Enforcing an Israeli Judgment Abroad and a Foreign Judgment in Israel: Recognition in the EU, the New York Convention and the 2019 Hague Convention

An Israeli company that has won a judgment against a foreign party often discovers that winning is only half the way: the money is abroad, and the judgment must go through another procedure before a bailiff there will act on it. This guide explains what happens to an Israeli judgment in Europe, how an arbitral award is enforced, and what the rules are in the opposite direction, when a foreign party wants to enforce a judgment against an Israeli company in Israel. The legal position is current as of November 2026.

1Is an Israeli judgment automatically enforced in the European Union?

No. The Brussels I Recast Regulation (1215/2012) provides that a judgment given in a Member State is recognised in the other Member States without any special procedure (Article 36), and is enforceable there without a declaration of enforceability (Article 39). This rule applies only to judgments of Member States. An Israeli judgment is a judgment of a third country, so each EU country examines it under its national law and the treaties to which it is party.

In practice, in most countries an Israeli judgment goes through a procedure known in Europe as exequatur: an application to a local court to recognise the judgment and declare it enforceable. The court does not re-hear the dispute itself, but checks conditions such as the finality of the judgment, the jurisdiction of the Israeli court, the defendant's right to defend, public policy and sometimes reciprocity.

2What do recognition and enforcement proceedings for an Israeli judgment in Europe look like?

The details vary between countries, but the structure is similar: file an application with the competent court in the country where the assets are, attach the documents, and after the declaration turn to the local enforcement authorities. In Romania, for example, after recognition an application to a bailiff (executor judecătoresc) is required to attach accounts or assets.

1. A certified copy of the judgment and confirmation that it is final and no longer subject to appeal, according to the requirements of the requested country.
2. Proof that the defendant was duly summoned and given an opportunity to defend, especially for a judgment given in default.
3. An apostille on the Israeli documents: Israel has been a party to the Hague Convention Abolishing the Requirement of Legalisation since 1978, and all EU Member States are party to it.
4. A certified translation into the language of the local court.
5. An application by a local lawyer, who also checks the reciprocity question and the deadlines in the requested country.
6. Actual enforcement under local law, once the declaration has become final.

3Does the 2019 Hague Judgments Convention apply to Israel?

No, as of November 2026. According to the Hague Conference status table, Israel signed the Convention on March 3, 2021, but has not ratified it, so it is not in force with respect to Israel. The Convention applies only between states in both of which it is in force, so an Israeli judgment does not benefit from it in Europe, and a European judgment does not benefit from it in Israel.

Israel also signed the 2005 Hague Convention on Choice of Court Agreements on the same day and has not ratified it, so a jurisdiction clause choosing an Israeli court does not receive that Convention's protection in Europe. It is worth following the Hague Conference status tables, because a future ratification will change the picture.

4How is an arbitral award enforced abroad?

Under the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards. Israel signed it on June 10, 1958, ratified it on January 5, 1959 and it has been in force for Israel since June 7, 1959, without reservations. All 27 EU Member States are party to the Convention, and 172 states in total according to the UNCITRAL status table. Some states, including Romania, declared that they will apply the Convention only to awards made in states party to it and only to commercial relationships, but Israel is a party, and a dispute between companies is usually commercial.

The party seeking enforcement submits the arbitral award and the arbitration agreement, in the original or a certified copy, with a translation where necessary. The court may refuse only on the grounds defined in Article V of the Convention:

• Incapacity of a party, or an arbitration agreement that is not valid under the law applicable to it.
• The party against whom enforcement is sought was not given proper notice of the appointment of the arbitrator or of the proceedings, or was unable to present its case.
• The award goes beyond the scope of the arbitration agreement.
• The composition of the tribunal or the procedure was not in accordance with the parties' agreement or with the law of the seat of arbitration.
• The award is not yet binding, or has been set aside or suspended in the country in which, or under the law of which, it was made.
• The subject matter is not capable of settlement by arbitration under the law of the requested country, or enforcement would be contrary to its public policy.

In Israel, an application to confirm or set aside a foreign arbitral award to which a convention that Israel is party to applies is heard in accordance with the provisions of the convention (section 29A of the Arbitration Law, 5728-1968), and alongside this, regulations were enacted for implementing the New York Convention (Foreign Arbitration), 5738-1978.

5How is a foreign judgment enforced in Israel?

Under the Foreign Judgments Enforcement Law, 5718-1958, which provides that a foreign judgment shall not be enforced in Israel except under it (section 2). The court may declare a foreign judgment enforceable if four conditions are met (section 3): it was given in a state whose courts were competent to give it under its laws, it is no longer appealable, the obligation in it is enforceable under the laws of enforcement in Israel and its content is not contrary to public policy, and it is executable in the state in which it was given.

There is an important point here for an Israeli company sued abroad: under section 6(b), merely appearing before the foreign court to contest its jurisdiction, to request a stay in favour of arbitration or to protect seized assets is not considered consent to its jurisdiction. But ignoring a claim abroad is a risk, because a default judgment may be enforced in a country where the company has assets.

6A judgment or an arbitral award: which is easier to enforce abroad?

Usually an arbitral award, because of the New York Convention and its narrow grounds for refusal. But arbitration is a decision made in the contract, before the dispute, and it has its own costs.

How to frame this decision in advance in the contract is explained in the guide to governing law, jurisdiction and arbitration clauses, and on a dispute with a real estate developer see A dispute with a developer abroad: arbitration or court.

7What to check before suing in Israel a party whose assets are abroad?

1. Where the assets are and in which country enforcement will be required.
2. How that country recognises Israeli judgments: a treaty, reciprocity, conditions and deadlines.
3. Whether there is an arbitration clause or jurisdiction clause that determines the forum.
4. Whether proper service abroad is possible: defective service is a common ground for refusal.
5. What the total cost is: proceedings in Israel, followed by recognition proceedings, translations and enforcement abroad.
6. Whether urgent interim relief is needed in the country of the assets right now.

8What to do now, and how we accompany it

Before suing, and certainly before trying to enforce a judgment abroad, it is worth mapping the country where the assets are and its rules for recognising Israeli judgments and arbitral awards. Our office in Ness Ziona helps Israeli companies examine the enforcement route, prepare the judgment documents for use abroad and coordinate the proceedings with lawyers licensed in the requested country. Meetings in Bucharest are possible by prior arrangement.

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