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Cross-border Debt Recovery Blog by Marco Sposini

Cross-border Debt Recovery Blog

by Marco Sposini

Laywer, Milan Bar Association

Worldwide debt recovery news


The Court of Justice on Articles 21(2) and 25 of Regulation (EC) No 805/2004

25 June 2026

The Court of Justice of the European Union, by judgment ECLI:EU:C:2026:523, dated 25 June 2026, in Case C-14/25 – in proceedings between Thüringer Aufbaubank, a company which has its registered office in Erfurt (Germany), and LN, concerning the enforcement, in Austria, of an authentic instrument certified as a European Enforcement Order in Germany – ruled that Article 21(2) of Regulation (EC) No 805/2004 creating a European Enforcement Order for uncontested claims, read in conjunction with Article 25 thereof, must be interpreted as precluding a review as to its substance, in the Member State of enforcement, of the certification as a European Enforcement Order in respect of an authentic enforceable instrument by the competent authority of the Member State of origin, even though that instrument was not formally drawn up or registered after the date of the entry into force of that regulation, in disregard of Article 26 thereof.

The text is available here


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