Enforcing foreign judgments and arbitral awards in Argentina

Key rules

1. The hierarchy of sources

• Treaties prevail. The rules applicable to situations connected with several national legal systems are determined by the international treaties and conventions in force; only failing those does Argentine domestic private international law apply (Civil and Commercial Code, CCyC, art. 2594). CPCCN art. 517 says the same for judgments: treaty first, then the five domestic conditions.
• The CCyC does not contain a recognition procedure. The private international law title of the CCyC (arts. 2594 onwards) has a general part, including public order (art. 2600), and a chapter on international jurisdiction (arts. 2601 to 2612). It has no chapter on the recognition of foreign judgments as such. The recognition conditions and procedure remain in the procedural codes: the CPCCN for the national courts (arts. 517 to 519), and each province's own code for provincial courts. This matters because the debtor's assets may be in a province whose code differs (unconfirmed).
• Where the CCyC does bite. Several CCyC rules feed directly into the exequatur:
• Public order (art. 2600): foreign law is excluded when it leads to results incompatible with the fundamental principles of public order of the Argentine legal system. This is the yardstick for CPCCN art. 517(4).
• Internationally mandatory rules (art. 2599) of Argentine law override party autonomy and foreign law.
• Interim measures in aid of recognition (art. 2603(c)): Argentine judges may order provisional and protective measures "when the judgment given by a foreign judge must be recognised or enforced in Argentina". Complying with a measure does not commit the court to recognise the final foreign judgment (art. 2603, last paragraph).
• Lis pendens (art. 2604): an Argentine court must suspend a local case with the same object, cause and parties already pending abroad, if the foreign decision is likely to be recognised.
• Choice of forum (arts. 2605 to 2607): in patrimonial international matters the parties may choose foreign judges or arbitrators, unless Argentine courts have exclusive jurisdiction or the choice is prohibited by law. The chosen forum is exclusive unless the parties say otherwise. Prorogation may also be tacit.
• Exclusive Argentine jurisdiction (art. 2609): rights in rem over Argentine real estate; validity of entries in Argentine public registries; registration and validity of patents, trademarks, designs and similar rights filed in Argentina. A foreign judgment on these subjects fails CPCCN art. 517(1).
• Equal treatment (art. 2610): no security or deposit may be imposed on a party because it is a citizen or permanent resident of another State, including foreign companies.
• Cooperation (arts. 2611 and 2612): Argentine judges must give broad judicial cooperation in civil, commercial and labour matters. Communications abroad go by letter rogatory (exhorto), and direct judge to judge communication is allowed if due process is respected.

2. The five conditions of CPCCN art. 517 (no treaty)

Three notes on these conditions.

• Indirect jurisdiction is judged by Argentine rules. Condition 1 refers to "competent court according to the Argentine rules of international jurisdiction". A written forum clause choosing the foreign courts normally satisfies it (CCyC arts. 2605 and 2607). Without a clause, the creditor must point to an Argentine connecting factor that would have given the foreign court jurisdiction: for contract claims, at the claimant's option, the defendant's domicile, the place of performance of any obligation, or a branch that took part in the deal (art. 2650). A New York court that took jurisdiction over an Argentine debtor only because of US contacts that Argentine law does not recognise is the classic weak case.
• "Personally summoned" is a real hurdle. The wording of art. 517(2) is strict. How Argentine courts treat service under the Hague Service Convention, by international courier, or on an agent for service named in the contract, is not settled by the texts in the sources. Whether Argentina is a party to the Hague Service Convention was not verified (unconfirmed). A contractual appointment of a process agent combined with notice to the Argentine domicile is the practical safeguard.
• No review of the merits. Art. 517 lists conditions; it does not authorise the Argentine judge to retry the case. The only door to the substance is public order (condition 4), and it should be narrow (unconfirmed).

3. Procedure for the exequatur (CPCCN arts. 518 and 175 to 187)

• Court. "The first instance judge that corresponds" (art. 518). The code does not say which branch: national commercial courts, national civil courts or federal civil and commercial courts. The answer depends on the parties and the subject (for example, a State party sends the case to the federal courts) (unconfirmed).
• Filing. With the application, file (art. 518): a legalised and translated copy (testimonio) of the judgment; documents proving it is final (ejecutoriada); and documents proving the other art. 517 conditions if they do not appear from the judgment itself (typically proof of service).
• Incident procedure. The exequatur follows the rules for incidents (art. 518, second paragraph):
• The application must be grounded in fact and law, and all evidence must be offered with it (art. 178).
• A manifestly inadmissible application is rejected outright (art. 179).
• Otherwise, the debtor has 5 days to answer and offer evidence (art. 180). Notice is served personally or by cédula within 3 days of the order.
• If evidence requires a hearing, it is set within 10 days of the answer (art. 181), postponable once by up to 10 days (art. 182).
• One court appointed expert at most, no party technical advisers, up to five witnesses per side (art. 183).
• The judge rules once the answer is in, or the evidence is produced (art. 185).
• Mandatory mediation. Pre suit mediation under Law 26.589 does not list exequatur among its exclusions (art. 5 excludes, among others, interim measures, voluntary proceedings and cases where the State is a party). Whether an exequatur must go through mediation is not answered by the texts. One reading is that it falls outside mediation because it is not a new claim on the merits; that is an interpretation, not a rule in the texts (unconfirmed).
• Interim measures while recognition is pending. Available under CCyC art. 2603(c). The CPCCN grounds for prejudgment attachment include a debtor without domicile in Argentina (art. 209(1)) and a claim proved by a document attributed to the debtor (art. 209(2)). A creditor who has a favourable judgment "even if appealed" may also seek attachment during the proceedings (art. 212(3)). A measure obtained before filing lapses automatically if the main application is not filed within 10 days of its execution (art. 207). Attachments and inhibitions recorded in a registry lapse after 5 years unless re registered (art. 207, second paragraph).
• After the exequatur is granted, enforcement proceeds "in the form established for judgments of Argentine courts" (art. 518, third paragraph):
• For a liquid sum: attachment of assets under the executive proceedings rules (art. 502). If the amount needs calculation, the creditor files a liquidation within 10 days, the debtor gets 5 days to object (arts. 503 and 504).
• Summons for sale once the attachment is executed. The debtor must raise and prove defences within 5 days (art. 505).
• Only four defences: falsity of the enforceable title, prescription of the enforceable title, payment, and quita, espera o remisión (reduction, extension or release) (art. 506). They must rest on facts after the judgment or award and be proved by the case file or documents from the creditor (art. 507).
• The ruling dismissing defences is appealable only with devolutive effect if the creditor posts security (art. 509). Other appeals during enforcement are granted with deferred effect (art. 509, second paragraph).
• Then sale or turnover until the creditor is paid (art. 510).
• Using a foreign judgment as a defence, not as a title. When a party invokes the authority of a foreign judgment in a case (for example, res judicata), it has effect only if it meets the art. 517 conditions (art. 519). No separate exequatur is needed, but the same test applies.

4. Treaty regimes for court judgments

Mercosur: Las Leñas Protocol (Law 24.578, BO 27 Nov 1995). Applies to judgments and arbitral awards in civil, commercial, labour and administrative matters given in Brazil, Paraguay and Uruguay (art. 18), and also to damages and restitution in criminal judgments.

• Route. The request is processed by letter rogatory through the Central Authority (art. 19). Procedure and competence follow the law of the requested State (art. 24), so in Argentina the CPCCN applies.
• Conditions (art. 20): authentic in the State of origin; duly translated; given by a court or tribunal competent under the requested State's rules of international jurisdiction; the defendant duly summoned and the right of defence guaranteed; cosa juzgada or enforceable in the State of origin; not manifestly contrary to the requested State's public order. Conditions (a), (c), (d), (e) and (f) must appear from the certified copy of the judgment or award.
• Conflicting proceedings (art. 22): recognition fails if incompatible with an earlier or simultaneous decision in the requested State, or if proceedings between the same parties on the same facts and object were started there before the foreign claim was filed.
• Partial effect is possible on request (art. 23).
• Documents. Documents from courts and other authorities, public deeds and certifications processed through the Central Authority are exempt from legalisation, apostille or similar formalities (art. 26). Public instruments from one State Party have the same evidentiary force in the other (art. 25).
• Security for costs. Citizens and permanent residents of the other States, and their companies, cannot be required to post security (art. 4; see Courts).

Inter-American: Montevideo Convention of 8 May 1979 (Law 22.921, BO 27 Sep 1983). Covers judgments and arbitral awards in civil, commercial and labour proceedings in a State Party (art. 1). For awards, it applies to anything not covered by the Panama Convention of 1975 (art. 1, last paragraph).

• Conditions (art. 2): authentic in the State of origin; duly translated; legalised according to the law of the State where they take effect; given by a court with international competence under the law of the State where they take effect; the defendant notified or summoned in a form substantially equivalent to that accepted by that State; defence ensured; final (ejecutoriado or cosa juzgada) in the State of origin; not manifestly contrary to public order principles and laws of the requested State.
• Documents (art. 3): authentic copy of the judgment; authentic copies proving service and defence; authentic copy of the order declaring it final.
• Partial effect (art. 4); legal aid granted in the State of origin is kept (art. 5); procedure and competence follow the requested State's law (art. 6).
• Who is a party. The list of States Parties and any reservations is kept by the OAS and was not in the permitted sources (unconfirmed). The United States is not shown as a party in any source reviewed; do not assume the Convention helps with a US judgment (unconfirmed).
• What it adds. The Montevideo test is close to CPCCN art. 517, but two points help creditors: "substantially equivalent" service instead of "personally summoned", and a "manifestly" contrary standard for public order.

Other instruments mentioned in practice but not verified. The Montevideo Treaties on International Procedural Law of 1889 and 1940, and any bilateral judicial assistance treaties (for example with Italy, Spain or France), were not in the sources (unconfirmed). Check the Ministry of Foreign Affairs treaty database before filing.

5. Arbitral awards: what changes compared with judgments

The full analysis is on Arbitration. The points that matter for a creditor planning enforcement:

• New York Convention (Law 23.619, BO 4 Nov 1988). Argentina signed on 26 Aug 1958, ratified on 14 Mar 1989, and the Convention entered into force for it on 12 Jun 1989 (UNCITRAL status table, notes (a) and (c)). Law 23.619 art. 2 records three declarations:
• Reciprocity: the Convention applies only to awards made in the territory of another contracting State.
• Commercial reservation: only to disputes from legal relationships, contractual or not, considered commercial under Argentine law.
• Constitutional interpretation: the Convention is to be interpreted in accordance with the principles and clauses of the National Constitution.
• The commonly cited pointer "ratified by Law 23.619 with reservations" is confirmed, with the third declaration added. The Infoleg summary line says the Convention was "signed on 26 August 1988", but art. 1 of the law and the UNCITRAL table give 1958; the summary line is a typo.
• Documents (Convention art. IV): the original or certified copy of the award and of the arbitration agreement, plus a translation certified by an official or sworn translator or a diplomatic or consular agent. Law 27.449 art. 103 asks only for the award, and says the court "may" request a translation.
• Refusal grounds: closed list (Convention art. V; Law 27.449 art. 104). The debtor must prove incapacity or invalid agreement, lack of notice or inability to present its case, excess of mandate, irregular tribunal or procedure, or an award not yet binding or set aside at the seat. The court may refuse on its own for non arbitrability under Argentine law or breach of Argentine international public order (art. 104(b)(II)). That is narrower than the "public order" of CPCCN art. 517(4).
• Pending annulment at the seat. The Argentine court may adjourn and order the debtor to give security (Law 27.449 art. 105; Convention art. VI).
• No more onerous conditions or higher fees than for domestic awards (Convention art. III). This is relevant to the court fee question in the cost section below.
• Mercosur and Montevideo also cover arbitral awards (Las Leñas art. 18; Montevideo 1979 art. 1). A creditor may rely on whichever instrument is more favourable (unconfirmed).
• ICSID awards against a State are enforced "as if they were a final judgment of a court" of the enforcing State (ICSID Convention art. 54(1), approved by Law 24.353), with a copy certified by the ICSID Secretary General (art. 54(2)). Execution follows local rules (art. 54(3)), and immunity from execution is preserved (art. 55).

6. Apostille, legalisation and translation

• Apostille. For public documents issued in a State that is party to the 1961 Hague Convention, the only formality Argentina may require is the apostille issued by the competent authority of the State of origin (Convention arts. 1 to 3, approved by Law 23.458, BO 21 Apr 1987). Court documents are expressly public documents for this purpose (art. 1). The status table of contracting States was not among the permitted sources (unconfirmed).
• What needs an apostille. In practice, each foreign court or notarial document you file: the certified copy of the judgment, the certificate of finality, the proof of service, any foreign notarial power of attorney for your Argentine counsel. A private document such as an ICC award is not itself a public document; the usual route is a notarial certification of the copy or of the signatures, which is then apostilled (unconfirmed).
• Non Hague States. Consular legalisation applies instead (CPCCN art. 518 requires a "legalised" copy). The Montevideo Convention also requires legalisation according to the law of the requested State (art. 2(c)).
• Mercosur shortcut. Documents processed through the Central Authority under Las Leñas need no legalisation or apostille (art. 26).
• Translation. Any foreign language document filed in national courts in CABA must come with a Spanish translation signed by a public translator registered in the jurisdiction where it is filed (Law 20.305 art. 6). The Colegio de Traductores Públicos de la Ciudad de Buenos Aires certifies translators' signatures (art. 10). In the courts, translators' fees in court proceedings are on a statutory scale (arts. 28 to 35) but out of court translation fees are not regulated. Translating a long judgment or award is a real cost item; get a quote early.
• Argentine apostille (for documents going the other way, for example to prove Argentine law or service abroad): ARS 4,500 (US$2.88) per document through the TAD platform, average 30 business days (Ministry of Foreign Affairs service page, held in the notaries sources; see Notaries, apostilles and books).

7. Currency, interest and the dollar question

• The code rule (since DNU 70/2023, BO 21 Dec 2023). A money obligation exists whether or not the currency is legal tender in Argentina. The debtor is discharged only by delivering the agreed quantities in the agreed currency, and judges cannot change the form of payment or the currency agreed by the parties (CCyC art. 765 as replaced by DNU 70/2023 art. 250; art. 766 as replaced by art. 251).
• The procedure code rule. CPCCN art. 520, last paragraph, still says that an executive claim in foreign currency must be brought for the peso equivalent at the official bank rate on the filing date, subject to adjustment on the payment date. Read literally, this clashes with the new art. 765. How courts reconcile the two in enforcement of a US dollar judgment or award is contested and needs case specific advice (unconfirmed).
• Court fee base. For claims in foreign currency the court fee is computed on the peso equivalent "at the exchange rate in force at the time the fee is paid" (Law 23.898 art. 4(a)). Which rate (official or MEP) is not specified (unconfirmed).
• Interest. Post judgment interest under the foreign judgment is part of the amount if the judgment awards it. Interest that exceeds Argentine limits could be attacked on public order grounds (unconfirmed).
• Getting the money out. Turnover of funds in Argentina and transfer abroad are subject to BCRA foreign exchange rules. See the fx section pages. This page does not cover FX access.

8. Prescription

• The debtor may plead prescription of the enforceable title at the enforcement stage (CPCCN art. 506(2)).
• The CCyC generic period is 5 years, unless local legislation provides otherwise (art. 2560), and runs from when the obligation is enforceable (art. 2554). Which period applies to the action to recognise a foreign judgment, and whether it runs from the foreign judgment or from the exequatur, is not stated in the texts (unconfirmed). Do not sit on a foreign judgment.

9. Enforcing against the Argentine State, and what Law 24.488 really says

Law 24.488 (BO 28 Jun 1995) is about foreign States, not Argentina. Its title is "Jurisdictional immunity of foreign States before Argentine courts". Art. 1 says foreign States are immune from the jurisdiction of Argentine courts on the terms of the law. Art. 2 lists the exceptions: express consent by treaty, written contract or declaration (a); counterclaims (b); commercial or industrial activity where Argentine jurisdiction arises from the contract or international law (c); certain labour claims (d); torts in Argentina (e); actions on Argentine real estate (f); succession (g); and proceedings on the validity or interpretation of an arbitration agreement, the arbitral procedure or annulment of an award, where the State agreed in writing to arbitrate a commercial transaction (h). Art. 3 (human rights claims) was vetoed by Decree 849/95 (BO 28 Jun 1995). The law covers immunity from jurisdiction only. It does not regulate immunity from execution against a foreign State's assets in Argentina (unconfirmed). So:

• If your debtor is a foreign State with assets in Argentina, Law 24.488 tells you when the Argentine court may hear the exequatur. Execution against its assets is a separate and harder question, and diplomatic and consular property is protected by the Vienna Conventions (Law 24.488 art. 6).
• If your debtor is the Argentine State, Law 24.488 is irrelevant. The rules are those for judgments against the national State, summarised on Courts:
• Funds and securities allocated to the national budget cannot be attached (Law 24.624 art. 19; Law 11.672 t.o. 2014 art. 165).
• Money judgments are paid within the budget; a judgment notified before 31 July enters the next year's budget, paid in order of notification date (Law 11.672 art. 170).
• Judgments against State companies and mixed companies "can in no case be enforced against the National Treasury" (Law 24.624 art. 21; Law 11.672 art. 166).
• Claims must be notified to the Treasury Attorney (Procuración del Tesoro) (Law 25.344 arts. 6 and 8), and no interim measure may affect the State's resources (CPCCN art. 195).
• ICSID awards against Argentina are to be enforced as final local judgments (Convention art. 54), but the State's immunity from execution is preserved (art. 55), so the budget rules above still apply (unconfirmed).

10. Context: the bondholder and YPF cases

These cases show the reverse situation: foreign creditors pursuing Argentina abroad. They are context for investors, not precedents for an exequatur in Argentina.

• Bond holdouts. Law 26.017 (BO 11 Feb 2005), known as the "lock law", barred the Executive from reopening the 2005 exchange (art. 2) and prohibited any judicial, out of court or private settlement on bonds not tendered (art. 3). Those articles were suspended by Law 26.547 (BO 10 Dec 2009) for the 2010 reopening, which required participants to waive rights "including those recognised by any judicial or administrative judgment, arbitral award" (art. 5), and again by Law 26.886 (BO 23 Sep 2013), according to the Infoleg notes. Law 27.249 (BO 1 Apr 2016) repealed Laws 26.017, 26.547, 26.886 and 26.984 (art. 1), ratified settlement agreements with holders (art. 5), and authorised a base offer of principal plus 50%, capped at the amount of any judgment plus legal interest to 31 Jan 2016 (art. 6). The ratification and several articles entered into force only on confirmation by the US Court of Appeals for the Second Circuit that all injunctions against Argentina had been lifted (art. 2). Whether residual holdout litigation continues is not in the sources (unconfirmed).
• YPF. Law 26.741 (BO 7 May 2012) declared 51% of YPF's Class D shares of public utility and subject to expropriation (art. 7), distributed between the national State and the producing provinces (art. 8), under the general expropriation law 21.499 (arts. 11 and 12). Former shareholders sued Argentina in New York (case Petersen Energía / Eton Park Capital Management v. Argentine Republic and YPF S.A.). Official sources downloaded for this page say:
• The Treasury Attorney's office obtained the suspension of an order to turn over the 51% of YPF shares and the rejection of an attempt to recognise the US judgment in Ireland; an appeal hearing took place before the US Court of Appeals for the Second Circuit on 29 Oct 2025 (argentina.gob.ar news, 5 Nov 2025).
• On 27 Mar 2026 the national government announced a ruling in the United States favourable to Argentina in the YPF case (argentina.gob.ar news, 27 Mar 2026), and on 2 Apr 2026 it reported receiving the legal team that "won the YPF case in the United States courts" (argentina.gob.ar news, 2 Apr 2026).
• The amount of the first instance judgment, the content and scope of the appeal ruling, and whether further review (rehearing or US Supreme Court) is pending are not stated in the official pages downloaded (unconfirmed).
• Why it matters here. The Irish episode is a reminder that recognition is country by country: a US judgment does not travel by itself, and each enforcing State applies its own recognition test. The same logic applies when a foreign creditor brings a judgment into Argentina.

Step by step

1. Check the judgment before you leave the foreign court. Is it final? Does it show how the defendant was served? Does it identify the debtor exactly as it appears in Argentine records (company name and CUIT, or individual's ID)? Ask the foreign court for a certificate of finality and certified copies of the service documents. Fixing these gaps later is slow.
2. Map assets in Argentina. Real estate (property registries by province), shares and quotas (IGJ in CABA or the provincial registry), bank accounts (attachment orders go to banks through the court), receivables from Argentine customers, vehicles. The value of the assets decides which court and which province you will litigate in.
3. Choose the instrument. Mercosur origin: Las Leñas. Montevideo party: Law 22.921 (unconfirmed). Otherwise: CPCCN art. 517. Award: New York Convention or Law 27.449.
4. Paper the file abroad. Certified copy of the judgment; certificate of finality; proof of service; apostille on each (or consular legalisation); a power of attorney for Argentine counsel, notarised and apostilled. For Mercosur, consider the Central Authority route, which avoids apostilles (Las Leñas art. 26).
5. Sworn translation in Argentina. By a public translator registered with the Colegio in CABA (or the relevant provincial body), signature certified by the Colegio (Law 20.305 arts. 6 and 10).
6. Prejudgment attachment (optional but often decisive). Ask the court for an attachment on bank accounts or an inhibition on the debtor's assets (CCyC art. 2603(c); CPCCN arts. 209 and 212). The judge sets a counter security (contracautela). If obtained before filing, file the exequatur within 10 days of execution (CPCCN art. 207).
7. File the exequatur. With all evidence offered in the application (CPCCN art. 178). Pay the court fee (3% or fixed; argue Convention art. III for awards) (unconfirmed).
8. Debtor's answer. 5 days (CPCCN art. 180). Expect objections on jurisdiction, service and public order.
9. Evidence and decision. Hearing within 10 days if needed (art. 181). The judge decides (art. 185). Appeals follow the general rules; incident rulings are usually appealable (unconfirmed).
10. Enforcement. Attachment, summons for sale, 5 days for the four permitted defences (arts. 502, 505 to 507). Then sale or turnover (art. 510).
11. Get paid and repatriate. Payment in the agreed currency where possible (CCyC art. 765); FX access for transfer abroad under BCRA rules.
12. Recover costs. Court regulated fees and the court fee are part of costs payable by the loser (CPCCN art. 68; Law 23.898 art. 10), subject to the 25% cap for first instance costs (CCyC art. 730).

Costs and timelines

Table 1. Which regime applies

Table 2. Statutory deadlines in the exequatur and enforcement

Days under the CPCCN run from notification and exclude non business days (CPCCN art. 156). Days under Law 27.449 are calendar days unless stated otherwise (art. 108).

Table 3. Fees and amounts with an official source (October 2026)

Table 4. Grounds compared: foreign judgment vs foreign award

Table 5. Timeline of norms (Boletín Oficial dates)

Worked examples

Facts. A US software vendor obtains a final money judgment from a New York state court for US$500,000 (principal, interest to date and costs) against an Argentine SA that stopped paying licence fees. The licence agreement chose New York courts and New York law. The SA was served at its Buenos Aires office, appeared through US counsel, and lost on the merits. No appeal was filed in time. The SA has about ARS 1,200 million in bank accounts and owns its office in CABA.

Conversion. US$500,000 × 1,563.90 = ARS 781,950,000 (unconfirmed).

Step 1. Which regime. No judgment treaty with the United States was found (unconfirmed); the Montevideo Convention does not help unless the US is a party (unconfirmed). CPCCN art. 517 applies.

Step 2. The five conditions.

Step 3. Costs in ARS and USD.

How the fee for the exequatur phase itself is set is uncertain: the incident fee rule (art. 47) was vetoed, and courts may treat the exequatur either as an incident, as an enforcement of a judgment (art. 41) or as an independent proceeding on the full scale (unconfirmed). The table therefore shows the full scale and the enforcement scale as bounds. Your own counsel's fees are contractual (Law 27.423 allows fee agreements) and not in any official source.

Step 4. Timeline.

The planning ranges are editorial assumptions to help budgeting. No court statistics were found in the permitted sources. They must be checked with practitioners before publication.

Cost to do it (example 1). Up front: court fee up to ARS 23,458,500 (US$15,000), translation, US apostilles, counter security, own counsel. Recoverable if successful: court fee and regulated fees, up to the 25% cap of ARS 195,487,500 (US$125,000) for first instance costs. Months: about 6 to 12 without appeal (unconfirmed).

What would make this case hard. Change one fact: the contract had no forum clause and the SA never appeared in New York. Now the Argentine court must find a basis under Argentine rules for the New York court's jurisdiction (CCyC art. 2650: place of performance, for example if payment was due in New York), and must be satisfied the SA was "personally summoned" (art. 517(2)) (unconfirmed). Expect a full contested incident and a likely appeal.

Facts. A Spanish engineering company obtains an ICC award seated in Paris against an Argentine industrial SA under a supply and installation contract. The award orders US$2,000,000 in damages and US$250,000 for costs of the arbitration (including ICC administrative expenses and the tribunal's fees advanced by the claimant). Total US$2,250,000. The SA did not challenge the award in France within the time allowed there. Its main assets are a plant in Buenos Aires Province and receivables from Argentine customers.

Conversion. US$2,250,000 × 1,563.90 = ARS 3,518,775,000 (unconfirmed).

Step 1. Which regime. France is a New York Convention State (UNCITRAL status table, note (a)); the award is made in another contracting State and arises from a commercial relationship, so both Argentine declarations are satisfied (Law 23.619 art. 2). The Convention and Law 27.449 arts. 102 to 105 apply. The interest in the Spanish claimant's nationality is limited: what matters is the seat (Paris), not the parties.

Step 2. Documents.

• Original award or certified copy (NYC art. IV(1)(a); Law 27.449 art. 103). ICC awards are notified to the parties as signed originals or copies certified by the ICC Secretariat (unconfirmed).
• The contract containing the arbitration clause, original or certified copy (NYC art. IV(1)(b)).
• Apostille in France on the notarial certification of the copies (unconfirmed).
• Sworn Spanish translation of the award (if in English or French) and the clause (NYC art. IV(2); Law 20.305 art. 6). Translating a long award and its exhibits is one of the larger out of pocket items (unconfirmed).
• Power of attorney for Argentine counsel, notarised and apostilled.

Step 3. Which court. The plant is in Buenos Aires Province. The creditor can (a) seek recognition in the national courts in CABA if the debtor is domiciled there, and then enforce in the province through a letter rogatory, or (b) apply directly to the provincial court where the assets are, under the provincial procedure code (unconfirmed). This page uses national court figures; provincial court fees differ (unconfirmed).

Step 4. Costs in ARS and USD (national courts figures).

Reading the numbers. The creditor's own cash outlay is the court fee (up to US$67,500 if the 3% applies), translation, French formalities, counter security and its own lawyers. The regulated fees in the table are what the court would order the debtor to pay the creditor's lawyers; they are recoverable, but only if the debtor is solvent, and only up to the 25% cap of CCyC art. 730 for first instance costs. Whether the 25% cap applies to fees in an exequatur and enforcement, as opposed to the original "litigation or arbitration", is open (unconfirmed).

Step 5. Defences the SA can raise. Only the Law 27.449 art. 104 / NYC art. V grounds at the recognition stage, then only the four CPCCN art. 506 defences at enforcement (falsity, prescription, payment, release), based on facts after the award and proved by documents (art. 507). An attempt to argue the merits again or to plead Argentine FX restrictions as a reason not to pay in dollars should fail at recognition; the currency question belongs to the enforcement stage (CCyC art. 765) (unconfirmed).

Step 6. Timeline. Same statutory periods as Example 1 (5 day answer, 10 day hearing, 5 day defences). The difference is practical: a provincial plant means a provincial judicial sale and registry steps, which add months (unconfirmed). Planning assumption: 6 to 12 months to recognition and attached receivables turned over if there is no appeal; a further 6 to 18 months if the plant must be sold (unconfirmed).

Cost to do it (example 2). Up front: court fee up to ARS 105,563,250 (US$67,500), or ARS 4,700 if the fixed fee applies; translation; apostilles; counter security; own counsel. Recoverable: court fee and regulated fees, within the 25% cap (ARS 879,693,750; US$562,500). Months: about 6 to 12 to recognition and first collections, longer if real estate must be sold (unconfirmed).

COMPARISON: to be sourced by editor

Practical traps

1. Assuming a US or UK judgment "travels". There is no treaty; CPCCN art. 517 applies in full, including the Argentine test of the foreign court's jurisdiction (unconfirmed).
2. Default judgments. A judgment obtained after service by mail or on a statutory agent, without the defendant appearing, is the weakest kind. Art. 517(2) asks for a personal summons. Plan service with Argentine enforcement in mind from day one.
3. No forum clause. Without a written forum clause, you must prove an Argentine connecting factor for the foreign court's jurisdiction. Draft clauses that choose a forum expressly (CCyC arts. 2605 and 2607) or, better, arbitration seated in a New York Convention State.
4. Exclusive Argentine jurisdiction. Judgments on title to Argentine real estate, Argentine registry entries or Argentine IP registrations will not be recognised (CCyC art. 2609). Sue for money, not for a transfer of Argentine land.
5. Missing finality evidence. CPCCN art. 518 requires proof that the judgment is ejecutoriada. A US judgment that is still within time for a post judgment motion or appeal will be rejected or suspended.
6. The 10 day trap on attachments. A prejudgment attachment obtained before filing lapses if the exequatur is not filed within 10 days of execution (CPCCN art. 207), and the creditor bears costs and damages. Have the full application ready before you attach.
7. Translator in the wrong register. The translation must be signed by a public translator registered in the jurisdiction where it is filed (Law 20.305 art. 6). A translation done abroad, even if certified, may be rejected.
8. Apostille on the wrong document. Apostille each public document (judgment copy, finality certificate, service proof, power of attorney), not only the cover page. Private documents (an ICC award copy) need a notarial step first (unconfirmed).
9. The court fee surprise. If the court applies the 3% fee on the full amount, a large judgment costs a large sum to file. For awards, argue New York Convention art. III. For judgments, there is no equivalent rule (unconfirmed).
10. Dollar or pesos. CCyC art. 765 (after DNU 70/2023) supports payment in dollars; CPCCN art. 520 still speaks of the peso equivalent in executive claims. Expect a fight on the currency of payment and on the exchange rate used (unconfirmed).
11. The State and its companies. Recognition against the national State does not unlock attachment of budget funds (Law 24.624 art. 19). A judgment against a State company is not enforceable against the Treasury (art. 21). Target the company's own commercial assets.
12. Provincial assets, national procedure. CPCCN arts. 517 to 519 bind the national courts. Provincial courts apply their own procedural codes; the conditions are similar in most provinces but must be checked (unconfirmed).
13. Lis pendens trap for debtors (and creditors). If the Argentine debtor sues first in Argentina, CCyC art. 2604 obliges the Argentine judge to suspend only if the foreign case was pending first and its decision is likely to be recognised. A later local judgment can then block recognition under art. 517(5). Race to file matters.
14. Prescription. The debtor can raise prescription of the enforceable title at enforcement (CPCCN art. 506(2)). The period applicable to a foreign judgment is not clear (unconfirmed); act within months, not years.

Recent changes

• 27 Mar 2026 and 2 Apr 2026. The national government announced a ruling in the United States favourable to Argentina in the YPF case and received the legal team (argentina.gob.ar). Scope and finality not in the sources (unconfirmed).
• 5 Nov 2025. Treasury Attorney's office reported the suspension of the order to turn over 51% of YPF shares and the rejection of recognition of the US judgment in Ireland; Second Circuit hearing held on 29 Oct 2025 (argentina.gob.ar).
• 1 Sep 2026. UMA raised to ARS 108,005, which increases every court regulated fee computed in this page (CSJN notice, 21 Oct 2026).
• 21 Dec 2023. DNU 70/2023 replaced CCyC arts. 765 and 766: payment in the agreed foreign currency, and judges may not change the agreed currency. Check whether it remains in force as enacted (unconfirmed).
• 26 Jul 2018. Law 27.449 repealed CPCCN art. 519 bis, so foreign awards no longer go through the foreign judgments regime; arts. 102 to 105 apply to awards from any country.

No change to CPCCN arts. 517 to 519 since the 1981 consolidated text was found in the Infoleg updated text downloaded (unconfirmed).

Pending changes

• New federal procedure code. No bill or enacted text replacing the national procedure code was in the sources (unconfirmed). If a new code is enacted, arts. 517 to 519 may be renumbered or changed.
• Court fee on exequatur. No CSJN acordada or statute found that says whether the 3% fee applies to recognition of foreign judgments or awards (unconfirmed).
• Fee regulation for the exequatur phase. With Law 27.423 art. 47 vetoed, the base for counsel fees in the recognition incident is uncertain (unconfirmed).
• Dollar enforcement after DNU 70/2023. The interplay between CCyC art. 765 and CPCCN art. 520 is unresolved in the sources (unconfirmed).
• Hague Judgments Convention 2019 and Choice of Court Convention 2005. Whether Argentina has signed or ratified either is not in the sources (unconfirmed). If ratified, they would change the analysis for judgments from other parties.
• YPF case. The official pages do not say whether the March 2026 ruling is final (unconfirmed).

FAQ

1. Can I enforce a US court judgment in Argentina? Yes, if it meets CPCCN art. 517: final, from a court competent under Argentine jurisdiction rules, with personal summons and defence, authentic, not against Argentine public order, and not in conflict with an Argentine judgment. No treaty with the United States on judgments was found (unconfirmed).

2. Will the Argentine court reexamine the merits? No. Art. 517 lists conditions only. The merits can come back only through public order, which should be a narrow exception (unconfirmed). For awards, the grounds are a closed list (Law 27.449 art. 104; New York Convention art. V).

3. How long does an exequatur take? The statutory periods inside the incident are short: 5 days to answer, a hearing within 10 days, then a decision (CPCCN arts. 180 to 185). Real elapsed time depends on service, evidence, appeals and the court's workload. No official statistics exist in the sources; the planning range in this page (6 to 12 months without appeal) is an assumption (unconfirmed).

4. What does it cost? Court fee of 3% of the amount if treated as a money claim, or a fixed ARS 4,700 if not (unconfirmed); translation; apostilles; own counsel; counter security if you attach. On US$500,000 the 3% fee is ARS 23,458,500 (US$15,000). Fees regulated for your lawyer are recoverable from the debtor up to the 25% cap of CCyC art. 730.

5. Can I freeze the debtor's assets before the exequatur is granted? Yes. CCyC art. 2603(c) allows interim measures when a foreign judgment must be recognised in Argentina, and the CPCCN attachment grounds apply (arts. 209 and 212). File the exequatur within 10 days of executing a pre filing attachment (art. 207).

6. Does a judgment from Brazil or Uruguay follow a simpler route? Yes. The Las Leñas Protocol (Law 24.578) uses a letter rogatory through the Central Authority (art. 19), requires only "manifest" public order breaches to refuse (art. 20(f)), and exempts documents sent via the Central Authority from apostille (art. 26).

7. Do I need an apostille on the foreign judgment? Yes, if the issuing country is a party to the Hague Apostille Convention (Law 23.458); otherwise consular legalisation. Under Las Leñas via the Central Authority, no. The judgment, the finality certificate, the proof of service and the power of attorney each need it.

8. Do I need a sworn translation? Yes. Foreign language documents filed in national courts in CABA need a Spanish translation by a public translator registered in the jurisdiction (Law 20.305 art. 6). For awards, the New York Convention requires a certified translation (art. IV(2)).

9. Is Law 24.488 relevant if I want to enforce against Argentina? No. Law 24.488 governs the immunity of foreign States sued in Argentine courts. Enforcement against the Argentine State runs into the budget rules (Laws 24.624 and 11.672): no attachment of budget funds, payment through the budget, and no enforcement against the Treasury for State company debts.

10. Can I insist on payment in dollars? The CCyC, as amended by DNU 70/2023, says the debtor is discharged only by paying in the agreed currency and judges cannot change it (art. 765). The procedure code still refers to a peso equivalent in executive claims (CPCCN art. 520). Expect argument on this point and get advice on FX access before collecting (unconfirmed).

11. What defences can the debtor raise after the exequatur is granted? Only falsity of the title, prescription, payment, or reduction, extension or release (CPCCN art. 506), based on facts after the judgment or award and proved by documents (art. 507), within 5 days of the summons for sale (art. 505).

12. My award is from an ICC arbitration seated in Buenos Aires. Is that "foreign"? No. An award seated in Argentina is a local award. It is enforced directly under CPCCN art. 499, and the debtor's remedy is annulment within 30 days under Law 27.449 art. 100 (international arbitration). See Arbitration.

13. What if the debtor started a case in Argentina first? An earlier or simultaneous Argentine judgment blocks recognition (CPCCN art. 517(5)). If the foreign case was filed first and its decision is likely to be recognised, the Argentine judge must suspend the local case (CCyC art. 2604).

Primary sources

• CPCCN, Law 17.454, updated text (t.o. 1981), arts. 175 to 187, 195, 199, 207, 209, 212, 499 to 520:.
• Civil and Commercial Code, Law 26.994, arts. 730, 765, 2554, 2560, 2594 to 2612:.
• DNU 70/2023, arts. 250 and 251:.
• Law 23.619 (New York Convention):.
• UNCITRAL status table, New York Convention:.
• Law 27.449 (International Commercial Arbitration):.
• Law 24.322 (Panama Convention):.
• Law 22.921 (Montevideo 1979 Inter-American Conventions): and.
• Law 24.578 (Las Leñas Protocol):.
• Law 23.502 (Hague Civil Procedure Convention 1954):.
• Law 23.458 (Hague Apostille Convention):.
• Law 24.488 (immunity of foreign States): and.
• Law 27.423 (lawyers' fees), arts. 20, 21, 30, 41, 47:.
• Law 26.017:.
• Law 26.547:.
• Law 27.249:.
• Law 26.741:.
• CSJN homepage, UMA notice (ARS 108,005 from 1 Sep 2026):.
• Ministry of Foreign Affairs apostille service page (fee and time):.
• YPF case, Treasury Attorney talk, 5 Nov 2025:.
• YPF case, favourable ruling announcement, 27 Mar 2026:.
• YPF case, legal team received, 2 Apr 2026:.

Related pages

• Dispute resolution
• Commercial arbitration in Argentina: Law 27.449, the Civil and Commercial Code and enforcing awards
• Argentine courts and litigation: how commercial disputes work
• Investment arbitration against Argentina: ICSID cases, awards and lessons