International estates: which documents need translating, and by whom?

By Keran Chaussard, administrator of the Directory of Sworn Translators of France — updated on 11 October 2026

When does an estate require translations?

There are two situations, and they do not call for the same translations:

• The estate is settled in France, but some documents are foreign: the deceased died outside France, an heir lives abroad, the deceased held an account, an investment or property in another country, or made a will abroad. In this case, foreign documents must be translated into French.
• The estate, or part of it, is settled abroad: property located outside France must be transferred, or a foreign bank asks for proof of heirship. In this case, French deeds (acte de notoriété, certificate of ownership, death certificate) must be translated into the language of the country concerned. The steps are set out in the article on translating a notarial deed for use abroad.

Estate settled in France: the foreign documents to have translated

Depending on the file, the notary may ask for a sworn translation of the following documents if they are not written in French:

• the foreign death certificate, which opens the estate
• the heirs' civil status documents (birth, marriage, divorce), which establish family relationships and marital status
• the will or any other disposition of property upon death made abroad, including a handwritten will
• the foreign marriage contract or matrimonial property regime, which determines what goes to the surviving spouse before the estate is divided
• the foreign document establishing heirship: certificate of inheritance (Erbschein in Germany), grant of probate or letters of administration in the United Kingdom, letters testamentary in the United States
• foreign bank statements, balance certificates and life insurance contracts, which value the assets
• title deeds and valuations of property located abroad
• foreign judgments relevant to the estate (divorce, adoption, guardianship)

Not all of them are needed in every file. The notary will tell you which documents are required, and sometimes only the relevant pages of a long document, such as a multi-page bank statement.

The European Certificate of Succession reduces the need for translation

For estates of persons who died on or after 17 August 2015 and that have a connection with another EU Member State (excluding Denmark and Ireland), the EU Succession Regulation applies. It created the European Certificate of Succession, issued in France by the notary, which allows an heir, legatee or executor to prove their status in all the States concerned.

The certificate is drawn up on a standard form available in every EU language, so its fields do not need translating. However, free-text sections (description of an asset, a clause of a will, specific conditions) may need to be translated if the receiving authority cannot read the language used. The Regulation also exempts documents issued in a Member State under the Regulation from legalisation and the apostille.

For civil status records themselves (death, birth, marriage) issued in an EU country, a multilingual standard form can often replace a translation: see the article on civil status documents from EU countries.

Apostille or legalisation of foreign documents

A public document issued outside the European Union (death certificate, judgment, certificate of inheritance) generally has to be apostilled or legalised in its country of origin before it is presented to the French notary. This formality is separate from translation: have it done before ordering the sworn translation, so that the apostille or legalisation is translated together with the document. The requirements for each country are set out in the country-by-country table.

Difficulties specific to estate documents

• Concepts with no equivalent in French law: probate, executor, trust, joint tenancy or Pflichtteil cannot be translated by hastily equating them with a French concept. The translator must convey the legal meaning without distorting the document, keeping the original term where necessary. Where an EU text sets the terminology, as the Succession Regulation does for "disposition of property upon death", that terminology takes precedence.
• Amounts in foreign currencies: if amounts in a statement or valuation are converted into euros, the exchange rate applied and its date must appear on the translation. Without it, the notary or the tax authorities cannot check the declared values.
• Handwritten wills: difficult handwriting, crossings-out or additions in the margin require a very good-quality copy. The translator will flag illegible passages but will never guess a word.
• Spelling of names: the names of the deceased and the heirs must be identical across all translations and consistent with French civil status records, particularly for names transliterated from a non-Latin script.

Plan ahead for deadlines

The French inheritance tax return must be filed within six months of the death when it occurred in metropolitan France, and within one year when it occurred abroad. After that, late-payment interest may apply.

Obtaining documents abroad, having them apostilled or legalised and then translated can take several weeks. Have each document translated as soon as it is available, without waiting for the file to be complete.

Preparing the file for the translator

• The list of documents required by the notary, so that only what is needed is translated
• complete, legible copies of each document, including apostilles, stamps and marginal notes
• the reference spelling of names, as it appears on French records or documents already translated
• the currency and exchange rate to apply if a conversion into euros is wanted, or a note that none is needed
• the name of the notary's office and your deadline

Entrusting all the documents for the same estate to the same translator ensures consistent terminology and names across documents.

Finding a sworn translator for an estate

For documents intended for a French notary, choose a translator registered as a court-appointed expert on the list of a court of appeal, ideally experienced with legal and notarial deeds. The Directory of Sworn Translators of France lets you search by language, département, region and court of appeal. When an estate involves several languages or the deadline is approaching, the express file submission service lets you send all the documents at once and find an available translator anywhere in France.

Frequently asked questions

Can the notary accept a foreign document without a translation?

They may accept it if they understand the language and the document is simple, or if it is a European multilingual standard form. In most cases, however, they will ask for a sworn translation, particularly for a will, a certificate of inheritance or a bank statement. Check with the notary's office before ordering.

Does the European Certificate of Succession need translating?

Its fields do not, as the form exists in every EU language. The free-text sections may, however, need translating if the receiving authority cannot read the language in which they were completed.

Do foreign bank statements have to be translated in full?

Not necessarily. The notary mainly needs the balance on the date of death and the account details. Ask which pages to translate; a balance certificate as at the date of death is often enough.

Is a will made abroad valid in France?

Its formal validity is assessed under international rules that broadly accept wills made in the form required by the country where they were drawn up. This is a legal question for the notary, not the translator; the translation must faithfully reproduce the text, including crossings-out and additions.

Who pays for translations in an estate?

Three payment arrangements exist in practice: the family pays for the translation when ordering it; the notary's office advances the costs and is then reimbursed from the estate's assets; or the translation is paid by the estate itself, for example when a property is sold. The choice lies with the expert translator, who states in the quote when and by whom they wish to be paid.

Sources

• Regulation (EU) No 650/2012 of 4 July 2012 on jurisdiction, applicable law, recognition and enforcement of decisions and acceptance and enforcement of authentic instruments in matters of succession and on the creation of a European Certificate of Succession
• Commission Implementing Regulation (EU) No 1329/2014 of 9 December 2014 establishing the forms referred to in Regulation (EU) No 650/2012
• Hague Convention of 5 October 1961 on the Conflicts of Laws Relating to the Form of Testamentary Dispositions
• French General Tax Code, Article 641 (deadlines for filing the inheritance tax return)
• Regulation (EU) 2016/1191 of 6 July 2016 on the circulation of certain public documents
• Hague Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents
• Decree No. 2004-1463 of 23 December 2004 on court-appointed experts