Robert Staszewski - Kancelaria Radcy Prawnego, Wroclaw

Enforcing a Foreign Judgment in Poland

If you have obtained a judgment abroad against a person or company with assets in Poland, you can usually enforce it here - the procedure depends on where the judgment comes from. As an attorney-at-law (radca prawny) in Wroclaw, I help foreign creditors recognise and enforce foreign judgments in Poland and act for clients who cannot be here in person.

This is a general overview as of late 2026. The details depend on the origin and type of the judgment, so each case should be assessed individually.

Judgments from EU member states

For judgments given in other EU member states in civil and commercial matters, the Brussels I Recast Regulation (Regulation (EU) No 1215/2012) applies. As a rule, such a judgment is recognised in Poland without any special procedure, and no separate declaration of enforceability (exequatur) is needed. In practice the creditor presents a copy of the judgment together with the standard certificate issued by the court of origin, and can then move to enforcement.

Judgments from outside the EU

Judgments from countries outside the EU - which, after Brexit, generally includes the United Kingdom, as well as the United States and other third countries - usually follow a different path. As a rule they require a declaration of enforceability from a Polish court before enforcement can begin: the court attaches an enforceability clause to the foreign judgment. Separate rules or bilateral arrangements can apply to particular countries, which is worth checking in advance.

Grounds for refusal are narrow

Importantly, the Polish court does not re-examine the merits of the dispute. The grounds for refusing recognition or enforcement are limited - for example where recognition would be manifestly contrary to Polish public policy, where the defendant's right to a fair hearing was not respected, or where the judgment is not final. A debtor who wants to contest enforcement generally has a limited time to lodge a formal objection, and that period may be longer where the debtor is domiciled abroad.

Enforcement itself

Once the judgment can be enforced in Poland, enforcement is carried out by a court bailiff (komornik), who can target the debtor's bank accounts, receivables and assets. Documents from abroad usually need a sworn translation into Polish, and sometimes an apostille or other authentication, so preparing the paperwork correctly at the start saves time later.

Acting through a representative - you do not need to travel

You do not have to come to Poland to recognise and enforce a judgment, or to be represented in Polish proceedings more generally. Under a power of attorney (pelnomocnictwo), a Polish lawyer can file the application, deal with the court and the bailiff, and represent you throughout. The power of attorney and foreign documents typically need a sworn translation, and in some cases authentication such as an apostille. I coordinate the whole process and keep you updated in English.

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Frequently asked questions

Can I enforce a judgment from another EU country in Poland?
As a rule yes, and relatively smoothly. Under the Brussels I Recast Regulation, a civil or commercial judgment from another EU member state is generally recognised in Poland without a special procedure and without a separate declaration of enforceability. The creditor presents the judgment and the certificate from the court of origin, then proceeds to enforcement.
What about a judgment from the UK, the US or another non-EU country?
These usually require a declaration of enforceability from a Polish court before enforcement can start, after which an enforceability clause is attached to the judgment. Specific rules or bilateral arrangements can apply to particular countries, so it is worth checking the position for the country concerned.
Will the Polish court re-open the whole case?
No. The court does not re-examine the merits. It checks only whether limited grounds for refusal apply - such as conflict with public policy, a breach of the right to a fair hearing, or the judgment not being final.
How is the judgment actually enforced?
Once it can be enforced in Poland, a court bailiff (komornik) carries out enforcement against the debtor's bank accounts, receivables and other assets. Foreign documents generally need a sworn translation and sometimes authentication.
Do I need to come to Poland?
No. Under a power of attorney, a Polish lawyer can handle recognition, enforcement and representation on your behalf, dealing with the court and the bailiff. The power of attorney and foreign documents usually need a sworn translation, and sometimes an apostille.

This article is general information and does not constitute legal advice. Every case is different - please consult a lawyer about your specific situation.