Countries › Costa Rica › Guide › 14. Disputes › Foreign court judgments in Costa Rica: recognition by the cassation chambers, requirements and enforcement

Foreign court judgments in Costa Rica: recognition by the cassation chambers, requirements and enforcement

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Last verified: 2026-10-29 · Status: Stable

A foreign judgment has effect in Costa Rica only after recognition by the competent cassation chamber of the Supreme Court, the Sala Primera for civil and commercial matters. The applicant must show an authenticated copy, an official translation, proper service on the defendant, no exclusive Costa Rican jurisdiction, a connection with Costa Rica, no breach of public policy and no conflicting local case. The decision has no appeal and the judgment is then enforced by the court of the debtor's domicile.

Key facts

Court recognising foreign judgments	Sala Primera (civil and commercial); Sala Segunda (labour, family, succession, insolvency) textLey 9342 art. 99, as of 2026-10-29 · in force
Reciprocity required	not listed among the requirements textLey 9342 art. 99.2, as of 2026-10-29 · in force
Review of the merits	no; requirements are formal plus public policy textLey 9342 art. 99.2, as of 2026-10-29 · in force
Official translation required	yes, if not in Spanish textLey 9342 art. 99.2, as of 2026-10-29 · in force
Exclusive jurisdiction over local real estate	yes yes or noLey 9342 art. 11.2, as of 2026-10-29 · in force

The rule

1. Recognised foreign judgments and awards of any subject matter have res judicata effect in Costa Rica.Ley 9342, Código Procesal Civil, art. 99.1, 2016-02-03 official text · verified 2026-10-29

2. Recognition requires an authentic copy meeting diplomatic or consular requirements (now satisfied by apostille for Convention states), an official translation if not in Spanish, proof that the defendant was lawfully served and, if absent, declared in default under the law of origin, that the matter is not reserved to Costa Rican courts, has a connection with Costa Rica and is not manifestly contrary to public policy, and that no Costa Rican case is pending or decided.Ley 9342, Código Procesal Civil, art. 99.2, 2016-02-03 official text · verified 2026-10-29

3. Each cassation chamber hears recognition in its subject matter, by incidental procedure; there is no appeal and enforcement once ordered cannot be suspended; a rejection on formal grounds can be refiled once cured; the enforcing court is that of the debtor's domicile, or one chosen by the applicant if the debtor lives abroad.Ley 9342, Código Procesal Civil, art. 99.3, 2016-02-03 official text · verified 2026-10-29

4. Costa Rican courts have exclusive jurisdiction over rights in rem on movables and real estate located in Costa Rica, over the constitution, validity, dissolution and resolutions of companies registered in Costa Rica, and over cases between Costa Ricans or local residents with effects in Costa Rica; judgments on these matters will not be recognised.Ley 9342, Código Procesal Civil, art. 11.2, 2016-02-03 official text · verified 2026-10-29

5. Requests for judicial assistance from foreign courts or arbitrators are processed by the competent chamber under treaties or, failing them, national procedure; the chambers only process letters rogatory from judicial bodies.Ley 9342, Código Procesal Civil, art. 100, 2016-02-03 official text · verified 2026-10-29

6. Costa Rica joined the Apostille Convention (in force 14 December 2011), which replaces consular legalisation of foreign public documents from other parties.Ley 8923, art. 1, 2011-02-22 official text · verified 2026-10-29

Worked example

A Florida money judgment against a Costa Rican company is apostilled, translated and filed at the Sala Primera, with proof that the company was served in the US case. If the requirements are met, the Sala grants recognition with no appeal and sends it to the San José civil court where the company is domiciled for enforcement.

Step by step

Obtain an apostilled certified copy of the judgment and proof of service or default.
Commission an official translation into Spanish.
Check that no Costa Rican case on the same dispute is pending and that the matter is not reserved to local courts.
File at the Sala Primera and prepare attachment requests for the enforcement stage.

Common traps

A judgment from a forum chosen by contract is still refused if it concerns Costa Rican real estate or the validity of resolutions of a Costa Rican company.
Defective service abroad is the most common ground of refusal; keep the proof of service on file.
A claim filed abroad does not block a Costa Rican case unless a treaty says so (art. 8.6), so a local judgment can win the race.

Sources

← Enforcing arbitral awards in Costa Rica: local awards, foreign awards under the New York and Panama Conventions, and the Sala PrimeraInvestment protection and investor State arbitration in Costa Rica: ICSID, bilateral investment agreements and CAFTA DR →

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