Inheritance abroad: the documents to have translated, and in which direction
In an estate with a foreign element, two kinds of translation come up: the foreign records the French notary asks for, to be translated into French, and the French records the foreign authority asks for, to be translated into its language. Top of the list: the death certificate and the records proving the family relationship.
Ask the notary for their list of documents first: they are the one who sets it.
Which country governs the estate?
For deaths occurring since 17 August 2015, a European regulation sets the rule in almost the whole of the EU. The estate is governed by the law of the country where the deceased had their last habitual residence. They could choose, in their will, the law of the country of their nationality.
A French notary applies this regulation even when the other country is outside the EU, such as Morocco or the United States. Within the EU, only Denmark and Ireland are not bound: the French notary treats them as non-EU countries.
For you, the consequence is practical: depending on the country governing the estate, or the one where an asset is located, you will have documents to translate into French, from French, or both ways.
The foreign records the French notary will ask you for
To draw up the deed of heirship (acte de notoriété), which names the heirs, service-public.gouv.fr (the official French administration website) states that the notary needs:
- the death certificate of the deceased;
- the civil-status records proving your relationship to them: birth certificate, family record book…
For the spouse, it is the marriage certificate. If one of these records was issued abroad in another language, the notary will normally ask you for a translation into French, except for the multilingual form described below. Depending on the file, the notary may also ask for a will drawn up abroad or a court judgment, for divorce or adoption for example.
At DocuTrad, you can have the death certificate translated, €30 per page, into French from some twenty languages, including Arabic, Portuguese, Turkish and Russian, from a simple scan.
Death in the European Union: think of the multilingual form
If the death occurred in an EU country, ask for the death certificate with a multilingual standard form, if that country issues one. The EU's e-Justice portal makes it clear: with this form, the authority receiving the document "may require a translation of the public document only in exceptional circumstances".
These records also need no apostille to circulate from one EU country to another. Ask for the form from the authority issuing the certificate: it often means one translation fewer, if the notary considers the form sufficient.
The other way round: French records for abroad
If an asset is located abroad, a bank account in Portugal or a house in Morocco for example, the local authority will want proof that you are an heir. In France, that is the deed of heirship, drawn up by the notary. Ask the foreign authority whether it accepts it as it is.
Within the EU, the notary can also issue a European Certificate of Succession. It is not compulsory and does not replace the deed of heirship, but it serves as proof in the other EU countries that apply the regulation. It only has effect between those countries, not in Morocco or the United States.
These documents are translated into the language of the authority receiving them. The French death certificate can be translated from the same product page, into English, German, Italian, Spanish, Portuguese, Romanian, Arabic, Turkish, Russian or Chinese.
The deed of heirship and the will have no dedicated product page at DocuTrad: for them, request a translation quote and attach the document.
Do you need an apostille or legalisation?
The French Ministry of Foreign Affairs' summary table, updated on 15 September 2026, gives the rule in both directions. Be careful: it is not always the same for civil-status records (column I) and for notarial deeds, such as the deed of heirship or an authentic will (column IV).
- No formality for either: Morocco, Algeria, Senegal, Germany, Italy, Belgium, Romania.
- Exemption for civil-status records, apostille for notarial deeds: Tunisia, United Kingdom.
- Apostille for both: United States, Canada.
- Legalisation for both: Lebanon.
For Spain, Portugal or Poland, the cell for notarial deeds refers to a note: civil-status records are exempt, other documents are apostilled. For any other country, read its row in the ministry's table, notes included.
Exception for the European Union. A document issued in an EU country for an estate, such as a deed of heirship or a European Certificate of Succession, needs no legalisation or similar formality in another EU country (Article 74 of the European regulation). Denmark and Ireland are not concerned.
Who should do the translation?
It is the notary, or the foreign authority, who says in what form they expect the translation. Ask them before ordering.
One case is governed by law: if the estate includes real estate in France and the notary has to register a deed drawn up by a foreign notary or a foreign judgment, the translation must be certified by an interpreter regularly appointed by the courts. At DocuTrad, these translations are entrusted to a translator on a court of appeal's list of experts: mention it when you order.
How much does the translation cost?
- death certificate: €30 per page;
- birth certificate: €27 per page;
- marriage certificate: €34 per page;
- court judgment: €35 per page;
- deed of heirship, will: on quotation.
A death certificate and the birth certificates of two children, one page each: 30 + 2 × 27 = €84. Translations are delivered in digital format within the standard 24 to 48 working hours; if the paper copy is requested, postal delivery costs €15.
In practice
- Ask the notary for their list of documents and, for each one, the language and form of translation expected.
- For a death in the EU, ask for the certificate with the multilingual form; elsewhere, check the apostille or legalisation in the ministry's table.
- Have all the records in the file translated at once, in the right direction.
Frequently asked questions
Is a deed of heirship always needed?
Not always. If the estate is worth less than €5,965, with no real estate, no will and no marriage contract, a certificate signed by all the heirs is enough for the deceased's bank accounts. Otherwise, the deed of heirship is required.
The death occurred in France: does the death certificate need translating?
Not for the French notary, since it is written in French. However, if a bank or foreign authority asks for it, it is translated into their language, often together with the deed of heirship.
Sources
- Regulation (EU) No 650/2012 on succession, Articles 21, 22, 62, 74 and 83, and the French Ministry of Justice circular of 25 January 2016 presenting it
- Decree No 55-22 of 4 January 1955 reforming land registration, Article 4
- Service-public.gouv.fr, proving that you are an heir (certificate, deed of heirship), checked on 1 January 2026
- European e-Justice portal, public documents, and Regulation (EU) 2016/1191, Articles 6 to 8
- French Ministry for Europe and Foreign Affairs, summary table of the current state of treaty law on legalisation, updated on 15 September 2026
