Answer ... In the coming months and years, accession by the European Union and/or Germany to the 2019 Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters will be the most likely source of significant changes to the German recognition and enforcement framework.

Brexit may also have implications on the enforcement of, for example, English judgments in Germany. Therefore, forum selection clauses in favour of English courts should be carefully reconsidered. Likewise, as the German courts in enforcement proceedings assess whether the foreign court had jurisdiction to hear the dispute, exorbitant jurisdiction will be considered (critically).