Winning a judgment against a debtor in another country is only half the battle. If the debtor, or its assets, are in Singapore, the foreign judgment has no direct force here until it is recognised and enforced by a Singapore court. Singapore has one of the more efficient and creditor-friendly frameworks in the region for doing exactly that, but the route you take depends on where the judgment came from.
This guide explains how a company can enforce a foreign judgment in Singapore in 2026, the three main pathways (statutory registration under the REFJA, the Choice of Court Agreements Act, and the common law action), the documents and timelines involved, and the defences a debtor may raise.
What enforcing a foreign judgment means
Enforcing a foreign judgment means asking a Singapore court to recognise a judgment obtained abroad so that it can be enforced against the debtor’s Singapore assets, using the same tools available for a local judgment. Recognition converts the foreign judgment into something a Singapore court will act on. Enforcement is the follow-on step of actually seizing assets or attaching bank accounts.
Which pathway applies depends on the country of origin and, in some cases, on the type of jurisdiction clause in the underlying contract.
Pathway 1: statutory registration under the REFJA
The primary statutory route is registration under the Reciprocal Enforcement of Foreign Judgments Act 1959 (the REFJA). This is a fast-track procedure available for money judgments from gazetted countries with which Singapore has reciprocal arrangements.
The framework changed significantly on 1 March 2023, when the older Reciprocal Enforcement of Commonwealth Judgments Act 1921 (the RECJA) was repealed and its countries were consolidated into the REFJA. As a result, judgments from jurisdictions such as the United Kingdom, Australia, New Zealand, Malaysia, India, Pakistan, Brunei Darussalam, Papua New Guinea, Sri Lanka and Hong Kong SAR now fall to be enforced under the single REFJA regime.
Under this route, the judgment creditor applies to the General Division of the High Court to register the foreign judgment. Once registered, the judgment has the same effect as a Singapore judgment and can be enforced directly. Registration must be applied for within the time limit prescribed by the statute, so creditors should act promptly.
Pathway 2: the Choice of Court Agreements Act
The Choice of Court Agreements Act 2016 (the CCAA) gives effect to the Hague Convention on Choice of Court Agreements. Where the underlying contract contained an exclusive choice of court agreement in favour of the courts of a Hague Convention contracting state, a judgment from that state can be recognised and enforced in Singapore under the CCAA.
This route is particularly useful for cross-border commercial contracts that name a specific court. If your contracts include exclusive jurisdiction clauses pointing to a Convention state, the CCAA can offer a clean enforcement path independent of the REFJA gazette list.
Pathway 3: the common law action
Where the judgment comes from a country that is neither gazetted under the REFJA nor covered by the CCAA, the creditor must fall back on the common law. Here the foreign judgment is treated as creating a debt. The creditor commences a fresh action in Singapore suing on that debt, and then typically applies for summary judgment because the foreign judgment usually leaves no genuine defence on the merits.
For the common law route to succeed, the foreign judgment must generally be final and conclusive, given by a court of competent jurisdiction over the defendant, and for a fixed sum of money that is not a tax, fine or penalty.
Defences a debtor may raise
Recognition is not automatic. A debtor may resist enforcement on established grounds. These commonly include that the foreign court lacked jurisdiction over the defendant, that the judgment was obtained by fraud, that recognition would be contrary to Singapore public policy, or that the proceedings breached natural justice, for example where the defendant was not properly served or not given a fair chance to be heard.
These defences are narrow and do not allow the debtor to re-argue the merits of the original case. A well-prepared creditor anticipates them and addresses them in the supporting affidavit.
Step-by-step: enforcing in Singapore
1. Identify the country of origin and confirm which pathway applies (REFJA, CCAA or common law). 2. Obtain a certified copy of the foreign judgment and a certified translation if it is not in English. 3. Confirm the judgment is final, for a fixed sum, and enforceable in the originating court. 4. File the registration application (REFJA or CCAA) or commence a common law action, supported by an affidavit. 5. Once recognised, enforce against Singapore assets using local mechanisms, in the same way you would enforce a Singapore judgment for unpaid debts.
Documents you will typically need
| Document | Purpose |
|---|---|
| Certified copy of the foreign judgment | Proves the judgment and its terms |
| Certified English translation (if applicable) | Required where the judgment is not in English |
| Evidence of finality and enforceability | Confirms the judgment is final in the originating court |
| The relevant contract (for CCAA) | Shows the exclusive choice of court agreement |
| Supporting affidavit | Sets out the basis for registration or the common law claim |
Timeline and indicative costs
| Route | Indicative timing | Relative cost |
|---|---|---|
| REFJA registration | Weeks to a few months | Lower, if unopposed |
| CCAA recognition | Weeks to a few months | Lower to moderate |
| Common law action | Several months (longer if contested) | Higher |
Registration under the REFJA or CCAA is usually faster and cheaper than a fresh common law action. Timing depends heavily on whether the debtor opposes recognition. The figures are indicative only.
What happens after recognition
Once the foreign judgment is registered or recognised, it can be enforced against the debtor’s Singapore assets using the full range of enforcement tools, including enforcement orders over property and the attachment of debts such as bank balances. Where the debtor is a company that cannot pay, a creditor may also consider a statutory demand and winding-up route. For insolvency situations that cross borders, see our guide to assistance to foreign insolvency representatives. General procedural guidance is available from the Singapore Courts.
Frequently asked questions
Can any foreign judgment be enforced in Singapore?
Not automatically. Money judgments from gazetted countries can be registered under the REFJA. Others may be enforced under the CCAA or by a common law action, subject to the usual requirements of finality, jurisdiction and a fixed sum.
What happened to the RECJA?
The RECJA was repealed on 1 March 2023. The countries formerly under it, including the United Kingdom, Australia, Malaysia and India, were transferred into the single REFJA regime.
Can the debtor re-argue the original case?
No. Recognition does not reopen the merits. A debtor can only resist on limited grounds such as lack of jurisdiction, fraud, breach of natural justice or public policy.
Do I need a translation of the judgment?
Yes, if the judgment is not in English. A certified translation is required to support the application.
Need Help With This Matter?
If your company is facing this situation, Raffles Corporate Services can assist with the groundwork, including ACRA filings, compliance documentation, and coordinating with experienced Singapore law firms. For matters requiring court proceedings, we work with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice.
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This article is for general information only and does not constitute legal advice. For advice specific to your situation, please consult a qualified Singapore Advocate and Solicitor.
– The Editorial Team, Raffles Corporate Services