UK Rome I—application and interpretation


Published by a UUÂãÁÄÖ±²¥ Dispute Resolution expert
Practice notes

UK Rome I—application and interpretation


Published by a UUÂãÁÄÖ±²¥ Dispute Resolution expert

Practice notes
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This Practice Note is for use when determining applicable law where the contract was entered into on or after 1 January 2021.

For contracts entered into before 1 January 2021, a different applicable law regime will be applied by the UK courts. Which regime is applied will depend on the date on which the contract was entered into. For guidance on the different regimes and their interrelationship, see Practice Note: Applicable law regimes.

This Practice Note refers to UK Rome I, Regulation (EC) 593/2008. Originally known as Retained Rome I, since 1 January 2024, it is known as Assimilated Rome I—the change is to the name only and not the provisions within the regulation. Authorities may refer to the regulation using either name and so, for ease of reference, the regulation is referred to as UK Rome I in this Practice Note. For information on assimilated law, see Practice Note: Assimilated law.

This Practice Note provides an explanation as to when and why UK Rome I, Regulation (EC) 593/2008 was introduced. It covers the implementation

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United Kingdom
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Brexit definition
What does Brexit mean?

means: (a) the United Kingdom (UK) ceasing to be a member state of the European Union (EU) and/or the European Economic Area (EEA) on exit day; and/or (b) the commencement, end of[ or variation in] any transitional, trading or other arrangements from time to time between: (i) the UK and the EU and/or EEA (including during any implementation period and IP Completion Day); and/or (ii) the UK and any other country, group of countries, international organisation, bloc or body (including the World Trade Organization) in contemplation of or (directly or indirectly) in connection with the UK’s said cessation of membership;

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