The Foreign Judgments (Reciprocal Enforcement) Act 1933 covers a shortlist of countries that has barely grown in decades. The United States isn’t on it. Nor is Hong Kong, Japan, or most of the countries UK businesses actually trade with outside Europe. Until 27 July 2026, that meant any UK business holding a court judgment from one of those places was in a genuine grey area about whether it could actually be used here against a debtor with assets in England. That grey area has just narrowed considerably, and it is one of three developments from the past fortnight that UK Finance Directors, Credit Managers and business owners should be paying attention to.
A quieter rule change with a bigger reach
The Supreme Court’s ruling in Drelle v Servis-Terminal LLC [2026] UKSC 29 settled a dispute that had run through four different courts over six years. A Russian company was trying to rely on a Russian court judgment to pursue a former director in England. The Court of Appeal had ruled that an unrecognised foreign judgment carried no legal weight here and could not be used to found a bankruptcy petition. The Supreme Court disagreed, unanimously, and reached back to a long-established legal idea called the obligation principle: a foreign judgment for a debt creates an immediate obligation to pay, and that obligation exists in English law whether or not the judgment has gone through any formal recognition process.
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The practical effect is that a UK creditor holding a final judgment from a court with proper jurisdiction abroad can now use it more directly here, including as the basis for a statutory demand, a winding-up petition, or a bankruptcy petition, without first running a separate action to have the judgment formally recognised. That is a meaningful widening of the toolkit for any business that trades internationally and has, at some point, been left chasing a customer or counterparty who has quietly moved assets, or themselves, back to a jurisdiction outside the UK’s usual enforcement routes.
It comes with limits. A debtor can still argue the underlying judgment is disputed, was obtained through fraud, or breaches natural justice, and the Drelle case itself has been sent back to the Court of Appeal to resolve exactly that question. Anyone considering acting on a foreign judgment should still get advice before serving anything on the strength of it. But the starting position has shifted, and it has shifted in the creditor’s favour.
Enforcement is coming, just not yet
The second development is less dramatic on the surface but worth reading carefully. The Insolvency Service published its Annual Plan for 2026 to 2027 on 29 July, setting out what the agency intends to prioritise over the coming year. Buried in the milestones is a commitment to set up a dedicated taskforce specifically to identify and disqualify directors engaged in what the plan calls abusive phoenixism: closing one company owing money and reopening a near-identical one, often at the same address, often with the same suppliers, sometimes within weeks.
Any credit manager who has watched this happen to their own ledger will welcome the taskforce. What is worth noticing, though, is the agency’s own stated target: phoenixism behaviours are expected to be identified in just 10% of disqualification outcomes this year, rising to 20% by 2028-29. Read plainly, that is an admission that the great majority of this conduct will continue to go unaddressed by formal enforcement for the foreseeable future. The plan also confirms the Insolvency Service is absorbing the casework of the former National Investigation Service, which handled Covid-19 loan fraud, and is consulting this year on reform to the wider civil enforcement regime so it can act more quickly against a broader range of misconduct.
None of that is bad news. It is simply a reminder that regulatory capacity builds slowly, and a business extending credit today cannot afford to wait years for a taskforce to catch a director it is already trading with.
What this means for your credit control this week
The third story concerns money owed rather than money never repaid. The Commercial Payments Bill, formerly the Small Business Protections Bill, cleared Committee stage in the House of Lords in late July, with peers unsuccessfully pushing the government to soften its planned ban on cash retention clauses in construction contracts. The government held its position: a phased, two-year transition to a full ban remains in the Bill, alongside a 60-day cap on business-to-business payment terms, mandatory statutory interest of 8% over the Bank of England base rate on late payments, and a new requirement for large companies with poor payment records to publish public commentary explaining what they are doing about it. It is not law yet and will not be before 2027, but the shape of the final Act now looks largely settled.
Taken individually, these are three fairly technical developments: a Supreme Court case about cross-border enforcement, a government agency’s forward plan, and a bill working through Parliament. Taken together, they describe a credit environment that is tilting, gradually and unevenly, in favour of the business that is owed money, provided that business is actually paying attention and using what is available to it. A wider route to enforce foreign judgments does not help if nobody checks where a debtor’s assets actually sit. A phoenixism taskforce does not help a business that extended credit last month to a company sharing a director with one that collapsed six months ago. And a tougher payment framework will not retrieve money that is already overdue under today’s rules.
If any of this sounds like it applies to a customer or supplier relationship you are currently managing, whether that is an overseas debtor who has gone quiet, a construction contract with retention terms you have not revisited in years, or a group of connected companies whose structure you have not fully looked into, it is worth acting on now rather than waiting for the legal landscape to finish shifting. We recently helped a client recover a six-figure debt from a UK company with an international ownership structure after the debtor tried to use a company strike-off and a late dispute to avoid paying; you can read how we secured that outcome in our overseas debt recovery case study, which sets out the practical steps involved in exactly this kind of cross-border recovery.
Downloading our FREE ULTIMATE GUIDE TO DEBT COLLECTION is a good first step. If you want a tailored view on your specific debt, we are happy to give you the straight answer, even if that means advising against legal action. If you’re looking for a partner to step in, you can easily request a transparent quote via our PRICING PAGE.
A short conversation early on can prevent months of delay and avoidable cost later.