With the transition period following the UK’s exit from the EU having ended on 31 December, and no information on whether, and if so when, the UK might join the Lugano Convention 2007, attention has turned squarely to the Hague Convention on Choice of Court Agreements 2005.
Where this Convention applies (that is, where there is an exclusive jurisdiction clause in favour of the courts of a contracting state), the position regarding jurisdiction and enforcement between the UK and the EU is similar (although not identical) to the position under the Recast Brussels Regulation (1215/2012) (RBR). A court must accept jurisdiction where it is the chosen court (and more importantly decline jurisdiction when it is not) and it must enforce judgments from other Convention countries, with limited defences to enforcement available.