Enforcing French Court Decisions in Russia: What Creditors Need to Know in 2026

You have a French court judgment against a Russian debtor. The debtor has assets in Moscow or St. Petersburg. Now what? Can you simply take your French judgment to a Russian court and expect enforcement?

The short answer is: it depends. And in 2026, the answer depends heavily on several factors: whether your judgment is a court decision or an arbitral award, whether the debtor is a sanctioned entity, and whether France is considered a “friendly” or “unfriendly” jurisdiction under Russian law.

Let's break down how this works in practice.

The Fundamental Distinction: Court Judgments vs. Arbitral Awards

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

Arbitral awards enjoy a relatively straightforward path to enforcement. Russia 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 Paris (for example, from the ICC International Court of Arbitration), you can seek its recognition and enforcement in Russia based on the Convention, regardless of political tensions. However, even arbitral awards face growing scrutiny – Russian courts have increasingly applied a broad interpretation of public policy to refuse enforcement, particularly where sanctioned Russian entities are involved.

Foreign court judgments operate under a different, more restrictive regime. Under Article 241(1) of the Russian Arbitration Procedure Code (APC), decisions of foreign courts in commercial disputes shall be recognized and enforced in Russia only where such recognition is permitted by:

• an international treaty to which Russia is a party; or
• a federal law of the Russian Federation.

Since Russia and France have no bilateral treaty on judicial assistance, the legal basis for enforcing a French court judgment in Russia is limited. In rare cases, Russian courts have recognized foreign court decisions on the basis of the principles of international comity and reciprocity.

The Reciprocity Principle: A Rare But Possible Path

A landmark case in 2026 demonstrated that enforcement of foreign judgments without a treaty is possible. Russian courts recognized and enforced a Dutch court judgment based on the principle of reciprocity and international comity – the first such case in Russian practice.

The court held that because Dutch courts had enforced Russian judgments, reciprocity existed, and therefore Russian courts should enforce Dutch judgments. This principle could theoretically apply to French judgments if a French court has enforced a Russian judgment.

What this means for French creditors: You must prove that French courts would enforce a Russian judgment under similar circumstances. This requires:

• obtaining expert legal opinions from French law practitioners
• presenting evidence of actual enforcement cases where French courts recognized Russian judgments
• demonstrating the principle of reciprocity in French practice

However, the political climate matters. The “unfriendly” designation of France significantly complicates this path.

The Impact of “Unfriendly” Jurisdictions

On 5 March 2022, the Russian government adopted Order No. 430-r, approving a list of so-called “unfriendly” states – jurisdictions that imposed or joined sanctions against Russia. France, as an EU member state, is on this list.

This designation has had a visible impact on enforcement practice. Statistics show that in 2025, of the 41 cases concerning foreign state court judgments, only 7% involved “unfriendly” jurisdictions. The overwhelming majority of successfully enforced judgments came from “friendly” jurisdictions, primarily in the post-Soviet region.

Key trend: Russian courts have increasingly treated sanctions-related considerations as independent public policy grounds for refusal. If the debtor is a sanctioned Russian entity, the prospects for enforcement drop significantly.

New Legislation: The 2026 Constitutional Shield

Effective January 9, 2026, Federal Constitutional Law No. 8-FKZ introduced a direct prohibition on enforcing in Russia decisions of foreign and international courts whose jurisdiction Russia does not recognize. This applies to:

• foreign criminal court decisions with expanded or delegated jurisdiction without Russian consent;
• international judicial bodies not based on a treaty ratified by Russia or a UN Security Council resolution under Chapter VII.

While this primarily targets criminal matters and international tribunals, it reflects a broader trend of Russian courts asserting judicial sovereignty and rejecting extraterritorial application of foreign law.

The Exclusive Jurisdiction Trap: Articles 248.1 and 248.2 of the APC

A significant obstacle for French creditors arises from Articles 248.1 and 248.2 of the Russian Arbitration Procedure Code, introduced in 2020. These provisions establish the exclusive jurisdiction of Russian economic courts over disputes involving sanctioned Russian entities or disputes arising from the application of foreign restrictive measures.

How this works in practice: Even if your contract with a Russian party contains a French court jurisdiction clause, Russian courts may disregard it. They have actively enforced these provisions, issuing anti-suit injunctions prohibiting the initiation or continuation of litigation before foreign courts or international commercial arbitration seated abroad. Judgments issued by foreign courts in breach of such orders are neither recognized nor enforced in Russia.

For a French creditor, this means that if the Russian debtor is sanctioned, any French court judgment may be unenforceable in Russia, regardless of the merits of the case.

Practical Steps for Enforcing a French Judgment in Russia

If you decide to pursue enforcement despite these challenges, here is what you need to know.

Determine the Competent Court

For commercial disputes, the application must be filed with the arbitrazh (commercial) court of the region where the debtor is located or where the debtor's property is situated. Under Article 242 of the APC, this is the court of the subject of the Russian Federation.

For non-commercial civil matters (e.g., family law, personal injury), the application goes to the courts of general jurisdiction under the Civil Procedure Code (CPC), specifically the regional or equivalent court.

Gather the Required Documents

Article 242 of the APC specifies the documents you must attach to your application:

• A certified copy of the French court decision;
• A document confirming that the judgment has entered into legal force (if not evident from the judgment itself);
• Evidence that the debtor was properly notified of the French proceedings (crucial – lack of proper notice is a common ground for refusal);
• A power of attorney or other document confirming the authority of the person signing the application;
• Proof that the application was sent to the debtor;
• A certified translation of all documents into Russian.

For civil cases under the CPC, similar requirements apply, including the three-year limitation period for presenting a foreign judgment for enforcement.

Prove Reciprocity (or Treaty Basis)

Since there is no bilateral treaty between France and Russia, you must prove that French courts would enforce a Russian judgment under similar circumstances. This requires:

• Expert legal opinions from French law practitioners;
• Evidence of actual cases where French courts enforced Russian judgments;
• Demonstration of the principle of reciprocity in French practice.

Without this, the court will refuse enforcement.

Anticipate Public Policy Arguments

Russian courts have increasingly relied on a broad interpretation of public policy to refuse enforcement. In cases involving sanctioned Russian entities, courts have held that enforcement could harm the Russian state budget or violate temporary measures regulating obligations to counterparties from “unfriendly” jurisdictions.

Be prepared for the debtor to argue that:

• Enforcement would violate Russian public policy;
• The French court lacked impartiality (a presumption of bias has been established for arbitrators and courts from “unfriendly” jurisdictions);
• The case falls under exclusive Russian jurisdiction under Articles 248.1 or 248.2.

Understand the Timeline

Under the APC, the court must review the application within one month. Under the CPC for non-commercial matters, the timeframe is similar. In practice, complex cases take longer, especially where reciprocity must be proven or public policy arguments are raised.

The Arbitration Alternative

If you are still in the contract negotiation phase, consider including an arbitration clause rather than submitting to the jurisdiction of French courts.

Why arbitration? Arbitral awards from France benefit from the New York Convention, which Russia continues to apply. While enforcement has become more difficult since 2022, arbitral awards are still enforced more frequently than foreign court judgments.

In 2025, the majority of foreign judgments from “unfriendly” jurisdictions were not recognized in Russia. However, some arbitral awards from institutions like the LCIA (London) and SCC (Stockholm) were enforced, particularly where the creditor was a Russian party. The key is choosing an arbitral institution and seat that Russian courts view as neutral.

What About the Reverse? French Enforcement of Russian Judgments

The reciprocal principle works both ways. If you are a French creditor, understanding whether Russian judgments have been enforced in France is crucial to proving reciprocity. Recent examples exist: a French court recognized and granted leave to enforce (exequatur) a $5 billion arbitral award against Russia in favor of Naftogaz, allowing asset attachments in France. This demonstrates that French courts do enforce foreign awards, supporting the reciprocity argument for Russian courts.

Practical Recommendations for French Creditors

• Choose Arbitration When Possible.If you are negotiating a contract with a Russian partner, include an arbitration clause with a neutral seat (e.g., Singapore, Hong Kong, or a “friendly” jurisdiction) and a reputable institution.
• If You Have a French Court Judgment, Act Quickly.The three-year limitation period under the CPC is strict. Start the enforcement process as soon as the judgment is final.
• Gather Evidence of Reciprocity Early.Obtain expert opinions from French law practitioners confirming that French courts enforce Russian judgments before filing. This evidence is crucial.
• Ensure Proper Service.One of the most common grounds for refusal is lack of proper notice to the debtor. Make sure the French proceedings included legally valid service that will be recognized in Russia.
• Consider Asset Location.If the debtor's assets are in Russia, be realistic about enforcement prospects – especially if the debtor is a sanctioned entity. If assets are in “friendly” jurisdictions, consider enforcing there instead.
• Work with Local Counsel.Russian enforcement procedures require familiarity with the APC and CPC. Local lawyers understand the practical requirements and can help avoid procedural mistakes.

Conclusion

Enforcing a French court judgment in Russia is possible in principle, but the path is narrow and uncertain. Unlike arbitral awards, which benefit from the New York Convention, French court judgments depend on proving reciprocity – a process that requires strong evidence and carries significant political risk.

The “unfriendly” designation of France, the exclusive jurisdiction provisions of Articles 248.1 and 248.2, and the broad interpretation of public policy by Russian courts all create substantial obstacles. For French creditors, the most practical approach is to:

• consider arbitration for future contracts;
• gather robust evidence of reciprocity;
• ensure proper service and documentation;
• work with experienced local counsel.

If you hold a French court judgment against a Russian debtor, realistic expectations are essential. Enforcement is not impossible, but it is a challenging process that requires careful preparation and strategic patience.

Our law firm “Economic Disputes” has been operating in the B2B market since 2019 and specializes in comprehensive business support, including international business. Our team consists of 15 lawyers and specialists, each with 15 to 25 years of experience in corporate law, tax consulting, and international commercial arbitration. Our practice manager, Sergey Belyavsky, brings 20 years of unparalleled experience in commercial courts, including 10 years as a judge, which allows us to assess risks from a practical perspective. We are members of the Austrian Arbitration Association (AEA) and have a partner network in over 160 countries. Results are our priority: throughout our work, we have recovered and saved our clients 1.95 billion rubles, supported by over 100 reviews with an average rating of 4.95 out of 5. We handle cases in Russian, Polish, and English and are ready to assist even in the most challenging situations. For the convenience of our international clients, we maintain a bank account with PKO Bank Polski to facilitate efficient cross-border settlements. If your company needs legal support, submit a request – we will offer a realistic solution.