Recognition of foreign judgments

Outside the European Union and in the absence of a treaty, the French court checks three conditions: the dispute has a genuine connection with the foreign court's country, the decision complies with international public policy, in substance and procedure, and it was not obtained by fraud. The French court does not retry the case.

Generally, no. In civil and commercial matters, the Brussels I bis Regulation abolished exequatur for judgments given in proceedings instituted since 10 January 2015: the judgment is enforceable in France on production of a copy and a certificate issued by the court of origin. Similar rules exist in family matters. The losing party may, however, apply for refusal of enforcement in limited cases.

Official source: EUR-Lex

An apostille is a formality provided for by the Hague Convention of 5 October 1961, which replaces legalisation for public documents circulating between States party to it: it certifies the origin of the document (signature, capacity of the signatory, seal). It is not required between countries exempted by an agreement; within the European Union, a regulation exempts many public documents, such as birth or marriage certificates, from legalisation and apostille.