How are foreign judgments recognised in the Netherlands?

Dutch term: Erkenning buitenlandse vonnissen | Legal basis: Brussels I Recast + Gazprombank case law

EU judgments are recognised and enforceable in the Netherlands directly under Brussels I Recast (Regulation (EU) 1215/2012) without a separate exequatur procedure. The creditor obtains an article 53 certificate from the court of origin and presents it to a Dutch bailiff for enforcement. Refusal is possible only on narrow grounds (public policy, irregular service, irreconcilable judgments).

Non-EU judgments are not automatically recognised. The creditor must start a new proceeding before a Dutch court, using the foreign judgment as evidence, following the Gazprombank framework developed by the Dutch Supreme Court. Recognition is granted if the foreign court had proper jurisdiction, due process was observed, the judgment does not violate Dutch public policy, and there is no irreconcilable Dutch or earlier foreign judgment.

Why it matters for international businesses

For international businesses with a judgment from a non-EU country, the Gazprombank route is available but adds time and cost compared to direct EU enforcement. Arbitral awards benefit from the more favourable New York Convention enforcement regime.