Power of attorney in a foreign language: how to make it acceptable to a French notary
By Keran Chaussard, administrator of the Directory of Sworn Translators of France — updated on
A power of attorney written in a foreign language must be translated into French by a translator registered as a court-appointed expert with a French court of appeal, and the translator's signature must then be certified (légalisée) at a town hall or by a notary. This certification allows the notary to be sure that the translation really comes from the expert who signed it.
Beforehand, the signature of the person granting the power must itself be authenticated in the country where they sign (local notary, with an apostille or legalisation depending on the country) or at the French consulate. The simplest option is to ask the notary first for a power of attorney template in French.
Conversely, when a foreign notary only sends a template in their own language, it is translated into French, the principal signs the French version before a French notary, and the signed power of attorney is then translated into the language of the destination country. The translator's signature must then be certified, because a document can only be apostilled if every signature on it has been authenticated.
When does a power of attorney need to be translated?
A power of attorney (procuration) allows a person, the principal, to be represented by another, the attorney, who signs a deed on their behalf. Before a French notary, it is common when the principal lives abroad or cannot travel, in particular for:
- the sale or purchase of property in France
- the settlement of an estate: acte de notoriété, certificate of ownership, division of the estate, renunciation
- a gift or a marriage contract
- a mortgage loan or the creation of a security
- a company transaction: transfer of shares, general meeting, appointment
The notary drafts the deed in French and must be able to check precisely the powers given to the attorney. If the power of attorney was drawn up in another language, for example by a foreign notary using their own wording, the notary will require a French translation.
How to avoid translation: start from the notary's template
Before doing anything else, ask the French notary handling the deed to send you their power of attorney template. It is written in French and describes exactly the transaction and the powers required. If the principal signs this document in French, no translation is usually needed: only their signature has to be authenticated.
Some foreign notaries, however, refuse to witness a document in a language they cannot read, or insist on their own form. In that case, the power of attorney is drawn up in a foreign language, or as a bilingual version, and a translation becomes essential.
The steps for a power of attorney in a foreign language
- Have the principal's signature authenticated in the country where they are, usually before a local notary or notary public. They can also sign at the French consulate, which certifies their signature for a consular fee.
- Have the power of attorney apostilled or legalised if the country requires it. Depending on the country, the apostille or legalisation authenticates the foreign notary's signature and seal. Some countries are exempt under an agreement: check the country-by-country table.
- Have everything translated into French by a court-appointed expert translator: the text of the power of attorney, the foreign notary's certificate, the apostille or legalisation, and any stamps and handwritten notes.
- Have the expert translator's signature certified, at a town hall or before a notary (see below).
- Send the French notary the original power of attorney with its apostille, and the original translation bearing the certified signature.
The order matters: if the translation is made before the apostille, the apostille will have to be translated separately, adding cost and delay.
Why certify the translator's signature?
A sworn translation bears the expert's signature and stamp. For a power of attorney, which commits the principal's assets, notaries in practice ask for an extra guarantee: certification of the translator's signature (légalisation de signature or certification matérielle de signature). It confirms that the signature on the translation really is the expert's.
This formality covers the signature only, not the content of the translation. It is carried out:
- at the town hall of the translator's place of residence, free of charge: the translator signs at the counter in front of the official, on presentation of an identity document
- or before a notary, for a freely set fee
The translator therefore has to attend in person. Allow time for this, often one to a few days depending on the town hall's opening hours, and say when requesting a quote that certification is required: not every expert offers it, and some charge for it.
Powers of attorney that must be notarised
For some deeds, a private power of attorney, even with a certified signature, is not enough: the notary requires an authentic power of attorney, drawn up by a notary or by the consulate. This is the case in particular for a gift or a marriage contract, and often for creating a mortgage. The French notary will tell you which form is required: ask before anything is signed, because a power of attorney in the wrong form will have to be redone.
Power of attorney for use abroad: the foreign notary only has a template in their language
The reverse situation is very common. A French citizen has to grant a power of attorney for a deed signed abroad, for example the sale of a property in Croatia. The Croatian notary sends their power of attorney template, but only in Croatian. The principal cannot read Croatian, and a French notary will not witness the signature of a document that neither they nor the signatory understand.
The solution is a round trip of translation:
- Have the foreign template translated into French by a court-appointed expert translator. The principal then knows exactly what they are signing, and the French notary can witness their signature.
- Sign the French version before a French notary, who certifies the signature or draws up an authentic power of attorney, depending on what the destination country requires.
- Have the signed power of attorney and the notary's certificate translated into the language of the destination country, here Croatian.
- Have the expert translator's signature certified on this translation, at the town hall where they live or before a notary.
- Have the whole set apostilled, if the destination country requires it. In France, apostilles have been issued by notaries since 2025.
- Send the originals to the foreign notary.
Certifying the translator's signature is not optional: for a document signed in France to be apostilled, every signature on it must have been authenticated. An apostille only covers public signatures: that of the notary who witnessed the power of attorney, and that of the town hall official or notary who certified the translator's signature. A translation whose signature has not been certified therefore cannot be apostilled, and the file is blocked at that stage.
This is also why the order matters: the translation and the certification of the translator's signature must be done before the apostille, so that a single apostille request covers everything.
Two precautions:
- Check who must produce the final translation. Some countries accept a translation by a French court-appointed expert; others require a local sworn translator, for example a court interpreter registered in Croatia. Ask the foreign notary before ordering.
- Ask whether a bilingual version is accepted. A power of attorney set out in two columns, French and the foreign language, signed once, often avoids the second translation. Many foreign notaries accept this, provided the translation is made by a sworn translator.
Entrusting both translations to the same expert ensures that the version translated back matches the original template word for word: the foreign notary finds exactly the powers they drafted.
Mistakes that lead to a power of attorney being rejected
- Powers that are poorly described: the power of attorney does not precisely identify the property, the price or the transaction. This is a drafting issue the translator cannot fix: they faithfully translate the signed text.
- The principal's signature not authenticated, or a missing apostille for a country that requires one.
- An apostille or certificate left untranslated.
- A translation without certification of the translator's signature, when the notary requires it.
- For a power of attorney intended for use abroad, a translation whose signature has not been certified: the apostille is then refused.
- A mere copy sent by email, when the notary expects the original power of attorney and translation.
- Names spelt differently in the power of attorney, the translation and the identity documents, particularly for names transliterated from a non-Latin script.
Finding an expert translator for a power of attorney
The Directory of Sworn Translators of France lets you search for a court-appointed expert translator by language, département, region and court of appeal. Since certification takes place at the town hall where the translator lives, location matters little: an expert from any region can handle your file from a scan and then post you the original. For an imminent signing, use the express file submission service and state the date of your appointment with the notary.
Frequently asked questions
- Is a power of attorney in English valid before a French notary?
- Yes, provided it comes with a French translation by a court-appointed expert translator, whose signature is in practice certified, and the principal's signature is authenticated, with an apostille if the country requires one.
- Who certifies the sworn translator's signature?
- The town hall where the translator lives, free of charge, or a notary, for a fee. The translator must sign in the presence of the official or the notary.
- Does certifying the translator's signature replace the apostille?
- No. The apostille or foreign legalisation authenticates the signature of the foreign notary who witnessed the power of attorney. Certification of the translator's signature, done in France, only authenticates the expert's signature on the translation. Both are often needed.
- Can a power of attorney be signed at the French consulate?
- Yes. The consulate can certify the principal's signature on a power of attorney in French, or in some cases draw up an authentic power of attorney. As the document is in French, no translation is then needed.
- The foreign notary has sent me a power of attorney in their language: what should I do?
- Have the template translated into French by an expert translator, sign the French version before a French notary, have the signed power of attorney translated into the language of the destination country, have the translator's signature certified, then have everything apostilled if the country requires it. Ask the foreign notary whether they accept a bilingual version and which translator they require for the final translation.
- Why must the translator's signature be certified before the apostille?
- Because a document can only be apostilled if every signature on it has been authenticated. An apostille certifies the signature of a public official, such as a notary or a town hall officer: the translator's signature must therefore be certified first so that the translation can be apostilled together with the power of attorney.
- Will the notary accept a scan of the power of attorney?
- They may accept one to prepare the deed, but they generally require the original power of attorney and translation before the signing. Send the originals in good time.
Sources
- Service-Public, "Legalisation of signature on a private document"
- French General Local Authorities Code, Article L. 2122-30 (certification of signatures by the mayor) (in French)
- Decree No. 2020-1368 of 10 November 2020 on signature certification by ambassadors and heads of consular posts (in French)
- Service-Public, "Legalisation of a public document issued by a foreign authority"
- French Civil Code, Articles 1984 et seq. (agency)
- 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

