Chapters in this guide
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Israel’s recognition and enforcement of foreign civil court judgments is governed primarily by the Enforcement of Foreign Judgments Law (1958) (the “Enforcement Law”), which establishes the conditions for declaring a foreign judgment enforceable in Israel, a limited set of defenses against enforcement, and a reciprocity requirement. Once declared enforceable, a foreign judgment is treated as an Israeli judgment for purposes of execution under the Execution Law (1967) (the “Execution Law”).
Under the Enforcement Law, the court examines whether the statutory conditions are met and whether any statutory defenses apply. When the declaration of enforceability is granted, collection may proceed before the Execution Office using ordinary domestic enforcement tools.
What are the main international treaties or conventions that apply?
The main framework applicable to the recognition and enforcement of foreign court judgments in Israel is the Enforcement Law.
Israel is a signatory to several international treaties and conventions relating to the recognition and enforcement of foreign judgments. However, pursuant to Israeli law, treaties generally require domestic implementing legislation to have direct effect. In the absence of such legislation, courts rely on the Enforcement Law as controlling law. Where possible, courts will interpret it so as to avoid contravening the provisions of treaties and conventions to which Israel is a party.
For example, Israel has signed the Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters (2019) but has not yet ratified or implemented it. A draft law to this effect is still pending in the Knesset (Israeli Parliament). Until it is implemented in Israeli law, it does not apply to the recognition and enforcement of foreign judgments in Israel.
Additionally, Israel has also signed four bilateral conventions on the recognition and enforcement of foreign judgments with Austria, Germany, Spain and the United Kingdom respectively. These conventions were never incorporated into Israeli domestic law and therefore do not replace or supersede the statutory Enforcement Law. They may, however, be used as interpretive aids where statutory provisions are implemented with respect to judgments from a country party to such a bilateral convention.
What legal principles apply if there is no applicable international treaty or convention?
As explained above, the main framework for the recognition and enforcement of foreign judgments in Israel is statutory in nature and is reflected mainly in the Enforcement Law. Key principles include:
- The court will not re-try the merits. It examines statutory conditions and defenses only.
- Conditions for enforceability require proof of foreign court jurisdiction under its own law; finality and non-appealability; executability in the rendering state; no contravention of Israeli public policy; and reciprocity with the country from which the foreign judgment originates.
- A motion should generally be filed within five years of the foreign judgment being handed down (unless otherwise agreed between Israel and the foreign country; and absent special circumstances justifying the delay in filing).
- Once declared enforceable, the judgment is executed as an Israeli judgment under the Execution Law.
These key statutory principles will be explained in more detail below.
Requirements. Under Article 3 of the Enforcement Law (1958), the judgment creditor (i.e., the plaintiff) must prove to the Israeli court that the following conditions are fulfilled:
- The court that issued the judgment maintained the jurisdiction to issue that judgment under the laws of the country where the court is located.
- The judgment is not appealable.
- The obligation in the judgment is enforceable under the laws on enforcement of judgments in Israel, and the contents of the judgment do not contravene public policy.
- The judgment can be executed in the country in which it was issued.
The conditions in Articles 3(1), 3(2) and 3(4) involve questions of applicable foreign law. Since under Israeli law, foreign law constitutes a fact that must be proven, the plaintiff would be required to support his or her arguments with an affidavit by an expert in the law of the jurisdiction where the judgment was issued to establish that these conditions are satisfied. By contrast, the condition for enforcement under Article 3(3) must be satisfied by the plaintiff under Israeli law.
An additional condition to enforcement is stipulated in Article 4 of the Enforcement Law, which states that “a judgment will not be declared enforceable if it was issued in a country according to whose laws Israeli judgments are not to be enforced” (the “Reciprocity Condition”). The burden of proof lies with the respondent to show that the Reciprocity Condition is not fulfilled in practice with regard to a specific foreign country. Israeli courts have generally held that reciprocity exists with countries such as the United Kingdom and the United States, as well as several others.
Time limits. Pursuant to Article 5 of the Enforcement Law, a motion for enforcement must be filed within five years from the date the foreign judgment was rendered.
Defenses. The respondent may object to enforcement under any of the grounds contained in Article 6 of the Enforcement Law:
- A foreign judgment will not be declared enforceable if one of the following is proved:
- the judgment was obtained fraudulently;
- the opportunity provided to the defendant to assert its claims and present evidence before the judgment was rendered was not, in the court's opinion, reasonable;
- the judgment was issued by a court that did not maintain jurisdiction to issue that judgment according to the Private International Laws applicable in Israel;
- the judgment contradicts a different judgment issued on the same matter between the same Parties that is still in effect; and
- when the claim was filed with the court in the foreign country, there was a pending proceeding on the same matter and between the same parties before a court or a tribunal in Israel.
- Concerning sub-article (a)(3), an individual will not be held as having accepted the jurisdiction of the court that issued the foreign judgment (hereinafter: the party obligated by law) solely due to the fact that he presented himself before that court, whether on condition or without condition and argued one or more of the following;
- contested or objected to the jurisdiction of the court;
- argued for the cancelation of the proceedings or their delay for the purpose of transferring the dispute to arbitration or to a court in a different country;
- argued for the release of his property that has been seized or is expected to be seized, or for the protection of such property.
- For this purpose, it makes no difference if, in addition to the arguments stipulated in sub-article (b), the party obligated by law argued substantive arguments concerning the dispute or participated in the proceedings in any other manner, so long as this was done before the court’s final decision concerning the jurisdiction issue was issued.
With regards to Article 6(a)(2), we note that improper service of process in the original foreign proceedings may qualify as a failure to provide the respondent with a reasonable opportunity to present arguments and evidence in the foreign proceedings.
Regarding Article 6(a)(3), it should be noted that Israeli courts generally accept foreign jurisdiction where the defendant resided in the issuing country at commencement (broadly understood), or submitted to the foreign court’s jurisdiction (e.g., by contract, or by participation without preserving a jurisdictional objection).
Israel is an arbitration-friendly jurisdiction. Foreign arbitral awards are recognized and enforced as a matter of course under Israeli law in line with the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (1958).
For international commercial arbitration, Israel has recently also enacted the International Commercial Arbitration Law (2024) which adopts a UNCITRAL Model Law-based framework which expressly anchors the requirements of the New York Convention with regards to recognition and enforcement, and all the defenses contained in its Article V (namely, incapacity/invalid agreement; lack of proper notice/inability to present the case; excess of mandate; composition/procedure not as agreed or as per the law of the seat; award not yet binding or set aside/suspended at the seat; non-arbitrability; and public policy).
For international arbitrations seated in Israel, the award debtor may file a motion to set aside the award on Model Law-based grounds under the International Commercial Arbitration Law. Such challenges must be brought within the statutory time limits set by the new law.
For international arbitrations seated outside Israel, the award debtor may not ask an Israeli court to set aside the award and may only resist enforcement — if sought by the award creditor — on grounds mirroring Article V of the New York Convention.
Israeli courts may grant interim measures in aid of international arbitration and may recognize or enforce interim measures issued by tribunals seated abroad, subject to the applicable statutory conditions.
Court fees. Filing fees for recognition/enforcement applications remain modest and are broadly similar for judgments and awards; approximately a few hundred dollars.
Duration. Where the respondent does not oppose enforcement, Israeli practice suggests that recognition may be completed within approximately six months. Contested cases can often extend materially longer due to evidentiary disputes (e.g., where expert evidence on foreign law/jurisdiction is required), in the range of two to three years. International arbitration matters may move even more efficiently, as objections are confined to the New York Convention‑aligned statutory grounds; however, complex jurisdiction/notice disputes or parallel set‑aside proceedings at the seat can lengthen timelines.
Competent courts. Recognition and enforcement of foreign judgments in Israel generally fall within the jurisdiction of the Magistrates Courts when the value of the judgment does not exceed NIS 2.5 million (approximately USD 750,000), or when the matter concerns certain property-related issues that do not involve questions of ownership. All other applications are heard by the District Courts, unless the subject matter is one that ordinarily falls under the exclusive jurisdiction of the labor courts, family courts or religious courts.
International commercial arbitral awards, including those subject to the New York Convention, are generally brought before the District Courts, unless the nature of the dispute places the matter within the jurisdiction of the labor, family or religious courts.
Once a foreign judgment or arbitral award has been recognized or declared enforceable, execution proceeds before the Execution Office under the Execution Law.
Appeals against orders allowing or disallowing recognition or enforcement of foreign court judgments may be appealed as a matter of right (orders of the Magistrate Courts to the District Courts; and of the District Courts to the Supreme Court) in final matters, or by leave where the decision is interlocutory. An appeal can only stay enforcement if a stay is granted. Stay of execution is discretionary and depends on factors such as prospects of appeal and prejudice to the parties.
For decisions in matters relating to international arbitral awards, court decisions on recognition or enforcement or interim measures remain subject to ordinary judicial review pathways as provided by civil procedure, but no appeal lies on the merits of the arbitral award. As with foreign judgments, enforcement is not stayed by filing an appeal and requires a specific stay order.
Execution Office tools include:
- Ability-to-pay investigation and orders requiring disclosure of assets, income and liabilities. A debtor may be required to appear for an investigation within 21 days of receiving the enforcement warning and must provide full financial disclosure.
- Requests to public authorities (e.g., Population and Immigration Authority for entry/exit data; registries for real estate, vehicles, companies). Where the debtor appears to be abroad, the Execution Office may request automatic notifications from the Population and Immigration Authority regarding the debtor’s return to Israel.
- Orders to financial institutions and third parties to disclose and freeze assets. Attachment orders may be requested before or during proceedings and can be issued ex parte, compelling banks or other third parties to identify, freeze or preserve assets for eventual execution.
Once an attachment is in place and enforcement is later granted, the Execution Office may proceed to sell attached assets to satisfy the judgment.
Sanctions for non-compliance can include restrictions on travel, fines and, in certain cases, imprisonment for debt-avoidance behaviors recognized by law. A debtor who fails to appear for investigation, withholds information or evades payment may be classified as a “debtor avoiding payment”, triggering measures such as credit-reporting consequences, asset seizure and restrictions on leaving the country. The Execution Office may also order asset seizures, liens and sales.
In prolonged non-compliance, the Execution Office may impose more invasive measures, including the sale of registered real estate.
Courts may grant ex parte attachment (freezing) orders against assets in Israel, as well as Mareva injunctions, either pre-action or during proceedings, which may be directed at the debtor or at third parties (such as banks, custodians or counterparties) and serve to freeze assets or debts owed to the respondent so as to secure their availability pending enforcement. Once issued, such attachments restrict the debtor’s ability to deal with the assets and may require third parties to preserve or freeze them; they are commonly granted ex parte and must later be served. If recognition/enforcement is ultimately granted, the attachment enables the Execution Office to seize and sell the assets to satisfy the judgment. Interim injunctions and receivership orders are also available where justified. Territorial reach is limited to assets or third parties within Israel’s jurisdiction; foreign assets require measures in the relevant foreign jurisdiction.
Under the International Commercial Arbitration Law, Israeli courts can also:
- grant interim measures in support of international arbitration (whether the seat is in Israel or abroad); and
- recognize/enforce interim measures issued by arbitral tribunals seated outside Israel, subject to the statute’s conditions.
These measures likewise apply only to assets or persons located in Israel or otherwise subject to Israeli jurisdiction.
Generally, where the debtor is believed to be abroad, the Execution Office may also request updated entry/exit information to anticipate the timing of effective service and collection.
Bank accounts
Third-party attachment orders can be issued to banks to freeze and remit funds to satisfy the judgment. Banks must comply upon service. If the account is pledged or restricted, priority and terms of the pledge may affect proceeds.
Shares
Shares can be attached and sold, including seizure of certificated shares or interests recorded in a securities account. Where a securities account is controlled by a custodian, orders can compel the custodian to freeze and remit or effect sale. The Execution Office may appoint an officer to manage the sale or transfer the shares where necessary. Attachments over equity interests may also extend to dividends or distributions due to the debtor.
Debts due to the judgment debtor from third parties
Garnishment/attachment orders can be served on third-party debtors to freeze and redirect payments. Non-compliance by the third party can lead to liability to the creditor. The order may cover contract receivables and other payment rights.
Real estate
Liens and attachments can be recorded in the land registry. Generally, once an attachment is registered, any later registered transfer or encumbrance is subject to the attachment. If the property is unregistered or held via lease/contractual rights, fixed-charge or assignment enforcement may be pursued against those rights. Statutory protections and priority rules apply. In appropriate cases, real estate may be sold by public auction under supervision of the Execution Office, with proceeds distributed according to statutory and registry priorities.
Movable property
Movable assets (e.g., vehicles, equipment, inventory) can be seized and sold via Execution Office processes or a court-appointed receiver. A seizure order authorizes officers to locate, inventory and remove assets, and may be executed with police assistance if resistance is anticipated. The existence of fixed or floating liens, or negative pledges, with respect to the movable asset, may affect the order of realization and distribution.
Execution in Israel generally targets assets legally owned by the debtor. Enforcement against assets held by another legal person typically requires separate proceedings to establish legal entitlement — such as veil piercing, fraudulent conveyance/avoidance in insolvency, or constructive trust — based on exceptional circumstances (e.g., abuse of corporate form or sham transfers). Mere beneficial ownership, without a legally recognized route to attach the asset, is usually insufficient. In practice, attachment and execution orders apply only to assets or monies that are legally attributed to the debtor or owed to the debtor by a third party; absent such a legal entitlement, enforcement cannot proceed.
Yes, but only to the debtor’s share or interest. Consistent with the general rule that execution may be levied only on assets “owned by” the debtor or monies “owed to” the debtor, enforcement is limited to that share and does not directly reach the co-owner’s portion. The Execution Office or court can attach the debtor’s undivided share, with mechanisms to protect the non-debtor co-owner. In appropriate cases, a sale can be ordered, with proceeds apportioned according to ownership interests. The family home and other statutory protections may apply, and courts assess proportionality and prejudice to co-owners before ordering forced sale.