Poland–UK court cases after Brexit

Since 1 January 2021, in cases between Poland and the United Kingdom EU regulations no longer apply (including Brussels I bis and Brussels II bis). Instead, the Hague conventions and national law apply.

Judgments in civil and commercial cases

• The 2019 Hague Convention (recognition and enforcement of judgments): the EU, including Poland, since 1.09.2023; the UK since 1.07.2025 (including Scotland and Northern Ireland). It applies only to proceedings started after it came into force.
• The 2005 Hague Convention – choice of court agreements (the UK in its own right since 1.01.2021).
• The UK is not a party to the Lugano Convention – the EU did not agree to its accession in 2021.
• Service of documents: the 1965 Hague Convention; evidence: the 1970 Convention.

Family cases

• Child abduction abroad: the 1980 Hague Convention.
• Custody and parental responsibility: the 1996 Convention.
• Maintenance: the 2007 Convention.
• Divorce: recognition under the Family Law Act 1986 and the 1970 Hague Convention (Poland is a party).

What to do

1. In contracts with companies from the other country, state clearly which court has jurisdiction.
2. For a case started before 1.07.2025, check with a lawyer which rules apply.
3. In cases involving children, act quickly – time counts from the child’s departure.

Sources

• HCCH – 2019 Convention (status)
• House of Commons Library