This post was written by Meng Yu and Wenliang Zhang. The authors would like to thank Prof. Bill Dodge for his helpful comments on the draft.

I. Introduction

China’s post-judgment double interest (加倍迟延履行利息) has garnered attention in cross‑jurisdictional enforcement proceedings. There is nonetheless no fully uniform global approach to this interest component. Aligning with the positions of United States and Australian courts, English courts have on two occasions recognized and enforced PRC monetary judgments along with the interest accruing under Article 253 (now Article 264) of the PRC Civil Procedure Law—first in Hangzhou Jiudang Asset Management Co Ltd & Anor v Kei [2022] EWHC 3265 (Comm) and again in Qing Li & Ors v Fan Demetris Yuan & Anor [2026] EWHC 242 (Comm). Notably, courts in these jurisdictions rely on distinct legal doctrines to justify the enforcement of China’s post‑judgment double interest. A stark contrast emerges in Hong Kong, where courts have characterised this interest as penal in nature and thus ineligible for registration, as exemplified by the recent Hong Kong judgment [2026] HKCFI 5896. Read more