The Lugano Convention applies between the EU member states and the members of EFTA, Switzerland, Iceland and Norway and covers broadly the same provisions. The procedure of the convention is similar to the Brussels Regulation.
Nevertheless, the enforcing court in Germany may of its own volition refuse the recognition due to the following reasons:
- Right to fear hearing: whether the debtor had sufficient time to respond to the original claim,
- German public order or public policy,
- Judgment is irreconcilable with a judgment given in a dispute between the same parties in Germany.