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On 31 December 2025, China Justice Observer released the 2025 version of the List of China’s Cases on Recognition of Foreign Judgments. To date, we have collected 120 cases involving China and 26 foreign States and regions. (Note: Foreign divorce judgments are excluded in the Case List.)
The key features of the updated list are:
- The List comprises 26 concise reports for each jurisdiction, together with a chart of bilateral judicial assistance treaties which China has concluded with 39 States, of which 35 bilateral treaties include judgment enforcement clauses.
- A total of eleven newly added cases involve one treaty jurisdiction – Uzbekistan (one case), and five non-treaty jurisdictions, namely, Australia (one case), New Zealand (four cases), Singapore (two cases), South Korea (two cases), and the United States (one case).
- Please note that Tian v Xu [2023] NZHC 3259 marks the first reported instance of a New Zealand court recognizing and enforcing a Chinese civil settlement statement (also known as a mediation judgment). By treating such instruments as equivalent to consent judgments, the New Zealand High Court has adopted a pro-enforcement approach consistent with precedents in Canada (Wei v Li 2019 BCCA 114) and Australia (Bank of China Limited v Chen [2022] NSWSC 749), providing a clear contrast to the earlier restrictive view expressed in Singapore (Shi Wen Yue v Shi Minjiu & Anor [2016] SGHC 137).
- Another noteworthy case is Sunvalley Solar Inc. v Baoding Tianwei Solarfilms Co. Ltd. (2019) Ji 01 Xie Wai Ren No. 3, where a Chinese court refused to enforce a U.S. default judgment rendered in breach of a valid arbitration agreement. By holding that a defendant’s absence does not constitute an implied waiver, the Chinese court shielded arbitration clauses from being bypassed via foreign default judgments.
- Other newly added cases, be it foreign judgments to be enforced in China or Chinese judgments to be enforced in foreign jurisdictions, provide a valuable comparative perspective on key issues in the eyes of courts from different jurisdictions, such as reciprocity ( e.g., the de jure reciprocity applied by a Beijing court in enforcing a South Korean IP judgment, the reciprocal consensus confirmed by a Shanghai court in enforcing a Singapore monetary judgment), natural justice (New Zealand), ascertainment and interpretation of foreign law (Singapore, Australia).
- Each case has been reviewed, and more details, such as the grounds, the case numbers, and causes of action, have been added.
- Case analyses have been aggregated under the country tags since 2022, so it is now easier to track down relevant cases, together with their information and analyses, in each country/region report. For example, under the tag ‘US-China Judgments Recognition and Enforcement’, one can find relevant case analyses involving mutual recognition and enforcement of judgments between the US and China.
We would like to thank the following persons/institutions that shared thoughts and valuable information with us:
- Dr. Béligh Elbalti, Associate Professor, Graduate School of Law and Politics, Osaka University, Japan
- Dr. ZHANG Wenliang (张文亮), Associate Professor, School of Law, Renmin University of China
- Dr. SU Xiaoling(苏晓凌), Lawyer at Beijing DHH Law Firm
- Mr. WANG Chengjie (王成杰), Lawyer at Allbright Law Offices (Shanghai)
- Wonbanglaw (万邦法律）
- Ms. Renee M Wong, Attorney at Goldberger and Dubin PC (New York)
- Dr. WANG Yahan (王雅菡), Associate Professor, Henan University School of Law
- Mr. Angus Ni, Litigation attorney at AFN Law PLLC (Seattle)
- Asian Business Law Institute
- Ms. Dawei Gongsun, Partner at DGW Kramer LLP (New York)
- Mr. Thomas Westaway, Special Counsel at Wynn Williams (New Zealand)
As always, we endeavor to collect all Chinese court decisions involving the recognition and enforcement of foreign judgments (“REFJ”), and foreign counterparts concerning the recognition and enforcement of Chinese judgments. The Case List is made available for our readers to build reasonable expectations on REFJ in China.
The Case List is continually updated with new reports. Case information, comments, and suggestions are most welcome. Please feel free to contact Ms. Meng YU via e-mail at meng.yu@chinajusticeobserver.com.
For an overview of the disposition of cases on recognition and enforcement of foreign judgments between China and treaty-jurisdictions (Italy, France, Turkey, Russia, etc.) and those between China and non-treaty-jurisdictions (USA, Germany, Singapore, South Korea, etc.), please see the tables below.
For information about bilateral judicial assistance treaties that China and 39 States have concluded, please see the table below.
(For the List of China's Bilateral Treaties on Judicial Assistance in Civil and Commercial Matters (Enforcement of Foreign Judgments Included), please click here. Authoritative texts in Chinese and other languages are now available.）
For the detailed country(region) reports about cases on recognition and enforcement of foreign judgments, please see the following charts.
Case information, comments, and suggestions are most welcome. Please feel free to contact Ms. Meng YU via e-mail at meng.yu@chinajusticeobserver.com.
1. America (USA) – China
To date, there are 23 court decisions involving the REFJ between China and the United States of America.
For more information, see case analyses under the tag ‘US-China Judgments Recognition and Enforcement’.
2. Australia - China
To date, there are 10 court decisions involving the REFJ between China and Australia.
For more information, see case analyses under the tag ‘Australia-China Judgments Recognition and Enforcement’.
3. Belarus- China
To date, there are 2 court decisions involving the recognition and enforcement of foreign judgments (“REFJ”) between China and Belarus.
For more information, see case analyses under the tag ‘Belarus-China Judgments Recognition and Enforcement’.
4. British Virgin Islands (BVI) - China
To date, there is one court decision involving the REFJ between China and the British Virgin Islands (BVI).
5. Canada - China
To date, there are 5 court decisions involving the REFJ between China and Canada.
For more information, see case analyses under the tag ‘Canada-China Judgments Recognition and Enforcement’.
For the case info, please see the list above.
6. Chad - China
To date, there is one court decision involving the REFJ between China and Chad.
7. France - China
To date, there are 6 court decisions involving the REFJ between China and France.
For more information, see case analyses under the tag ‘France-China Judgments Recognition and Enforcement’.
8. Germany - China
To date, there are 6 court decisions involving the REFJ between China and Germany.
For more information, see case analyses under the tag ‘Germany-China Judgments Recognition and Enforcement’.
9. Israel - China
To date, there are 2 court decisions involving the REFJ between China and Israel.
For more information, see case analyses under the tag ‘Israel-China Judgments Recognition and Enforcement’.
10. Italy - China
To date, there are 5 court decisions involving the REFJ between China and Italy.
For more information, see case analyses under the tag ‘Italy-China Judgments Recognition and Enforcement’.
11. Japan - China
To date, there are 7 court decisions involving the REFJ between China and Japan.
For more information, see case analyses under the tag ‘Japan-China Judgments Recognition and Enforcement’.
12. Kenya- China
To date, there is one court decision involving the recognition and enforcement of foreign judgments (“REFJ”) between China and Kenya.
For more information, see case analyses under the tag ‘Kenya-China Judgments Recognition and Enforcement’.
13. Malaysia - China
To date, there are 2 court decisions involving the REFJ between China and Malaysia.
For more information, see case analyses under the tag 'Malaysia-China Judgments Recognition and Enforcement'.
14. Myanmar- China
To date, there is one court decision involving the recognition and enforcement of foreign judgments (“REFJ”) between China and Myanmar.
For more information, see case analyses under the tag ‘Myanmar-China Judgments Recognition and Enforcement’.
15. Netherlands - China
To date, there is one court decision involving the REFJ between China and the Netherlands.
For more information, see case analyses under the tag ‘Netherlands-China Judgments Recognition and Enforcement’.
16. New Zealand- China
To date, there are 7 court decisions involving the recognition and enforcement of foreign judgments (“REFJ”) between China and New Zealand.
For more information, see case analyses under the tag ‘New Zealand-China Judgments Recognition and Enforcement’.
17. Poland - China
To date, there are 2 court decisions involving the recognition and enforcement of foreign judgments (“REFJ”) between China and Poland.
For more information, see case analyses under the tag ‘Poland-China Judgments Recognition and Enforcement’.
18. Russia - China
To date, there are 2 court decisions involving the REFJ between China and Russia.
For more information, see case analyses under the tag ‘Russia-China Judgments Recognition and Enforcement’.
19. Singapore - China
To date, there are 10 court decisions involving the REFJ between China and Singapore.
For more information, see case analyses under the tag ‘Singapore-China Judgments Recognition and Enforcement’.
20. South Korea - China
To date, there are 13 court decisions involving the REFJ between China and South Korea. More specifically:
For more information, see case analyses under the tag ‘South Korea-China Judgments Recognition and Enforcement’.
21. Thailand - China
To date, there is 1 court decision involving the REFJ between China and Thailand.
For more information, see case analyses under the tag ‘Thailand-China Judgments Recognition and Enforcement’.
22. Turkey - China
To date, there is one court decision involving the REFJ between China and Turkey.
23. UAE - China
To date, there are three court decisions involving the REFJ between China and the UAE.
For more information, see case analyses under the tag ‘UAE-China Judgments Recognition and Enforcement’.
24. UK - China
To date, there are 4 court decisions involving the REFJ between China and the UK.
For more information, see case analyses under the tag ‘UK-China Judgments Recognition and Enforcement’.
25. Uzbekistan - China
To date, there are 3 court decisions involving the REFJ between China and Uzbekistan.
For more information, see case analyses under the tag ‘Uzbekistan-China Judgments Recognition and Enforcement’.
26. Vietnam - China
To date, there is one court decision involving the REFJ between China and Vietnam.
For more information, see case analyses under the tag ‘Vietnam-China Judgments Recognition and Enforcement’.
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If you would like to discuss with us about the post, or share your views and suggestions, please contact Ms. Meng Yu (meng.yu@chinajusticeobserver.com). If you would like to acquire the full text of these decisions, please also contact Ms. Meng Yu.
If you need legal services for the recognition and enforcement of foreign judgments and arbitral awards in China, please contact Mr. Guodong Du (guodong.du@chinajusticeobserver.com ). Du and his team of experienced attorneys will be able to assist you.
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Contributors: Guodong Du 杜国栋 , Meng Yu 余萌
