Foreign divorce judgment: translation, apostille and recognition in France

By Keran Chaussard, administrator of the Directory of Sworn Translators of France — updated on 20 October 2026

Why have a foreign divorce recognised in France?

Until the divorce is noted on the French marriage and birth certificates, the French authorities still treat the spouses as married. The consequences are practical:

• you cannot remarry or enter into a PACS in France: the town hall requires a birth certificate bearing a note of the divorce
• difficulties with estates, income tax, social benefits or the sale of jointly owned property
• a French birth certificate that does not reflect your actual situation, which causes problems in any later application

This applies to any French national whose marriage was celebrated in France or recorded in the French registers, and to foreign nationals married in France.

Divorce granted in an EU country

Regulation (EU) 2019/1111, known as “Brussels II ter”, has applied since 1 August 2022 in every Member State except Denmark. A divorce granted in a Member State is recognised without any special procedure, including for updating civil status records (Article 30). The previous Regulation (EC) No 2201/2003 already provided for this for older proceedings.

There is no need to go through the prosecutor: you contact the civil registrar who holds the records to be updated (the town hall where the marriage took place, or the Central Civil Status Service in Nantes for a recorded marriage). The file usually includes:

• a written, dated and signed request
• a copy of the divorce decision
• the certificate issued by the court that granted the divorce, on the European form provided for by the Regulation (Articles 31 and 36)
• full copies of the French records to be updated

Is a translation needed? The European certificate is a standard form, identical in every EU language: only its free-text entries may need translating. The authority may, however, require a translation of the decision itself (Article 91 of the Regulation). In practice, a translation of the judgment by a court-appointed expert avoids any hold-up. No apostille or legalisation is required between Member States.

Divorce granted outside the European Union

For a divorce granted in a non-EU country (or Denmark), updating the records requires a verification of enforceability (vérification d’opposabilité) by the public prosecutor. The competent prosecutor is:

• the prosecutor at the Nantes court if the marriage was celebrated abroad (and recorded in France)
• the prosecutor responsible for the town hall that celebrated the marriage, if it took place in France

The prosecutor checks that the foreign decision meets the conditions of French private international law: jurisdiction of the foreign court, absence of fraud, respect for the rights of the defence and for public policy. If it can be relied on, the prosecutor instructs the registrar to note the divorce. A bilateral agreement may provide specific rules with certain countries.

Documents to provide

• the divorce decision, original or certified copy, and, if it gives no reasons, the document that initiated the proceedings
• proof that it is final: certificate of no appeal, deed of acquiescence or equivalent
• proof of the spouses’ residence and nationality at the time of the proceedings, if not shown in the decision
• full copies of the French civil status records to be updated (marriage, births)
• a translation by a court-appointed expert translator of every foreign-language document
• depending on the country, the apostille or legalisation of the foreign documents

Allow time: processing times at the Nantes prosecutor’s office are often counted in months, or longer. An incomplete or poorly translated file goes back to the end of the queue: one more reason to get the translation right from the start.

Decisions that raise difficulties

Some dissolutions of marriage are in principle refused in France because they conflict with public policy, in particular unilateral repudiation by the husband with no real opportunity for the wife to defend herself (French Court of Cassation, First Civil Chamber, 17 February 2004). An administrative or religious divorce granted without a judge may also raise questions. In these situations, advice from a lawyer specialising in international family law is recommended before taking any step.

What must the translation of the judgment include?

A divorce judgment is a dense legal document. Its translation must be faithful and complete:

• the whole judgment, not just the operative part: reasons, parties, dates, court
• the notes of finality, stamps, marginal notes and register numbers
• the apostille or legalisation, which forms part of the document
• the certificate of no appeal or its equivalent, if written in a foreign language

Legal vocabulary does not map word for word from one system to another: “dissolution of the marriage”, “custody”, “maintenance” or “compensatory payment” have precise French equivalents. For a judgment, choose an expert used to court decisions from that country. Give them the spelling of names as it appears on the French records, to avoid any discrepancy with the marriage certificate.

In the other direction: using a French divorce abroad

You divorced in France and need to prove it abroad (remarriage, updating the other country’s civil records, an administrative procedure):

1. Obtain the French documents: a copy of the divorce judgment and a certificate of no appeal, or a birth certificate bearing a note of the divorce, depending on what the country requires.
2. Have them apostilled if the country applies the Hague Convention (consular legalisation otherwise). Since 2025, apostilles have been issued by French notaries.
3. Have them translated, together with their apostille, by a court-appointed expert translator, if the country accepts a translation made in France.
4. Have the translator’s signature certified, then the translation apostilled, if the country requires it: every signature on a document to be apostilled must first be authenticated.

Special case: divorce by mutual consent without a judge, available in France since 2017, takes the form of an agreement signed by the spouses’ lawyers and filed with a notary. There is therefore no judgment. Some non-EU countries do not recognise this type of divorce: check with the authorities of the country concerned before starting. Within the European Union, the agreement circulates with a certificate issued by the notary.

Common mistakes

• Translating only the operative part of the judgment instead of the full decision.
• Forgetting proof of finality, or not having it translated.
• Translating before the apostille: the apostille will then need translating separately.
• Sending an EU divorce to the Nantes prosecutor, when the civil registrar is competent.
• Waiting until you plan to remarry to start, when the verification can take months.

Finding a translator for a divorce judgment

The Directory of Sworn Translators of France lets you search for a court-appointed expert translator by language, département, region and court of appeal. For a judgment in a rare language or a file with several decisions, the express file submission service lets you entrust the request to the Directory, which passes it to an expert used to court decisions.

Frequently asked questions

Is a divorce granted abroad valid in France?

It can be, but it must be noted on the French civil status records. For a divorce from an EU country (except Denmark), the civil registrar does this directly; for another country, after verification by the public prosecutor.

Who should I contact to have a foreign divorce recognised?

EU divorce: the civil registrar holding the records. Non-EU divorce: the Nantes public prosecutor if the marriage took place abroad, or the prosecutor for the place of marriage if it was celebrated in France.

Does the divorce judgment need translating?

Yes, if it is in a foreign language, by a court-appointed expert translator, together with proof of finality and its apostille or legalisation.

Does a foreign divorce judgment need an apostille?

Not between EU Member States. For other countries, an apostille or legalisation is in principle required, unless a bilateral agreement provides otherwise.

Can I remarry in France without having my foreign divorce recognised?

No: the town hall requires a certificate bearing a note of the divorce. Start the procedure as soon as the foreign divorce is final.

Is a French divorce without a judge recognised abroad?

Within the EU, yes, with a certificate issued by the notary. Outside the EU, some countries do not recognise it: check with the authorities of the country concerned.

Sources

• Regulation (EU) 2019/1111 of 25 June 2019 (Brussels II ter), Articles 30, 31, 36 and 91
• Decree No. 2023-25 of 23 January 2023 on the application of European regulations in family matters
• AGN Avocats, recognition in France of a divorce granted abroad (in French)
• ASFE, “Validation et transcription en France d’une décision de divorce rendue à l’étranger” (in French)
• ASFE, “Délais de la vérification d’opposabilité des divorces prononcés à l’étranger” (in French)
• French Court of Cassation, First Civil Chamber, 17 February 2004 (unilateral repudiation)
• French Civil Code, Article 229-1 (divorce by mutual consent by private agreement countersigned by lawyers)
• Hague Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents