Securinga favourable judgment is only part of the process. If the judgment debtor holdsbank accounts, shares, immovable property, receivables or other assets inCyprus, the judgment creditor may apply to the Cypriot courts for recognitionand enforcement of the Ukrainian judgment.

Ukrainianjudgments are not recognised under the European Union regime applicable tojudgments issued in other EU Member States. Instead, their recognition andenforcement in Cyprus are principally governed by the bilateral legalcooperation framework between Cyprus and Ukraine, together with the relevantCypriot legislation.

Where theapplicable requirements are satisfied, a final Ukrainian judgment may berecognised, registered and enforced substantially as if it were a judgmentissued by a Cypriot court.

Thelegal framework

Theprincipal legal instruments governing the procedure are:

• The Agreement between the Republic of Cyprus and Ukraine on Legal Cooperation in Civil Matters, signed on 6 September 2004 and ratified in Cyprus by Law 8(III)/2005.
• The Foreign Judgments (Recognition, Registration and Enforcement pursuant to a Convention) Law of 2000, Law 121(I)/2000.
• The applicable provisions of the Cyprus Civil Procedure Law, the Courts of Justice Law and the procedural rules governing applications before the Cypriot courts.

Thebilateral Agreement establishes the basis upon which judgments delivered by thecourts of Ukraine may be recognised and enforced in Cyprus.

Theprocedure does not ordinarily involve a retrial of the underlying dispute. TheCypriot court is not asked to decide the case again or determine whether theUkrainian court reached the correct conclusion on the facts or Ukrainian law.Its role is to examine whether the judgment satisfies the conditions prescribedby the bilateral Agreement and Cypriot legislation.

Conditionsfor recognition and enforcement

Everyapplication must be assessed on its particular facts and procedural history.Generally, the applicant will need to establish the following matters.

1.Judgment of a competent Ukrainian court

Thejudgment must have been issued by a Ukrainian court that exercised jurisdictionin circumstances recognised under the bilateral Agreement.

Questionsof jurisdiction may arise where, for example, the defendant was not domiciledin Ukraine, did not submit to the Ukrainian proceedings or disputes theexistence of any sufficient connection with Ukraine.

2.Finality and enforceability

Theapplicant must demonstrate that the judgment is final, binding and enforceablein Ukraine.

Where thejudgment has been appealed, amended or upheld by a higher court, the relevantappellate decisions should also be presented. The Cypriot court must be able toidentify the judgment’s final operative terms and establish that no ordinaryappeal prevents its enforcement.

Adistinction should be drawn between legal enforceability and practical successin execution. The fact that enforcement attempts in Ukraine have not producedpayment does not necessarily mean that the judgment is no longer legallyenforceable.

3.Proper notice and the right to be heard

Therespondent must have been given proper and timely notice of the Ukrainianproceedings and a genuine opportunity to present its case.

Thisissue is particularly important in relation to judgments issued in thedefendant’s absence. The applicant should be prepared to produce evidenceshowing how and when the originating documents were served and whether therespondent participated in the proceedings.

Recognitionmay be refused where the defendant was not properly notified or was otherwisedeprived of a fair opportunity to defend the proceedings.

4. Aclear and enforceable obligation

In thecase of a monetary judgment, the amount payable must be specified orobjectively ascertainable from the judgment.

Ajudgment may still be capable of recognition where it does not state one finalaggregate figure, provided that its terms clearly identify:

• The principal amount.
• The applicable interest rate.
• The period for which interest is payable.
• Any other objective elements necessary to calculate the debt.

TheCypriot court must be able to determine the obligation without reconsideringthe merits or altering the substance of the foreign judgment.

5.Compliance with Cyprus public policy

Recognitionmust not be contrary to the public policy of the Republic of Cyprus.

Thepublic-policy exception is generally applied restrictively. It is notsufficient to argue that a Cypriot court might have reached a differentconclusion. The respondent must ordinarily identify a serious incompatibilitywith fundamental principles of Cypriot law, procedural fairness or naturaljustice.

6. Noconflicting judgment

Recognitionmay be refused where the Ukrainian judgment is irreconcilable with a finaljudgment already issued in Cyprus or with another judgment capable ofrecognition in Cyprus involving the same parties and subject matter.

Theexistence of parallel or previously concluded proceedings should therefore beexamined before the application is filed.

TheCypriot court will not ordinarily reconsider the merits

Arecognition application is not an appeal against the Ukrainian judgment.

TheCypriot court will ordinarily not reconsider:

• The Ukrainian court’s assessment of the witnesses.
• The weight given to documentary evidence.
• The interpretation of the underlying contract.
• The correctness of factual findings.
• Alleged errors of Ukrainian substantive law.
• Defences that were, or could have been, determined in the Ukrainian proceedings.

Argumentsthat the underlying debt was paid, that the contract was invalid or that theUkrainian court reached the wrong conclusion will not normally justify a freshdetermination of the original dispute. Such matters must generally have beenraised through the remedies available before the Ukrainian courts.

However,issues such as fraud, lack of proper notice, denial of a fair hearing orviolation of public policy may be relevant where they fall within a recognisedground for refusing enforcement and are supported by credible evidence.

Proceduralrequirements

Proceedingsare generally commenced before the competent Cypriot court by an applicationsupported by affidavit evidence.

Dependingon the circumstances, the applicant will usually need to produce:

• A duly certified or authenticated copy of the Ukrainian judgment.
• Copies of all relevant appellate or cassation decisions.
• Official confirmation that the judgment is final and enforceable.
• Evidence establishing that the respondent was properly notified of the Ukrainian proceedings.
• Evidence identifying the parties and confirming the judgment creditor’s entitlement.
• Certified Greek translations of the judgment and supporting documents.
• Evidence concerning the judgment debtor’s presence or assets in Cyprus.
• Expert evidence on Ukrainian law where the judgment’s legal effect, finality or enforceability is disputed.

Thesupporting affidavit should explain the history of the Ukrainian proceedings,identify the final judgment to be registered and address the relevant treatyand statutory conditions.

Accuracyof names and corporate details

Particularcare should be taken with the transliteration of Ukrainian names.

Differentdocuments may use different English spellings of the same Ukrainian name.Although a minor clerical error will not necessarily defeat an applicationwhere the party’s identity is otherwise clear, inconsistencies can createavoidable objections and delays.

Theapplication should therefore clearly reconcile any differences concerning:

• First names, surnames and patronymics.
• Ukrainian and English transliterations.
• Passport or identification details.
• Previous corporate names.
• Registration numbers and registered addresses.
• Corporate transformations, mergers or succession.

Where thejudgment creditor or debtor has undergone a corporate restructuring, supportingdocuments should establish the chain of legal succession.

Enforcementfollowing recognition

Oncerecognised and registered, the Ukrainian judgment may be enforced through theprocedures available for Cypriot judgments.

Dependingon the nature of the debtor’s assets, enforcement measures may include:

• Garnishee proceedings against Cypriot bank accounts or debts owed by third parties.
• Charging orders over shares held in Cypriot companies.
• Registration and execution against immovable property.
• Seizure or sale of movable assets.
• Examination of the judgment debtor regarding its assets and financial affairs.
• Insolvency or winding-up proceedings, where the relevant conditions are satisfied.

Recognitionand enforcement should therefore be supported by an early investigation intothe debtor’s assets. Registration of the judgment may have limited commercialvalue unless assets or income capable of execution can be identified in Cyprus.

Interimprotective measures

Wherethere is a genuine risk that assets will be concealed, transferred ordissipated, the judgment creditor may need to consider applying for interimprotective measures.

Dependingon the facts, the Cypriot courts may have jurisdiction to issue freezing,disclosure or other protective orders. Such relief is discretionary andrequires persuasive evidence of urgency, risk and the need to preserve theeffectiveness of the enforcement process.

Assetpreservation should be considered at the beginning of the matter rather thanafter the debtor has received notice of the recognition application.

Practicalconsiderations

Beforeproceedings are commenced, the judgment creditor should consider:

• Whether the judgment is final and currently enforceable in Ukraine.
• Whether all appeals have been completed or exhausted.
• Whether service on the defendant can be proved.
• Whether the monetary obligation is sufficiently clear.
• Whether the necessary originals and certified copies are available.
• Whether certified Greek translations can be obtained.
• Whether limitation issues arise.
• Whether the debtor has identifiable assets in Cyprus.
• Whether any sanctions or regulatory restrictions affect the parties, assets or transfer of funds.
• Whether urgent interim protection is required.

Earlycoordination between Cypriot and Ukrainian legal counsel is often essential,particularly where expert evidence on Ukrainian procedural law is required.

Howour firm can assist

MichaelVorkas & Partners LLC advises and represents judgment creditors andjudgment debtors in cross-border disputes involving the recognition andenforcement of foreign judgments in Cyprus.

Ourservices include:

• Assessing whether a Ukrainian judgment is capable of recognition in Cyprus.
• Reviewing jurisdiction, service, finality and public-policy issues.
• Coordinating certified documents, translations and Ukrainian-law expert evidence.
• Investigating and identifying assets situated in Cyprus.
• Preparing or defending recognition and registration proceedings.
• Applying for interim protective measures.
• Pursuing execution against bank accounts, shares, immovable property and other assets.

Obtainingearly legal advice can ensure that procedural requirements are satisfied,potential objections are addressed in advance and any available assets areprotected before enforcement begins.

Thispublication provides general information as at July 2026 and does notconstitute legal advice. The recognition and enforceability of any foreignjudgment depend on its terms, procedural history and the particularcircumstances of the case.

For further information you may contact Pantelis Vorkas at p.vorkas@vorkaslaw.com.cy and Paraskevas Kafkaros at p.kafkaros@vorkaslaw.com.cy.