Enforcing a Foreign Judgment or Arbitral Award in China: What Works in 2026

A foreign arbitral award is the most reliable document to bring into China: mainland courts enforce awards under the New York Convention, and any refusal must be reported up to the Supreme People's Court before it takes effect. A foreign court judgment is harder but no longer hopeless, since Chinese courts now accept reciprocity more readily than they once did. Hong Kong judgments and awards, and Taiwan judgments, have their own arrangements. In every case you have two years to apply, and the real question is whether the debtor has assets in China worth chasing.

Winning abroad feels like the end of the dispute. In China it is the start of a second procedure, and a surprising number of creditors lose value in the gap: they wait a year to see whether the debtor pays voluntarily, and by the time they apply, the deadline is close and the assets have moved. The document you hold matters less than what you do in the first three months after you receive it.

First, identify what you actually hold

The route depends on the document. A foreign arbitral award, for example from the ICC, SIAC, LCIA or an ad hoc tribunal seated abroad, goes through the New York Convention. A judgment of a foreign court goes through the Civil Procedure Law's rules on treaties and reciprocity. A Hong Kong court judgment or arbitral award, a Macau decision and a Taiwan judgment or award each have a separate arrangement or set of rules, because the mainland does not treat them as foreign. Before anything else, confirm that the document is final and enforceable where it was made, and that you have a certified copy, proof that the other side was properly notified, and, for an award, the arbitration agreement.

Arbitral awards: the strongest position

China applies the New York Convention with two reservations: it applies only to awards made in other contracting states, and only to disputes considered commercial under Chinese law. You apply to the intermediate people's court where the respondent is domiciled or where its property is located (Civil Procedure Law, Article 304). The court can refuse only on the Convention's limited grounds, such as an invalid arbitration agreement, lack of proper notice, the tribunal exceeding its mandate, or public policy. It does not review the merits.

What makes China more predictable than its reputation suggests is the internal reporting system: a lower court that intends to refuse recognition of a foreign or Hong Kong, Macau or Taiwan award must report to the higher court, and ultimately to the Supreme People's Court, before ruling. In our experience, where the paperwork is in order and notice was properly given, recognition is the normal outcome. The fights are usually about service of notice in the original arbitration and about whether the arbitration agreement actually bound the Chinese party.

Foreign court judgments: reciprocity has opened up

Chinese courts recognise a foreign judgment if there is a treaty between China and the foreign state, or if there is reciprocity (Article 299). China has judicial assistance treaties covering judgments with a number of countries, but not with the United States, the United Kingdom, Canada, Australia, Singapore or most of Europe. For years that left creditors relying on proof that the foreign country had previously enforced a Chinese judgment, a test few could meet.

That has changed. The Supreme People's Court's 2021 symposium minutes accepted a broader approach: reciprocity can be found where the foreign country's law would allow a Chinese judgment to be recognised, or where the two countries have a reciprocity understanding or commitment, even if no Chinese judgment has yet been enforced there. Mainland courts have now recognised judgments from, among others, Singapore, the United States, Germany and the United Kingdom, the last of these in 2022. The 2024 amendments also wrote the grounds for refusal into the law: the foreign court lacked jurisdiction under Chinese rules, the defendant was not properly summoned or could not be heard, the judgment was obtained by fraud, a Chinese court has already ruled on the same dispute, or recognition would violate basic principles of Chinese law or public policy (Articles 300 and 301).

Our view is that recognition of a foreign judgment is now a realistic route, but it is still slower and less certain than enforcing an award, and default judgments are the most vulnerable. If the defendant never took part in the foreign case, expect a close look at how it was served.

Hong Kong and Taiwan

Since 29 January 2024, Hong Kong civil and commercial judgments can be recognised in the mainland under a comprehensive arrangement that covers money and non-money judgments, including many that were outside the older, narrower arrangement for judgments under exclusive jurisdiction clauses. Hong Kong arbitral awards are enforced under a separate arrangement from 2000, supplemented in 2020 to allow parallel applications in both places and preservation measures during enforcement.

Taiwan civil judgments and arbitral awards are recognised under the Supreme People's Court's 2015 provisions. The application goes to the intermediate court where the applicant or respondent is domiciled or where the respondent's property is located. Refusals are uncommon where the Taiwan proceedings were properly conducted and the respondent was duly served.

Timing, assets and what decides recovery

The application period is two years, running from the last day for performance stated in the judgment or award, or from its effective date if no period was stated (Article 250, applied to foreign judgments and awards by the Supreme People's Court's interpretation). Two years sounds long. It is not, once you allow for locating the debtor, obtaining certified copies, apostilles and translations, and briefing Chinese counsel.

Recognition proceedings can take several months to more than a year, and the debtor knows the application is coming. You can ask the court for property preservation during the recognition proceedings, and in most cases you should. See our guide to freezing a Chinese company's assets. What we would not do is start the process without first checking what the debtor owns: its registered capital, shareholdings, real estate, receivables from known customers. A recognised award against a company with nothing left is a costly certificate.

Frequently asked questions

• Can a foreign arbitral award be enforced in China? Yes. China enforces awards from other New York Convention states in commercial matters. Refusal is possible only on limited grounds and must be reported to the Supreme People's Court before it takes effect.
• Can a US or UK court judgment be enforced in China? It can be, on the basis of reciprocity. Since the 2021 Supreme People's Court minutes adopted a broader test, Chinese courts have recognised judgments from the United States, the United Kingdom and other countries without a treaty, but outcomes are less predictable than for arbitral awards.
• What is the deadline to enforce a foreign judgment or award in China? Two years, generally counted from the last day for performance set in the judgment or award, or from its effective date if none was set.
• How are Hong Kong judgments enforced in the mainland? Since 29 January 2024, under the comprehensive Mainland–Hong Kong arrangement on civil and commercial judgments. Hong Kong arbitral awards follow a separate arrangement.

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Related Reading

• How to Freeze a Chinese Company's Assets Before You Sue: Property Preservation in China
• Suing a Chinese Company in a Chinese Court: What Foreign Businesses Should Expect

This article is general information about recognition and enforcement in mainland China as of 28 September 2026 and does not constitute legal advice. Outcomes depend on the document, the jurisdiction where it was made, service of process and the debtor's assets.