers the whole of the UK from 1 July 2025: England and Wales, Scotland and Northern Ireland, according to the UK's declarations recorded in the HCCH status table. The Convention was extended to Gibraltar from April 2026. The Crown Dependencies are not covered, so judgments from Jersey, Guernsey and the Isle of Man depend on Spanish national law. The broader European picture is set out in our analysis of the Brussels Ia review and how judgments circulate after Brexit. The Spanish side of the process described below applies in much the same way to judgments from other countries outside the EU.

Before starting: is there anything to collect in Spain?

Exequatur and enforcement are two sets of court proceedings, and both cost money. Before committing to them, three checks show whether a judgment is worth taking to Spain.

The first is the debtor's assets. Spanish land registries are open to anyone with a known interest in the property records, and a judgment creditor has one; a simple registry note (nota simple) shows who owns a property and what charges it carries (Article 221 of the Ley Hipotecaria, the Spanish mortgage and land registry act). The commercial registry is public, so a debtor company's details, directors and filed accounts can be obtained without any court involvement. The public insolvency register shows whether the debtor is already in insolvency proceedings in Spain, in which case the claim has to be handled within those proceedings.

The second is whether the debtor has already started proceedings against the creditor in Spain on the same dispute. That was the issue in the Barcelona case discussed below, and it can block recognition outright.

The third is the arithmetic. Small county court judgments can cost almost as much to enforce in Spain as they are worth. The Scales, a two-minute calculator, weighs the amount at stake against the likely cost of a lawyer in Spain. Creditors who do not yet hold a judgment can often sue the debtor directly in Spain, as explained in our guide to recovering an unpaid invoice from a Spanish company.

What to prepare in the UK

The documents are the part of the process most within the creditor's control. The following set covers both routes:

• A sealed copy of the judgment from the court that gave it. For the Hague conventions, UK law allows the court to issue a copy together with a certificate giving particulars of the judgment and the proceedings (section 12 of the Civil Jurisdiction and Judgments Act 1982), and the 2019 Convention provides a recommended form for that purpose.
• An apostille on the copy, issued by the FCDO Legalisation Office. Court documents qualify if they carry a wet ink court seal; an e-Apostille is available for PDFs signed electronically by a UK notary or solicitor, and it is worth confirming in advance that the Spanish court will accept it.
• Proof of service of the claim, if the judgment was given in default. Both routes allow refusal where the claim was not properly served, so this document carries particular weight.
• Evidence that the judgment is final and enforceable in the UK. For the national route, Spanish law accepts that finality appears from the judgment itself or follows from the UK rules on appeal (Article 54 of Ley 29/2015).
• A power of attorney for the Spanish procurador (the court agent who formally represents a party before Spanish courts), signed before a UK notary and apostilled.

Every document must then be translated into Spanish. Spanish procedure allows a private translation, but the other side can challenge it within five days and force an official one (Article 144 of the Ley de Enjuiciamiento Civil, the Spanish code of civil procedure). A sworn translation from the start closes that avenue for delay.

How the Spanish proceedings run

The application. It is filed with the civil section of the Tribunal de Instancia (the first-instance court of each judicial district) where the debtor is domiciled, or with the commercial section for matters within its remit. Where the debtor has no domicile in Spain, the place of enforcement decides. A Spanish lawyer and a procurador are compulsory, whatever the amount (Articles 52 and 54 of Ley 29/2015). The application can ask for exequatur and enforcement together, and it can include protective measures, such as freezing assets, while the court decides.

Opposition. The debtor has thirty days to oppose. The public prosecutor takes part in every exequatur case. The court then has ten days to rule.

Appeal. Either side can appeal to the Audiencia Provincial (the provincial court of appeal). If exequatur was granted, the court can suspend enforcement while the appeal is heard or make it conditional on security (Article 55).

Enforcement. Once exequatur is granted, the UK judgment is enforced like a Spanish one. The court can order the debtor to declare its assets under threat of sanctions, and, where the creditor cannot identify enough of them, the court will ask banks, public bodies and registries what the debtor holds. Seizure follows a statutory order that starts with cash and bank accounts and moves through receivables, income and shares to real estate. A seizure of property is entered in the land registry, which protects the creditor against later sales or charges (Articles 589, 590, 592 and 629 of the Ley de Enjuiciamiento Civil).

Currency. A judgment in pounds sterling is enforced in pounds. For the purpose of seizing assets, the sum is converted at the official exchange rate on the day enforcement is ordered, while court costs and interest accruing in the Spanish proceedings are paid in euros (Article 577).

Where a UK judgment can be refused

A Spanish court never reopens the merits of the UK judgment under either route. What it checks depends on the route.

Under the 2019 Convention, the judgment must rest on one of the jurisdictional links the Convention accepts. The ones that matter most in debt cases are these: the debtor lived in the UK, or had its business or a branch there, when it became a party to the proceedings; the debtor accepted the UK court's jurisdiction or defended on the merits without contesting it; the contract was to be performed in the UK; or the contract named the UK courts in a non-exclusive clause. Consumers and employees are protected: the performance link, the non-exclusive clause and defending without objecting cannot be used against them, and their consent counts only if it was given to the court itself. In practice, a county court judgment against someone who lived in the UK when the claim was issued and later moved to Spain usually qualifies. A default judgment against a consumer who already lived in Spain often does not, and then falls back on national law.

Once a link exists, recognition can only be refused on the grounds the Convention lists: the claim was not served in time and in a way that allowed a defence; the judgment was obtained by fraud; recognition would be manifestly contrary to Spanish public policy; the proceedings breached an agreement to litigate elsewhere; or the judgment conflicts with another judgment between the same parties.

Under Ley 29/2015, the judgment must be final, with no appeal still available in the UK. The court refuses recognition if the judgment is contrary to Spanish public policy, if it was given in manifest breach of the right of defence, if the matter belonged exclusively to the Spanish courts or the UK court had no reasonable connection with the dispute, if it conflicts with a Spanish judgment or with an earlier foreign one, or if proceedings between the same parties on the same subject were already pending in Spain when the UK claim began (Article 46). For a default judgment, the claim must have been served regularly and with enough time to prepare a defence. Regular service carries more weight here than under the Convention.

An exclusive choice of court clause brings in the 2005 Hague Convention, which has its own short list of grounds for refusal. The UK treats it as applying to clauses agreed since 1 October 2015; the EU's position limits it to clauses agreed on or after 1 January 2021. For clauses agreed before 2021, it is prudent to prepare the application on the basis of national law.

The Barcelona refusal

On 12 February 2026, Civil Section No. 27 of the Tribunal de Instancia de Barcelona refused to recognise the December 2024 judgment of the Commercial Court in London in Banco de Sabadell v Cerberus, worth hundreds of millions of euros to the bank. The English claim had been issued in 2023, so the application ran under Ley 29/2015. The order has not been published in the CENDOJ, the official database of Spanish case law. A commentary published by Law360 in April 2026 links the refusal to litigation between the parties that was already pending in Spain, without identifying the provision applied; Ley 29/2015 lists that situation among its grounds for refusal. The point holds for any creditor: a strong UK judgment can stall in Spain if the debtor got to a Spanish court first. Under the 2019 Convention the same situation leads to refusal only where the dispute is closely connected with Spain, and a refusal does not prevent a fresh application later.

Deadlines that can sink a sound judgment

Spanish law gives a creditor five years to bring enforcement proceedings from the date the judgment becomes final (Article 518 of the Ley de Enjuiciamiento Civil), and Ley 29/2015 applies that limit to foreign judgments. It does not say when the five years start for them, and the published commentary reads it as applying both to the exequatur application and, again, to enforcement after exequatur. The prudent course counts five years from the date the UK judgment became final.

A pending appeal in the UK has a different effect under each route. Under national law, a judgment still open to appeal cannot be recognised at all. Under the 2019 Convention, the Spanish court may postpone or refuse recognition while an appeal is pending or the time to appeal has not expired, and a refusal on that ground does not prevent a new application once the appeal is resolved.

Where to start

The issue date of the UK claim decides the route, and the route decides what the Spanish court will check. Service of the claim, finality in the UK and earlier proceedings in Spain are the three points that can defeat an otherwise sound judgment, and each can be checked before any money is spent in Spain. PASSAS handles exequatur and enforcement of foreign judgments in a single engagement, from the document check to the seizure of assets; where the debt has not yet reached judgment, Debt Recovery in Spain starts the claim directly in Spain.

Frequently asked questions

How do I enforce a UK judgment in Spain?

A Spanish court must first grant exequatur, which recognises the judgment and authorises enforcement. For claims issued in the UK on or after 1 July 2025, the conditions come from the 2019 Hague Judgments Convention; for earlier claims, from Spanish national law. Once exequatur is granted, the judgment is enforced like a Spanish one, through bank account freezes and seizures of property.

Can a county court judgment be enforced in Spain?

Yes. A county court judgment can be recognised in Spain on the same terms as a High Court judgment. The two points to watch are how the claim was served, particularly where the judgment was given in default against someone living in Spain, and whether the amount justifies the cost of two sets of Spanish proceedings.

Does the Hague Convention 2019 apply between the UK and Spain?

Yes, since 1 July 2025, through the EU's accession to the Convention. It applies only to judgments in proceedings issued in the UK on or after that date, in civil and commercial matters outside its exclusions, such as family law, insolvency, defamation and intellectual property.

What is exequatur in Spain?

It is the court procedure that recognises a judgment from outside the EU and authorises its enforcement in Spain. It is heard by the civil section of the Tribunal de Instancia, requires a Spanish lawyer and a procurador, and gives the debtor thirty days to oppose.

How long does a UK judgment remain enforceable in Spain?

Spanish law allows five years to bring enforcement from the date a judgment becomes final, and applies that limit to foreign judgments without saying when the period starts. The safe assumption is five years from the date the UK judgment became final.