Czech Court Judgments in Belarus: Recognition and Enforcement Under the 2026 Civil Procedure Code

You have a Czech court judgment against a Belarusian debtor. The debtor has assets in Minsk or another region of Belarus. Now what? Can you enforce your judgment directly, or is there a special procedure?

The answer depends on several factors. Unlike arbitral awards, which benefit from the New York Convention, foreign court judgments operate under a different legal regime in Belarus. And for judgments from EU countries like Czechia – with which Belarus has no bilateral legal assistance treaty – the path to enforcement requires proving reciprocity.

This guide walks you through the legal framework under the new Civil Procedure Code (CPC) that came into force in Belarus on January 1, 2026, and explains what creditors need to know when seeking to enforce Czech court decisions.

The Fundamental Distinction: Court Judgments vs. Arbitral Awards

Before diving into procedures, one distinction matters above all others. Belarusian law treats foreign court judgments and foreign arbitral awards very differently.

Arbitral awards enjoy a relatively straightforward path to enforcement. Belarus is a party to the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards. This means that if you have an arbitration award from Prague or any other New York Convention state, you can seek its recognition and enforcement in Belarus based on the Convention, regardless of whether Belarus has a separate treaty with the country of origin.

Foreign court judgments operate under a different, more restrictive regime. Under Article 527 of the new CPC, decisions of foreign courts are recognized and enforced in Belarus only if:

• an international treaty between Belarus and the country where the judgment was issued so provides;
• the principle of reciprocity applies;
• an international treaty provides that the foreign judgment does not require a special recognition procedure and is enforced in the same manner as a Belarusian court decision.

For Czech court judgments, the first basis does not apply – Belarus and the Czech Republic have no bilateral legal assistance treaty covering the recognition and enforcement of court judgments. The third basis also does not apply. This leaves only the second option: reciprocity.

What Does Reciprocity Mean in Practice?

Reciprocity means that a Belarusian court will enforce a Czech judgment only if it is satisfied that Czech courts would enforce a Belarusian judgment under similar circumstances.

This is not automatic. Under the CPC, reciprocity must be proven. The party seeking enforcement must provide evidence that Czech courts recognize and enforce judgments from Belarusian courts.

In practice, this creates several challenges:

• Expert legal opinions required.You need to obtain opinions from Czech law practitioners confirming that Czech courts do in fact enforce Belarusian judgments.
• Case law evidence.Presenting actual cases where Czech courts recognized Belarusian judgments significantly strengthens your application.
• Discretionary assessment.Belarusian courts evaluate reciprocity evidence on a case-by-case basis. Even with strong evidence, there is no guarantee of success.

Is There Any Cooperation Between Belarus and Czechia?

While there is no bilateral treaty on judicial assistance, there is some cooperation in the enforcement field. On October 18, 2019, the Ministry of Justice of the Republic of Belarus and the Chamber of Judicial Officers of the Czech Republic signed a Memorandum of Cooperation.

This memorandum establishes a basis for:

• exchanging expert knowledge on improving legislation and organizing enforcement bodies;
• sharing information, analytical and reference materials, and regulatory legal acts;
• organizing events of common interest.

The memorandum included discussions on enforcement of decisions issued by foreign courts outside the European Community. While this memorandum does not create a direct legal basis for enforcement, it demonstrates that Belarus and Czechia have an established relationship in the enforcement field – which may be relevant when arguing the principle of reciprocity.

Legal Framework Under the 2026 Civil Procedure Code

Articles 527–536 of new CPC, which entered into force on January 1, 2026, now governs international civil procedure, including the recognition and enforcement of foreign judgments and arbitral awards.

Key Changes from Previous Legislation

The CPC introduced several important changes:

• Electronic filing.Applications can now be filed as electronic documents signed with a digital signature. This modernizes the process and speeds up submission.
• Clarified document requirements.The list of documents to be attached to the application has been detailed, with specific differences depending on whether the party participated in the proceedings.
• Distinction for arbitral awards.The CPC separates grounds for refusing recognition of arbitral awards into two categories: those where the court may refuse (upon application of the party) and those where the court must refuse.

What Documents Are Required for Enforcement?

If you decide to pursue enforcement of a Czech court judgment in Belarus, you must prepare the following documents under CPC:

Grounds for Refusal: When Enforcement May Be Denied

Article 532 of the CPC sets out the grounds on which a Belarusian court may refuse recognition and enforcement of a foreign court judgment. For Czech judgments, these include:

What About the Three-Year Limitation Period?

Under Belarusian law, there is a three-year limitation period for presenting a foreign judgment for enforcement. This period runs from the date the judgment entered into legal force in Czechia.

Missing this deadline is fatal – courts cannot restore it. Creditors who delay enforcement in hopes of voluntary payment often find themselves barred by prescription.

Strategic Recommendations for Creditors

If you hold a Czech court judgment against a Belarusian debtor, consider the following practical steps:

• Obtain reciprocity evidence early.Gather expert legal opinions from Czech law practitioners confirming that Czech courts enforce Belarusian judgments. Present actual case examples if available.
• Ensure proper service in the original proceedings.One of the most common grounds for refusal is lack of proper notice to the debtor. Make sure the Czech proceedings included legally valid service that will be recognized in Belarus. Document it carefully.
• Act quickly.The three-year limitation period is strict. Start the enforcement process as soon as the judgment is final.
• Prepare complete documentation.Ensure all documents are properly certified, translated by a sworn translator, and comply with the requirements of Article 530 of the CPC.
• Consider the arbitration alternative.If you are negotiating future contracts with Belarusian partners, consider including an arbitration clause rather than submitting to the jurisdiction of Czech courts. Arbitral awards benefit from the New York Convention and do not require proving reciprocity.

What About the Reverse? Enforcing Belarusian Judgments in Czechia

The reciprocity principle works both ways. If you are a Czech creditor, understanding whether Belarusian judgments have been enforced in Czechia is crucial to proving reciprocity. While there is no publicly available data on recent cases, the existence of the 2019 Memorandum of Cooperation suggests that both countries recognize the importance of cooperation in enforcement matters .

For Belarusian parties seeking to enforce judgments in Czechia, the procedure is governed by Czech law. Since both Belarus and Czechia are parties to the European Convention on Human Rights, there may be additional considerations regarding due process and fair trial rights.

Conclusion

Enforcing a Czech court judgment in Belarus is possible in principle, but the path is narrow and depends on proving reciprocity. Unlike arbitral awards, which benefit from the New York Convention, Czech court judgments require demonstrating that Czech courts would enforce Belarusian judgments under similar circumstances.

The new 2026 Civil Procedure Code has modernized the process by allowing electronic filing and clarifying document requirements. However, the fundamental legal structure remains unchanged: without a bilateral treaty, reciprocity is the only route.

For creditors holding Czech judgments, the most practical approach is to:

• gather robust evidence of reciprocity;
• ensure proper service and documentation;
• act within the three-year limitation period;
• work with experienced local counsel who understand Belarusian enforcement procedures.

If you are still in the contract negotiation phase, consider adding an arbitration clause to your agreement. That single clause can transform a complex enforcement challenge into a manageable procedure under the New York Convention.

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