Fiona Pearson has co-authored an article in the respected journal, Corporate Rescue and Insolvency, on the Hague Convention on Choice of Court Agreements. In summary, as a Member State of the European Union, the United Kingdom participates in a number of agreements relating to jurisdiction and enforcement in civil and commercial matters, principally the Brussels Regulation, the Brussels Regulation (recast) and the Lugano Convention. Those agreements will, however, cease to apply to the UK when it leaves the EU. The Hague Convention, to which the UK is currently a party by proxy as a Member State of the EU, will instead – following the UK’s accession to that Convention in its own right – provide a basis for the recognition of jurisdiction and enforcement in the future. However, not a like-for-like replacement or watertight solution.
You can access a copy of their article here, with kind permission from LexisNexis.