Freezing Orders: A Practical Deep Dive After the CPR Part 25 Reform

In this session we will undertake a comprehensive walkthrough of freezing orders—crucial and powerful tools in a debt-recovery specialist’s toolkit. We will begin by revisiting the fundamentals: what a freezing order (often known as a “freezing injunction”) is, when and how it can be obtained, and the role it plays in protecting assets from dissipation pending litigation or enforcement. We will then move into the full process of obtaining one: the procedural steps, timing, evidential thresholds, the duty of full and frank disclosure, undertakings, standard model orders, and enforcement considerations. A major focus of the session will be on the recent reform to Civil Procedure Rules Part 25, which came into effect on 6 April 2025.

Attendees will gain insight into how the rules have been reorganised (into six clear sections), how the model orders for freezing injunctions and proprietary & freezing orders have been updated, and what the practical implications are for drafting, service, hearings and defence. Alongside the procedural overhaul, we will explore key recent case-law and legislative updates that affect freezing relief, especially in the debt recovery context.

The session will combine theory and worked examples, so that both junior practitioners and experienced debt-recovery solicitors walk away with actionable guidance on making or resisting freezing orders in the current regulatory environment.

Top 3 Things Facts From the Webinar:

1. The 2025 reforms have reorganised Part 25 into six sections and introduced dedicated rules (25.12–25.14) governing freezing injunctions. Practitioners must now navigate a clearer but more prescriptive framework, with updated model orders and enhanced disclosure obligations. Understanding these structural and procedural changes is essential for ensuring applications comply fully with the new regime.

2. Courts continue to stress that freezing relief is exceptional and requires meticulous evidence of a real risk of asset dissipation. Under the reformed rules, the court’s scrutiny of full and frank disclosure and undertakings is even tighter. Successful practitioners will know how to present robust, proportionate applications supported by carefully verified facts.

3. Despite procedural tightening, the freezing order remains one of the most effective tools in debt enforcement—particularly where assets are movable or at risk of concealment. The updated rules and recent case law reinforce how freezing orders can be integrated into a strategic recovery plan, whether for securing judgment debts, safeguarding assets pending enforcement, or leveraging settlement.

Who This Is For:

Level of Expertise:

All Levels – this can be picked up throughout anyones professional career regardless of experience.

CPD Hours:

This webinar provides you with 1 hour of learning.

Attendees will receive a CPD certificate upon completion of this course.

Learning Objectives

1. Explain what a freezing order is, its purpose and how it fits into the debt-recovery process.
2. Identify the legal and evidential tests that must be satisfied when applying for a freezing order under the updated Part 25.
3. Navigate the re-written structure of CPR Part 25 (Sections I–VI) and recognise the rules specifically applicable to freezing injunctions (Section III: Rules 25.12-25.14).
4. Understand and apply the updated model orders for freezing injunctions and proprietary & freezing injunctions, including how to draft, modify and flag deviations from the model.
5. Advise clients (claimants or defendants) on procedural strategy: selecting the right form of relief, timing (without-notice vs return date), required evidence (including duty of full and frank disclosure) and undertakings.
6. Recognise how the recent amendments affect enforcement risk, third-party banks/trustees, overseas assets and cross-border considerations in a debt recovery setting.
7. Draft a clear plan for monitoring compliance with a freezing order (and responding to breaches) including enforcement steps available to a creditor.
8. Critically assess common pitfalls in freezing order applications (and defences) under the new rules — and identify what best practice looks like in 2025.