Singapore Judgment, Korean Debtor: How to Enforce a Singapore Judgment in Korea

Short answer: A Singapore money judgment has no automatic force in South Korea. The creditor must ask a Korean court to recognise and enforce it under Korean law, through Korean counsel. The Memorandum of Guidance signed by the two Supreme Courts on 16 September 2026 explains each court’s procedure, but it creates no new enforcement rights.

If your Singapore company has won a court judgment against a Korean customer, distributor or individual, the hard part is often collecting it. The debtor’s bank accounts, receivables and property are in Korea, and a Singapore judgment cannot be executed there directly. This guide explains how to enforce a Singapore judgment in Korea, what the new Singapore and Korea Memorandum of Guidance does and does not change, and what happens in the reverse case where a Korean company obtains a judgment against your Singapore company.

Raffles Corporate Services works with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice. This article is general information only and is not legal advice.

What did the Singapore and Korean Supreme Courts sign on 16 September 2026?

They signed two instruments: a Memorandum of Guidance on enforcing each other’s money judgments, and a Memorandum of Understanding on exchanging information about each other’s laws. Both were signed in Seoul by Chief Justice Sundaresh Menon and Chief Justice Jo Hee-de of the Supreme Court of Korea, on the sidelines of the 20th Conference of Chief Justices of Asia and the Pacific.

According to the Singapore Courts’ media release of 16 September 2026, the MOG sets out the Singapore and Korean courts’ understanding of the procedures and requirements for recognising and enforcing a money judgment of one country in the other. It is intended as a practical reference for litigants and practitioners, whether they are taking a Singapore judgment to Korea or a Korean judgment to Singapore.

The MOU sets up a court-to-court channel for exchanging information on each country’s laws where a court must consider the other’s law in an ongoing case. It is not a service that private parties can use.

Singapore has signed similar memoranda with, among others, China, Bahrain, Rwanda, Myanmar, Bermuda and Qatar. Earlier memoranda, such as the 2023 Bahrain MOG, state expressly that they are not treaties or legislation and do not bind the judges of either court. Ask your lawyer to confirm the Korea MOG’s exact wording on this point.

Is a Singapore judgment automatically enforceable in Korea?

No. A Singapore judgment must first be recognised by a Korean court, applying Korean law, before it can be used to seize the debtor’s assets in Korea. The MOG explains how this works but does not replace the Korean court process.

The Singapore Courts have said plainly that the MOG “does not create new rights of reciprocal enforcement”. Your rights still come from Korean domestic law and the Korean court’s decision in your case.

Korea has its own statutory conditions for recognising a foreign judgment and its own procedure for obtaining an order that permits enforcement. These typically turn on questions such as whether the Singapore court had jurisdiction, whether the Korean defendant was properly served and had a fair chance to defend, and whether recognition would offend Korean public policy. The precise conditions, and how a Korean judge applies them, are matters for a Korean-qualified lawyer. The MOG itself is the best starting point for that conversation, because it was written by the two courts to explain exactly this.

What a Singapore company can control is the quality of the Singapore judgment it takes to Korea. A judgment obtained after proper service on the Korean defendant, with clear findings and a precise sum, will be easier to defend in Korea than a default judgment entered after doubtful service.

How do you enforce a Singapore judgment in Korea, step by step?

In practice, you obtain the right documents from the Singapore court, authenticate and translate them, instruct Korean counsel to apply to the Korean court, and then enforce against the debtor’s Korean assets once the court allows it. The Singapore-side steps are within your control; the Korean-side steps are run by your Korean lawyer.

1. Confirm the judgment is final and for a fixed sum. Check with your Singapore solicitor whether any appeal or setting-aside application is pending or still possible, and calculate the amount outstanding, including costs and interest awarded.
2. Check where the money is. Before spending on enforcement, gather what you know about the debtor’s Korean bank accounts, customers, property or business premises. A judgment against a company with no assets is a paper win.
3. Extract certified court documents. Your Singapore solicitor obtains certified true copies of the judgment and any related orders, and assembles proof of how the originating claim was served on the Korean defendant.
4. Authenticate the documents. Singapore and Korea are both parties to the Hague Apostille Convention, so an apostille can usually take the place of consular legalisation. Korean counsel will confirm what the Korean court needs.
5. Translate into Korean. Expect Korean counsel to ask for a certified Korean translation of the judgment and key supporting documents.
6. Instruct Korean counsel. Give them the MOG, the documents and a short case summary. They file the application in the competent Korean court and handle any challenge by the debtor.
7. Enforce in Korea. Once the Korean court permits enforcement, Korean counsel can use Korean execution procedures against the debtor’s assets.
8. Close the loop in Singapore. Record recoveries, costs and any write-off in the company’s books, and update the board.

Before committing to steps 4 to 7, compare the cost with what you can realistically recover. A demand letter from Korean counsel citing the Singapore judgment sometimes produces a settlement without any court application.

What documents should a Singapore company prepare?

You need clean evidence of the judgment, how the defendant was served, how much is still owed, and who is authorised to act for your company. Most of this sits with your Singapore solicitor and your company secretary.

Keep a single indexed bundle so that lawyers in two countries are working from the same documents.

How long does it take and what drives the cost?

There is no fixed timetable or price. Time and cost depend mainly on whether the debtor contests recognition in Korea, how quickly documents are authenticated and translated, and how easy the debtor’s assets are to find.

We do not quote Korean court or legal fees, which are set under Korean rules and by individual firms. The table shows the stages and cost drivers to ask about when you get quotes.

These durations are general planning assumptions, not official figures, and they assume the Singapore judgment is final with no pending appeal. If the debtor is in financial difficulty, insolvency proceedings in Korea may change the picture entirely, and Korean counsel should advise on that first.

What if a Korean company has a judgment against your Singapore company?

A Korean judgment cannot be registered in Singapore under the REFJA, because Korea is not a gazetted country. The Korean creditor must start a fresh common law action in the Singapore High Court, suing on the judgment as a debt, usually followed by an application for summary judgment.

The Reciprocal Enforcement of Foreign Judgments Act 1959 applies only to countries named by the Minister in a gazetted order under section 3. On Singapore Statutes Online, the only two orders in force on 18 October 2026 are the Hong Kong SAR order and the Reciprocal Enforcement of Foreign Judgments (United Kingdom and the Commonwealth) Order 2023, whose Schedule lists Brunei, Australia, India, Malaysia, New Zealand, Pakistan, Papua New Guinea, Sri Lanka and the United Kingdom. Korea is not among them, so the registration procedure in Order 60 of the Rules of Court 2021 is not available for a Korean judgment.

The Singapore Supreme Court’s published memoranda with other non-gazetted countries describe how the common law route works in Singapore. Using the 2023 Bahrain MOG as the reference point:

• The foreign judgment must be final and conclusive on the merits, and for a fixed or ascertainable sum of money.
• The foreign court must have had jurisdiction in the Singapore conflict of laws sense. Generally, this means the Singapore company was present or resident there when proceedings began, was itself the claimant or counterclaimant, or submitted to that court’s jurisdiction.
• The judgment can be challenged only on limited grounds, such as fraud, Singapore public policy or a breach of natural justice. The Singapore court will not reopen the merits or correct errors of fact or law.
• The creditor files an originating claim under Order 6 Rule 1 of the Rules of Court 2021, within 6 years of the foreign judgment, and in most contested cases applies for summary judgment under Order 9 Rule 17.

If the Korean creditor succeeds, it holds a Singapore judgment and can use the ordinary Singapore enforcement tools under Order 22, which we explain in our guide to enforcing a court judgment against a Singapore company. For the wider picture, including the REFJA registration route and the Choice of Court Agreements Act 2016, see our earlier guide to enforcing a foreign judgment in Singapore.

If your company is served with such a claim, act quickly. The Rules of Court 2021 set short deadlines for filing a notice of intention to contest and a defence, and a missed deadline can lead to judgment being entered against the company. Court proceedings in Singapore are conducted by a Singapore Advocate and Solicitor, so speak to a lawyer as soon as the papers arrive.

What does the company secretary prepare and what does the solicitor file?

The solicitors in each country handle every court filing and give the legal advice. The company secretary and corporate service provider keep the company’s authorisations, records and accounts in order so that the lawyers can act without delay.

Enforcement itself does not usually require an ACRA lodgement. The company records matter in other ways: the board minutes authorising the action, the treatment of the debt in the financial statements, and any provision or write-off. Our guide to provisioning for bad debts and writing off receivables covers the accounting side. If your company is the defendant to a Korean creditor’s claim, the directors should consider whether the claim needs to be disclosed in the accounts as a provision or contingent liability.

What are the common mistakes?

The most expensive mistakes are treating the MOG as an enforcement treaty, starting in Korea without knowing where the assets are, and arriving with incomplete or unauthenticated documents.

• Assuming the MOG makes the judgment enforceable. It explains the process; it does not create a right to enforcement.
• Relying on a default judgment with weak proof of service. Service and notice are likely to be examined closely in Korea.
• Ignoring time. In Singapore, the Supreme Court’s published guidance describes a 6 year window to sue on a foreign judgment. Korean time limits for your application are for Korean counsel to confirm early.
• Skipping the asset check. Recognition costs money even when the debtor has nothing to seize.
• Commissioning translations before Korean counsel confirms which documents and what certification the court needs.
• For Singapore companies sued on a Korean judgment, ignoring the papers because “it is only a foreign judgment”. Once a Singapore court gives judgment, local enforcement tools such as third party debt orders are available against the company’s bank accounts and receivables.

Frequently asked questions

Does the Singapore and Korea MOG apply to judgments given before 16 September 2026?

The MOG is a guide to how each court approaches money judgments under its existing law, and the Singapore Courts say it does not create new rights. Whether an older Singapore judgment can be recognised in Korea depends on Korean law, so ask Korean counsel to confirm for your specific judgment.

Can I enforce a Singapore order for specific performance or an injunction in Korea under the MOG?

No. The MOG covers judgments requiring payment of a sum of money only. It does not cover non-monetary relief, criminal orders, fines or penalties.

Is Korea covered by the REFJA?

No. As at 18 October 2026, the REFJA orders on Singapore Statutes Online cover Hong Kong SAR and the countries in the United Kingdom and the Commonwealth Order 2023 only. A Korean judgment must be enforced in Singapore by a common law action.

Do I need a Korean lawyer if I already have a Singapore solicitor?

Yes. Recognition and enforcement in Korea happen in a Korean court under Korean law. Your Singapore solicitor prepares the Singapore documents, and Korean counsel runs the Korean proceedings.

Can I recover my legal costs?

Costs awarded in the Singapore judgment form part of the sum you seek to enforce. Whether the Korean court awards the costs of the Korean application is a question for Korean counsel. Budget on the basis that some costs may not be recovered.

For practical calculators and checklists that help with planning and record-keeping, see our free tools.

Last reviewed: 18 October 2026. The Editorial Team, Raffles Corporate Services.