Specific features of enforcing foreign court judgments in Ukraine

The legal basis for recognising and enforcing foreign court judgments in Ukraine is set out in Article 81 of the Law of Ukraine “On Private International Law”, as well as in relevant Convention of 02 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters. The procedural framework is regulated by Section IX of the Civil Procedure Code of Ukraine (the “CPC of Ukraine”), which sets forth the principles, conditions, and requirements for the recognition and enforcement of foreign court judgments in Ukraine in accordance with international standards.

Below, we outline the key stages required to successfully complete the recognition and enforcement procedure in Ukraine and highlight the common mistakes most frequently encountered by applicants.

Key stages and typical mistakes in the procedure for recognition and enforcement of a foreign court judgment in Ukraine

It should be noted that foreign court judgments are subject to recognition and enforcement in Ukraine either where an international treaty is in force and binding upon Ukraine, with the consent of the Verkhovna Rada of Ukraine, or on the basis of the principle of mutual reciprocity.

Accordingly, the first practical step before filing an application with the court for recognition and enforcement of a foreign court judgment is to verify whether Ukraine and the state whose court rendered the relevant judgment have an applicable international treaty governing the recognition and enforcement of court decisions.

At the same time, the absence of an international treaty is not, an obstacle to the recognition and enforcement of a judgment, provided that reliance on reciprocity is permitted under national law. In other words, where no international treaty applies, the recognition and enforcement of a foreign court judgment is carried out on the basis of the principle of reciprocity. Article 462 of the CPC of Ukraine provides that, where recognition and enforcement of a foreign court judgment depends on reciprocity it, is presumed to exist unless proven otherwise.

A second key step is to identify the competent Ukrainian court to which the relevant application should be submitted, and to comply with the prescribed procedure and time limits for filing.

The procedure itself is not overly complex: the applicant files an application with the court together with the required supporting documents, as listed in Articles 466–472 of the CPC of Ukraine.

Where an international treaty binding upon Ukraine (with the consent of the Verkhovna Rada of Ukraine) sets out a specific list of documents to be submitted, the applicant must follow that list. If no such treaty applies, or if it does not prescribe the list of annexes, the following documents must be attached to the application:

1. a duly certified copy of the foreign court judgment;
2. evidence that the judgment has entered into legal force (unless this is stated in the judgment itself);
3. evidence that the party who did not participate in the proceedings was duly notified;
4. evidence specifying the part of the judgment that is subject to enforcement (if the judgment has been enforced in part previously);
5. evidence of the representative’s authority (where the application is filed by a representative).

Additionally, it is important to consider the practical issues that often lead to the rejection of the application. A typical mistake is the improper notification of a party about the proceedings, or the absence of proper evidence of such notification. If the party against whom the foreign judgment was rendered proves that it was not duly informed of the foreign proceedings, or was deprived of the opportunity to exercise its right to defence, this may constitute an independent ground for refusing recognition and enforcement of the foreign court judgment.

Another frequent ground for refusal is the applicant’s disregarding the existence of a domestic court decision in Ukraine between the same parties and based on the same grounds, which is already at the stage of compulsory enforcement. In such circumstances, Ukrainian courts generally proceed from the inadmissibility of double recovery and the principle of legal certainty.

In this context, it is useful to refer to several Supreme Court decisions which illustrate the prevailing approaches in Ukrainian case law on these issues.

Analysis of relevant Supreme Court case law

In its ruling of 30 July 2025 in case No. 756/7283/23 the Supreme Court examined compliance with the statutory time limit for filing an application for recognition of a foreign court judgment in Ukraine.

In June 2023, the applicant approached the Obolon District Court of Kyiv seeking recognition and leave for compulsory enforcement of the judgment of the District Court of Novo-Mesto (Republic of Slovenia) of 3 January 2020. The Slovenian judgment entered into

legal force on 13 February 2020 in case No. P 229/2016-46 concerning the recovery of monetary funds.

By its ruling of 21 February 2024, the Obolon District Court of Kyiv dismissed the application, in particular on the grounds that the debtor does not reside in Ukraine and that the judgment is already under enforcement in Slovenia, which could result in double recovery.

By its judgment of 24 September 2024, the Kyiv Court of Appeal set aside the first-instance court’s ruling but likewise refused the application on different grounds. The appellate court found that the applicant had lodged the application on 12 June 2023, i.e. outside the three-year limitation period established by Article 463 of the Civil Procedure Code of Ukraine.

The Supreme Court upheld the appellate court’s approach and stated that, under Ukrainian law, the time limit for presenting a foreign judgment for compulsory enforcement is three years from the date it has enteren into legal force. Since the foreign court judgment in case No. P 229/2016-46 entered into legal force on 13 February 2020 and the applicant submitted the application only on 12 June 2023 after the expiry of the three-year period, this constitutes grounds for refusing the application.

In its judgment of 22 October 2025 in case No. 308/17585/23, the Supreme Court considered other grounds relevant to granting an application for leave to enforce a foreign court judgment.

The circumstances of the case were that the applicant filed an application seeking recognition and leave for compulsory enforcement of the judgment of the District Court of Humenné (Slovak Republic) of 5 October 2020 and the ruling of 5 February 2021 in case No. 17Cb/26/2020 concerning the recovery of funds from a citizen of Ukraine for non-performance of obligations under a contract.

By its ruling of 2 April 2024, the Uzhhorod City-District Court of Zakarpattya Region granted the applicant’s motion. The court found no deficiencies as to the form and content of the application.

However, by its judgment of 7 November 2024, the Zakarpattya Region Court of Appeal set aside the ruling of the Uzhhorod City-District Court of Zakarpattya Region of 2 April 2024 and adopted a new decision, dismissing the application for recognition and leave for compulsory enforcement of the judgment of the court of the Slovak Republic. The dismissal was justified by improper notification of the debtor of the proceedings.

The Supreme Court disagreed with the appellate court’s conclusion regarding improper notification. It noted that the case file contained the debtor’s written statement waiving the right to submit written objections to the application for leave to enforce the foreign judgment.

Accordingly, the debtor had been duly notified and was aware of the filing and consideration of the application, and had a genuine opportunity to exercise procedural rights. This led the Supreme Court to conclude that the appellate court’s position was erroneous and, therefore, to set aside its decision to that extent.

It is worth addressing separately the categories of cases most frequently encountered in Ukrainian practice on the recognition and enforcement of foreign court judgments, in particular those relating to the recovery of alimony.

In this category of cases, in its judgment of 28 January 2026 in case No. 456/1567/24, the Supreme Court articulated a legal conclusion that an application for leave for compulsory enforcement of a foreign court judgment may be dismissed where a domestic court judgment between the same parties already exists and is being enforced.

In March 2024, the applicant approached to the Stryiskyi City-District Court of Lviv Region seeking recognition and leave for compulsory enforcement of the judgment of the Prague District Court of 15 June 2009 on the recovery of child maintenance.

By its ruling of 30 October 2024, the Stryiskyi City-District Court of Lviv Region granted the application for compulsory enforcement of the foreign judgment and granted leave for recovery of child maintenance under the foreign court judgment.

By its judgment of 23 September 2025, the Lviv Region Court of Appeal set aside the ruling of the court of first instance and adopted new decision, reasoning that there were no legal grounds to grant the application in view of the existance of Ukrainian domestic court judgment on child maintenance for the child’s support.

The Supreme Court upheld the appellate court’s position and stated that the existence of a domestic court judgment on child maintenance which is already at the enforcement stage excludes the possibility of granting an application for leave for compulsory enforcement of a foreign court judgment. Otherwise, this would result in the simultaneous existence of two enforcement documents for recovery from the debtor of the same amounts in favour of the same person.

Accordingly, it may be concluded that, when filing an application for leave for compulsory enforcement of a foreign court judgment, it is necessary to carefully take into account both substantive and procedural aspects. Before submitting the application, it is advisable to thoroughly analyse the circumstances of the case and the available documents, and to ensure that the application is properly prepared in accordance with the requirements as to its form, content, supporting documents, and time limits.