What is the limitation period to enforce a foreign judgment?

In  Commission de la Construction du Québec v. Access Rigging Services Inc., 2010 ONSC 5897 (S.C.J.), the court confirmed that the two-year limitation period under the Limitations Act, 2002, S.O. 2002, c. 24 applies to the enforcement of foreign judgments.

This is consistent with the decision in Lax v. Lax (2004), 186 O.A.C. 20, under the old act, which held:

36          I conclude that because it remains the law that a foreign judgment constitutes a simple contract debt, the six-year limitation in s. 45(1)(g) continues to apply to it. Further, a foreign judgment is not a "judgment" within the meaning of s. 45(1)(c), interpreting that section in accordance with the intention of the legislature when the word "judgment" was added in 1949 and as it has been interpreted and applied by the case law since that time: see para. 11, supra.

Access Rigging involved an application to enforce a judgment from Quebec. The court noted that Quebec is not a member of the Reciprocal Enforcement of Judgments Act, R.S.O. 1990, c. R.5, which provides a six-year limitation period on the enforcement of judgments from reciprocating provinces. The two-year limitation period under the Limitations Act, 2002 therefore applied.