On 17 December 2009, Rome I, a new EU Regulation (Regulation 593/2008/EC on the Law Applicable to Contractual Obligations) came into effect. Accordingly, the courts of all EU Member States other than Denmark will, from now on, apply Rome I to determine the governing law of contractual disputes between parties entered into on or after that date.

The purpose of Rome I is to convert the Rome Convention on the Law Applicable to Contractual Obligations 1980 into a community regulation, whilst at the same time modernising the rules and enhancing certainty as to applicable law by setting down fixed rules. Rome I preserves the basic rule of the Rome Convention that, in the absence of an express choice, the applicable law is the law of the country with which it is most closely connected.