Recognition of Foreign Court Judgments in Russia 2026

Short answer: can a foreign judgment be enforced in Russia?

Yes, recognition and enforcement of foreign court decisions in Russia is possible, but the procedure is subject to strict requirements. The legal basis is made up of international treaties, norms of procedural legislation and the principle of reciprocity. In 2025–2026, the procedure became significantly more complicated - legislative restrictions were adopted that block certain categories of decisions of courts of unfriendly states.

We, RECHTSANWALT ERICH RATH, accompany foreign creditors and Russian companies at all stages of this procedure - from assessing the enforceability of the decision to representation in court.

Basic information: legal framework, deadlines and statistics

• Legal basis: Article 409 of the Civil Procedure Code of the Russian Federation, Article 241 of the Arbitration Procedure Code of the Russian Federation, international treaties
• Deadline for filing an application: 3 years from the date of entry into force of the decision
• Average review period: from 2 to 6 months
• Probability of recognition for solutions from CIS countries: high (over 70%)
• Likelihood of recognition for EU and US decisions in 2026: significantly reduced due to legal restrictions

When recognition is possible and when it is not: overview table

Legal grounds for recognition and enforcement of foreign court decisions in Russia

Article 409 of the Civil Procedure Code of the Russian Federation and Article 241 of the Arbitration Procedure Code of the Russian Federation: scope and differences

The Civil Procedure Code (Article 409) regulates the recognition of decisions in cases not related to business activities: family, inheritance and other disputes between individuals. The Arbitration Procedure Code (Article 241) applies to commercial disputes between business entities.

The difference is in jurisdiction. The application is submitted either to a court of general jurisdiction at the place of residence of the debtor, or to an arbitration court of a constituent entity of the Russian Federation at the location (registration) of the debtor - a legal entity.

International treaties as the main basis: the Chisinau Convention and bilateral agreements

International treaties remain the main basis for recognition. Among them:

• Chisinau Convention of 2002 on Legal Assistance and Legal Relations in Civil, Family and Criminal Matters (for States Parties)
• Bilateral treaties on legal assistance (with Italy, Spain, India, China and a number of other states)

If there is an agreement, the court does not check the principle of reciprocity - compliance with the terms of a specific international agreement is sufficient.

The principle of reciprocity: how Russian courts apply it without an agreement

Without an international treaty, Russian courts can recognize a foreign decision on the basis of the principle of reciprocity (Part 4 of Article 15 of the Constitution of the Russian Federation, Article 409 of the Code of Civil Procedure of the Russian Federation). In practice, courts require the applicant to prove that the relevant foreign state recognizes and implements Russian judicial acts.

The burden of proof lies with the applicant. Courts accept as confirmation specific precedents for the execution of Russian decisions in a given state, opinions of foreign lawyers, and official certificates.

Special treatment for CIS countries in comparison with states without a treaty

For states party to the Chisinau Convention, the procedure is simplified: there is no need to prove reciprocity, and the list of grounds for refusal is determined by the terms of the applicable international treaty. For non-treaty states, the applicant must separately prove reciprocity, which significantly complicates the process.

Step-by-step procedure for applying for recognition and execution

Which Russian court has jurisdiction

• Cases involving individuals: court of general jurisdiction at the place of residence or location of the debtor’s property
• Commercial disputes: arbitration court of a constituent entity of the Russian Federation at the location (registration) of the debtor

Required documents

1. Certified copy of a foreign court decision
2. A document confirming the entry into force of the decision
3. Confirmation of proper notice to the defendant
4. Notarized translation of all documents into Russian
5. Apostille or consular legalization - only if required for documents from the relevant jurisdiction
6. Power of attorney for a representative (if necessary)

Application requirements and common mistakes

The application must contain:

• name of the addressee court
• information about the parties (full details)
• reference to the foreign court that issued the decision
• substance of the decision and date of entry into force
• request for recognition and enforcement

Typical errors: incomplete translation (including seals and stamps of the court), failure to provide evidence of notification, lack of confirmation of the entry into force of the decision, failure to comply with the three-year deadline.

Three-year period for enforcement

The application must be submitted within three years from the date the decision entered into legal force. The missed deadline can be restored by the court for good reasons (serious illness, force majeure circumstances). In practice, courts rarely reinstate the term.

Review deadlines

The average time for consideration of an application is from one to three months in arbitration courts and up to six months in courts of general jurisdiction. If appealing - an additional two to four months.

Grounds for refusal of recognition: what Russian courts check

Public order clause (ordre public)

The court has the right to refuse recognition if the execution of the decision contradicts the fundamentals of law and order (public order) of the Russian Federation. This clause is interpreted restrictively: it is not about any discrepancy with Russian law, but about a violation of fundamental principles - sovereignty, the foundations of the constitutional system, fundamental rights.

In 2025–2026, courts are increasingly applying this clause to decisions made on the basis of the sanctions legislation of foreign states.

Inadequate notice and violation of the right to defense

If the defendant was not given timely and proper notice of the proceeding, the court will deny recognition. This is one of the most commonly used grounds for refusal.

Exclusive jurisdiction of Russian courts

If the dispute falls within the exclusive competence of Russian courts (for example, cases of rights to real estate in the Russian Federation, cases of bankruptcy of Russian debtors), a foreign decision is not subject to recognition.

Conflict with Russian judicial act

If on the same dispute between the same parties there is already a Russian judicial act that has entered into force or the case is being processed by a Russian court, recognition will be refused.

Final judgments and interim measures

Russian courts recognize only final (entering into force) decisions. Interim rulings and interim measures of foreign courts are not subject to recognition - this is confirmed by consistent practice.

New legislative restrictions 2025–2026: anti-sanction standards

Federal constitutional law prohibiting the execution of certain foreign decisions

In 2025, the Federal Constitutional Law came into force, establishing a direct ban on the recognition and enforcement of decisions of courts and arbitrations of individual foreign states, if such decisions:

• based on the application of restrictive measures (sanctions) against Russian persons
• issued using asset freeze mechanisms
• aimed at enforcing compliance with sanctions requirements

Which decisions of the EU and US courts are blocked

Decisions related to:

• recovery of damages arising from the application of sanctions
• forcing to break contractual relations due to sanctions pressure
• foreclosure of assets frozen under sanctions regimes

This does not mean a complete ban on the recognition of all decisions from the EU or US. Decisions on ordinary commercial disputes not related to sanctions can still be formally recognized subject to compliance with general conditions. However, in practice, courts show increased caution.

Practical influence on participants in commercial disputes

Foreign creditors from unfriendly countries face a serious complication of the procedure. It is recommended to conduct a preliminary assessment of the enforceability of the decision before the start of the procedure, as well as to consider alternative mechanisms - recourse to international commercial arbitration, negotiations, use of the debtor’s assets abroad.

Judicial practice and statistics

Most common grounds for refusal

1. Inadequate notice to the defendant
2. Contradiction to the public order of the Russian Federation
3. Exclusive jurisdiction of Russian courts
4. Lack of an international treaty and lack of proof of reciprocity

Comparative indicators: CIS and EU/US states

Impact of restrictions 2025–2026 on case outcomes

The number of requests to recognize decisions of courts of unfriendly states has decreased. Courts are increasingly using the public policy clause, and claimants from the EU and US are increasingly using arbitration mechanisms in neutral jurisdictions.

A practical list for creditors seeking enforcement in Russia

Pre-check

• Determine the presence or absence of an international treaty
• Assess whether the decision is subject to anti-sanction restrictions
• Check the proper notification of the debtor at the stage of foreign proceedings
• Make sure the decision is final (entry into force)

Preparation of documents

1. Check if an apostille or consular legalization is required for a specific jurisdiction
2. Perform a notarized translation into Russian
3. Receive a certificate of entry into force of the decision
4. Collect evidence of the debtor's notice

Risk assessment

We recommend that you conduct a legal analysis of the prospects before submitting your application. Lawyer Erich Rath (Rechtsanwalt Erich Rath) and our team carry out this assessment taking into account current legislation and judicial practice in 2026.

Alternative Strategies

If there is a high probability of failure, it is advisable to consider:

• filing a new claim in a Russian court on the merits of the dispute
• applying to international commercial arbitration
• identification and foreclosure of the debtor’s assets in other jurisdictions

Key facts

• Recognition of foreign court decisions in Russia is regulated by the Code of Civil Procedure of the Russian Federation, the Arbitration Procedure Code of the Russian Federation and international treaties
• The three-year period for filing an application is calculated from the date the decision enters into force
• In 2025–2026, legislative restrictions will apply on the recognition of decisions related to sanctions issues
• Decisions of courts of CIS countries have the greatest chance of recognition
• Inadequate notice to the defendant is the most common ground for refusal.
• Preliminary legal assessment significantly reduces the risks of unsuccessfully going to court

FAQ: Recognition of decisions of foreign courts in Russia

Is it necessary to have an international treaty for recognition?

No. Without a contract, recognition is possible based on the principle of reciprocity. However, the burden of proving reciprocity lies with the applicant, which significantly complicates the procedure.

When is an apostille or consular legalization required?

An apostille or consular legalization is not required as a general rule, but only if it follows from the applicable international treaty, the country of origin of the documents and the requirements of the Russian court. This issue is examined separately in each case.

Is it possible to recognize a German court decision in Russia in 2026?

There is no bilateral agreement between Russia and Germany on legal assistance in civil matters. Recognition is possible on the basis of the principle of reciprocity, provided that the decision is not related to sanctions. Each case requires individual analysis.

How long does the procedure take from submission to execution?

On average - from three to six months without appeal. In case of appeal, the period increases to 8–12 months.

What to do if the application deadline is missed?

Simultaneously with the application for recognition, submit a petition for restoration of the deadline. Please provide valid reasons for absence and attach supporting documents.

Can interim measures from a foreign court be recognized?

No. Russian courts only recognize final decisions on the merits of the dispute. Interim (temporary) measures of foreign courts are not subject to recognition and enforcement.

If you need advice on the issue of recognition of a foreign court decision in Russia or an assessment of the prospects for enforcement, please contact us:

Phone: +7 (495) 970-74-16

Email: info@ratanwalt.com

Address: Moscow, Rozhdestvenka St., 5/7 p. 1

Website: https://www.ratanwalt.com/

RECHTSANWALT ERICH RATH - legal support of international disputes, recognition and execution of foreign court decisions, representation of the interests of foreign companies and citizens in Russian courts.