The problem Brexit created
Before 2021, a judgment from a Lithuanian court could be enforced in England almost as though an English court had made it. The Brussels regime handled recognition automatically, and the reverse was equally true.
That is over. An EU judgment now needs a separate process in England before it can touch a debtor's assets here, and an English judgment needs an equivalent step in Lithuania. The practical effect is that a great many creditors hold judgments they assume are enforceable and discover, sometimes years later, that they are not.
When did the proceedings begin?
Before 31 December 2020
Transitional rules may still apply
- The old Brussels regime can survive for cases already begun
- Recognition is considerably simpler where it does
- The date proceedings started is what matters
- Worth establishing first, because it changes everything after
From 2021 onward
Common law enforcement
- Sue on the foreign judgment as a debt in England
- The English court does not re-hear the merits
- Defences are narrow but they exist
- Slower and more expensive than the old route
What I handle
- Enforcing a Lithuanian or EU judgment against assets in England and Wales.
- Enforcing an English judgment in Lithuania.
- Jurisdiction advice before proceedings, which is where most of the value sits.
- Commercial disputes where the contract, the parties or the assets sit in both countries.
- Contract and jurisdiction clauses drafted so a future dispute is enforceable rather than merely winnable.
- Asset tracing across both jurisdictions before deciding whether to sue at all.
How a cross-border matter runs
- 01Before anything
Find the assets first
Which country holds the money, the property and the trading entity. That answer usually decides where to sue, and it is cheaper to establish now than to discover after judgment.
- 02Before issuing
Choose the forum deliberately
Jurisdiction clauses, habitual residence, where the contract was performed. Where there is a genuine choice, it should be made on where enforcement will happen.
- 03Throughout
Litigate or settle in one place
Handled on one file in either jurisdiction, in English, Lithuanian or Russian, without a second firm and a second set of fees in the middle.
- 04After judgment
Enforce where the assets are
Recognition first where it is needed, then the enforcement method that fits what the debtor actually holds.
Why one solicitor rather than two firms
The usual arrangement
- A UK firm and a correspondent firm abroad
- Two retainers, two sets of fees
- Translation between them, and things lost in it
- Neither side owns the strategy
- Jurisdiction decided by whoever was instructed first
How this works instead
- One solicitor admitted in both jurisdictions
- One retainer, one file
- English, Lithuanian or Russian, no translator
- Enforcement planned before proceedings begin
- Forum chosen on where the assets are
What it costs
Cross-border matters are quoted case by case, because recognising a judgment and running a contested commercial dispute are not comparable. You get a written estimate before anything starts. Where a discrete step can be fixed-fee, it is.
Straight debt recovery, including cross-border debt, runs on the published fee scale: £75 for a letter before action plus 15% of what is recovered.
Common questions
Can I enforce a Lithuanian judgment in the UK?
Yes, but not automatically since Brexit. For proceedings begun from 2021 onward the usual route is common law enforcement: you sue on the foreign judgment as a debt in the English courts. The English court does not re-hear the merits, though narrow defences exist. Cases begun before the end of 2020 may still follow the older and simpler regime.
Can I enforce an English judgment in Lithuania?
Yes, through the equivalent process there. As with the reverse direction it is a separate step rather than something that happens by itself, and it is far easier to plan for before proceedings than to arrange afterwards.
Which country should I sue in?
Usually the one where the assets are. A judgment is only worth what you can enforce it against, so a convenient forum with no assets behind it produces a second piece of litigation rather than a recovery. Where a contract contains a jurisdiction clause that may settle it.
Do I need a lawyer in each country?
Not here. I am a solicitor in England and Wales and an advocate registered with the Lithuanian Bar, so both sides run on one file with one retainer. That removes the second set of fees and the translation layer that usually sits between a client and the advice.
What if the contract has no jurisdiction clause?
Then jurisdiction is argued on general principles: where the parties are based, where the contract was performed, where the damage occurred. It becomes a preliminary question in its own right, which is a good reason to take advice before either side issues.
How long does enforcement take?
Longer than it did before Brexit. Common law enforcement means fresh English proceedings, so the timetable resembles a claim rather than a registration. The practical answer depends on whether the debtor contests recognition.
This page states the law of England & Wales and Lithuania as at 18 August 2026. It is general information, not advice on your matter, and reading it does not create a solicitor-client relationship.