Enforcing a Foreign Court Judgment in Israel

A London company wins a High Court judgment against a former supplier for an unpaid six-figure debt. The supplier has left the United Kingdom, has no assets there worth chasing, and now owns an apartment in Jerusalem and holds an Israeli bank account. The English judgment is sound, final, and completely inert on its own the moment the debtor's money is in Israel. A judgment is a domestic instrument; it stops at the border. To reach the apartment in Jerusalem, the creditor has to make the Israeli legal system adopt the English result as its own, and Israel has a specific statute for exactly that.

This is a routine but unforgiving area. It rewards creditors who move within the time limit and who understand that an Israeli court will not re-argue the original dispute, and it punishes those who treat a foreign judgment as self-executing. For a foreign business or individual holding a judgment against someone with an Israeli footprint, the question is not whether the debt is owed, which the foreign court already decided, but whether the Israeli conditions are met. A related route, suing in Israel in the first place, is covered in our answer on suing an Israeli business from abroad; this article assumes you already have the judgment.

Recognition and Enforcement Are Two Different Things

The Foreign Judgments Enforcement Law 5718-1958 offers two distinct remedies, and creditors often ask for the wrong one.

Enforcement (achifa) is what the London company needs. It asks an Israeli District Court to declare the foreign judgment enforceable, after which the judgment can be collected through the Execution Office exactly like a judgment handed down in Tel Aviv. Recognition (hakara) is different and narrower: it asks an Israeli court to accept the foreign judgment as an established fact, which matters for status and defensive purposes, for instance where a party relies on a foreign divorce or a finding already made abroad. Recognition can be direct, where a treaty provides for it, or incidental, arising inside another Israeli case. A creditor who wants to seize an apartment needs enforcement, and framing the application correctly at the outset avoids a wasted filing.

The Four Conditions the Court Checks

An Israeli court does not sit as an appeal from the foreign court. It checks that four gateway conditions in Section 3 are met, and it does not reopen the merits.

The judgment must have been given by a court that was competent under the law of the country where it sat. It must be final, no longer open to appeal in that country, so a judgment still under appeal is premature. Its content must be enforceable under Israeli law and not contrary to Israeli public policy, which is a high bar rarely reached by an ordinary commercial debt. And it must be executory, actually enforceable, in the country that gave it. Meet those four and the merits of the original dispute are simply not on the table; the debtor cannot use the Israeli hearing to re-argue that they did not really owe the money.

In Practice: Under Section 3 of the Foreign Judgments Enforcement Law 5718-1958, an Israeli District Court declares a foreign money judgment enforceable once it is final, was given by a competent court, and does not offend Israeli public policy, and Section 5 requires the application within five years of the judgment. An undefended application commonly takes 4 to 8 months. Budget for notarial translation of the judgment, where the first page runs NIS 251 under the Notaries Fees Regulations 1977 with further pages charged on top, plus apostille of the court documents in the country of origin.

Reciprocity and the UK-Israel Convention

Section 4 adds a condition that decides some cases before they start: reciprocity.

Israel will not, as a rule, enforce a judgment from a country whose own law would refuse to enforce Israeli judgments. For a British creditor this is straightforward, because the United Kingdom and Israel signed a bilateral convention in 1970, in force from 1971, for the reciprocal recognition and enforcement of judgments in civil matters, which provides a registration route for qualifying money judgments between the two states. That treaty is why UK judgments travel to Israel more smoothly than those from many other places. For a United States creditor there is no treaty, but Israeli courts have repeatedly treated reciprocity with the US as satisfied on the strength of how American courts handle foreign judgments, so US judgments are enforceable through the ordinary Section 3 route. Reciprocity, in practice, blocks very few common-law creditors.

In Practice: The UK-Israel convention of 1970, in force since 1971, lets a qualifying British money judgment be recognised and enforced in Israel, and once an Israeli District Court has declared it enforceable the creditor collects through the Execution Office (Hotzaa LaPoal). That can mean a lien registered against the debtor's Israeli apartment at the Land Registry or an attachment on an Israeli bank account. On a debtor who owns a Jerusalem flat worth NIS 3,000,000, a registered charge secures the debt against the sale proceeds, and the enforcement file itself is typically opened within days of the declaration.

The Defences a Debtor Will Raise

Because the merits are closed, a debtor resisting enforcement is pushed onto the procedural defences in Section 6, and a well-advised creditor anticipates them.

The debtor may argue that the judgment was obtained by fraud, that they were not given a reasonable opportunity to present their case, that the foreign court lacked jurisdiction under Israeli conflict-of-laws rules, that the judgment conflicts with another final judgment between the same parties, or that an action on the same matter was already pending in an Israeli court when the foreign proceedings began. The defence that surfaces most often against foreign default judgments is the second one: that the debtor was never properly served and so never had a chance to defend. A creditor who obtained a clean default abroad should assemble the proof of service before filing in Israel, because that is exactly where the debtor will push.

Collecting Once You Win

A declaration of enforceability is a means, not an end. The money still has to be extracted, and that happens in a separate forum.

Enforcement runs through the Execution Office (Hotzaa LaPoal), the same machinery that collects domestic Israeli debts. Through it a creditor can attach and garnish the debtor's Israeli bank accounts, register a lien on real estate at the Land Registry so the property cannot be sold clean, intercept an inheritance share due to the debtor, and in appropriate cases pursue further enforcement steps. This is why the whole exercise only makes sense when the debtor actually has reachable Israeli assets. Locating them, an apartment on the tabu, an account, a share in a family estate, is often the first practical task, and it is worth doing before spending on the enforcement application itself.

Common Mistake: A creditor sits on a foreign judgment for years while negotiating, then files in Israel after the five-year period in Section 5 has run, or tries to enforce a judgment that is still under appeal and therefore not final under Section 3. The application is dismissed or stalled, not because the debt is unreal but because the gateway was missed. By the time it is noticed, the debtor may have sold the Israeli apartment that would have secured the whole sum.

Practical Checklist

• Confirm the judgment is final and no longer appealable in the country that gave it before filing anything in Israel.
• Diarise the five-year limit in Section 5 from the date of the judgment, and file well inside it.
• Locate the debtor's Israeli assets first, since enforcement is pointless without a bank account, property, or inheritance share to reach.
• Gather proof of proper service in the original proceedings, especially for a default judgment, to defeat the Section 6 defence.
• Have the judgment and supporting documents apostilled and notarially translated into Hebrew.
• Instruct an Israeli lawyer under a notarised and apostilled power of attorney to bring the application and open the Execution Office file.

Speak With an Israeli Attorney

A foreign judgment is only as good as your ability to enforce it where the debtor keeps their money, and in Israel that means meeting the conditions of the 1958 Law inside the five-year window and moving quickly to secure the assets before they disappear. We assess whether your judgment qualifies, locate the debtor's Israeli assets, bring the enforcement application, and run the collection through the Execution Office.

Contact us for a confidential initial consultation.