The HCCH 2019 Judgments Convention enters into force for the United Kingdom

Today the HCCH 2019 Judgments Convention entered into force for the United Kingdom. The UK signed this Convention on 12 January 2024 and filed its instrument of ratification on 27 June 2024.

On 26 March 2025, the UK extended the 2019 Judgments Convention to Scotland and Northern Ireland. Initially, the UK had extended this Convention to England and Wales only. These declarations will take effect on the day the Convention enters into force for the UK in accordance with Articles 25 & 30(3)(4) of the said Convention. For more information, click here.

In particular, the time gap between the declarations requires some clarification. The first declaration with regard to England and Wales takes effect simultaneously with the entry into force of the Convention for the UK (Art. 30(3) of the 2019 Judgments Convention) i.e. 1 July 2025. The second declaration with regard to Scotland and Northern Ireland takes effect “on the first day of the month following the expiration of three months following the date on which the notification is received by the depositary” i.e. 1 July 2025. In the latter case, Article 30(4) of the 2019 Judgments Convention applies and not Article 28(2)(b) of this Convention – which targets territorial units -, because the declaration was made before the Convention entered into force for the UK; nevertheless, the wording of both articles is very similar, with one difference regarding the starting date –  at receipt or after notification is made -, which may in some cases have practical consequences for the counting.

Article 29 of the 2019 Judgments Convention permits States to file a declaration stating that the Convention shall not have the effect of establishing relations between the filing State and another Contracting Party. To date, no State has filed such a declaration. Accordingly, the 2019 Convention will apply between the UK and the 32 Contracting Parties to the Convention (incl. the European Union).