Получается что нет enforcement’а решений англ судов в EU.
European Union, United Kingdom European Union,
United Kingdom February 26 2021
Following the end of the Brexit transition period at 11pm on 31 December 2020 most EU Regulations are no longer applicable in the UK.
This includes the Brussels 1 Regulation (Recast)(1215/2012) which covers the recognition and enforceability of judgments between EU Member States. As the trade agreement established between the UK and the EU does not contain provisions on the enforcement of judgments the UK will look to other conventions to which it is a party and established domestic law to assess whether EU judgments can still be enforced.
UK position post-BrexitNow the Brexit transition period has ended the enforcement of new Irish and other EU member state judgments in the UK will be governed by (i) the Hague Convention and (ii) domestic UK law. The main take-away is that the
party seeking to enforce a non-UK judgment will have to make a full court application to have it recognised and enforced whereas pre-Brexit EU judgments were recognised and enforced through a simple procedural mechanism.