Is a sworn translation made in France valid in another EU country? The rule and its exceptions
By Keran Chaussard, administrator of the Directory of Sworn Translators of France — updated on
Yes, in one specific case: for public documents covered by Regulation (EU) 2016/1191 (birth, marriage, death, name, nationality, absence of a criminal record, residence, etc.), a certified translation made by a qualified person in any Member State must be accepted by the authorities of the other Member States (Article 6). A birth certificate translation made by a French court-appointed expert translator must therefore be accepted by a German or Italian registry office, and vice versa.
Outside that scope, there is no automatic recognition of translations between EU countries: for a diploma, a company extract, a power of attorney, a civil or commercial judgment, or before a court, each country applies its own rules. Some require a translator authorised in their own country, or certification of the translator’s signature. Always ask the receiving authority whether it accepts a translation made in France.
The rule: Article 6 of Regulation (EU) 2016/1191
Since 16 February 2019, Regulation (EU) 2016/1191 has simplified the circulation of certain public documents between Member States. It has two parts:
- no apostille or legalisation for the public documents it covers
- no need to have documents translated again: where an authority requires a translation, it must accept a certified translation made by a person qualified to do so under the law of any Member State
In practice, a Spanish birth certificate translated into French by a Spanish traductor jurado must be accepted by a French authority under the Regulation, and a French criminal record extract translated by a French court-appointed expert must be accepted by a Belgian or Portuguese authority. The Regulation also provides multilingual standard forms that can be attached to certain documents and often make any translation unnecessary.
The documents covered
The Regulation applies to public documents issued by an authority of a Member State that establish, in particular:
- birth, death, name, parenthood, adoption
- marriage, capacity to marry, marital status, divorce, legal separation, annulment of marriage
- registered partnership, its dissolution or annulment
- domicile or residence, nationality
- absence of a criminal record
- the right to vote or stand as a candidate in European and municipal elections
The exceptions: when a French translation may be refused
1. Documents outside the Regulation’s scope
Diplomas and transcripts, company extracts and articles of association, notarial deeds of sale, gift or power of attorney, wills, judgments other than divorce judgments, driving licences, passports, private documents (contracts, employer’s certificates, bank statements): for all of these, Article 6 does not apply. The receiving country is free to decide whether it accepts a translation made abroad.
2. Courts
Before a court, national rules of procedure apply. In Germany, for example, the court may require a translation by a translator authorised or publicly appointed under the law of a federal state, or treated as equivalent (Section 142(3) of the German Code of Civil Procedure). In France, the court freely assesses the value of a translation produced by a party and may order a translation by an expert.
3. Authorities that require a formality on the translation
A foreign authority may want to check that the translator is properly authorised. In a real case, a Finnish authority required certification of the signature of the French expert translator for a passport translation, a document not covered by the Regulation. Planning for this step avoids a second round trip.
4. Private organisations
The Regulation is binding on public authorities. A bank, an employer, a private university or an insurer sets its own requirements and may ask for a translator from its own country.
5. The content of the document is not recognised as a result
The Regulation concerns the authenticity of the document and its translation, not the recognition of its legal effects. A marriage or divorce in one country remains subject, in the other, to the applicable recognition rules.
6. Countries outside the European Union
The Regulation does not apply to the United Kingdom since it left the Union, nor to Switzerland, Norway or Iceland. Nor does it cover a document issued by a non-EU country, even if translated in a Member State: a Moroccan document translated in Belgium and then presented in France is subject to French rules.
Translate in France or in the destination country?
| Situation | Advice |
|---|---|
| Civil status document, criminal record, residence certificate for an EU public authority | A translation by a French court-appointed expert must be accepted; first check whether a multilingual form is enough |
| Diploma, company extract, power of attorney, notarial deed | Ask the authority whether it accepts a translation made in France, and whether it requires certification of the translator’s signature or an apostille |
| Proceedings before a foreign court | Ask the local lawyer: a translation by a translator authorised in the court’s country is often safer |
| Foreign document presented in France | A translation by an expert registered with a French court of appeal raises no questions; a translation made in another Member State is accepted for documents covered by the Regulation |
Questions to ask before ordering
- Is the document one of those covered by Regulation (EU) 2016/1191?
- Can a multilingual standard form replace the translation?
- Does the authority accept a translation made by a translator authorised in another Member State?
- Does it require certification of the translator’s signature, or an apostille?
- Does it accept an electronically signed translation, or is the paper original required?
Finding a court-appointed expert translator
The Directory of Sworn Translators of France lets you search for a court-appointed expert translator by language, département, region and court of appeal. State the destination country and the type of authority that will receive the translation in your quote request: the translator can then arrange certification of their signature if required. The express file submission service lets you hand the request over to the Directory.
Frequently asked questions
- Is a French sworn translation valid in Germany, Belgium or Spain?
- Yes for public documents covered by Regulation (EU) 2016/1191, such as civil status documents or criminal records. For other documents, it depends on the receiving authority.
- Is a translation by a foreign sworn translator accepted in France?
- For documents covered by the Regulation, a certified translation made by a qualified person in another Member State must be accepted. For others, French authorities generally ask for a translation by an expert registered with a court of appeal.
- Does the European Regulation always remove the need for translation?
- No. It removes the apostille and makes translation easier, but the authority can still require a translation if the document is not in its language and no multilingual form is sufficient.
- Does the Regulation apply to the United Kingdom or Switzerland?
- No: it applies only between Member States of the European Union.
- Must a foreign court accept a translation made in France?
- Not necessarily: courts apply their own rules of procedure, which may require a translator authorised in their country.
Sources
- Regulation (EU) 2016/1191 of 6 July 2016 on promoting the free movement of citizens by simplifying the requirements for presenting certain public documents, Articles 2, 4 and 6
- Czech Ministry of Foreign Affairs, note on Regulation 2016/1191 (in French)
- Service-Public, “Traduction d’un document : comment trouver un traducteur agréé ?” (in French)
- German Code of Civil Procedure (ZPO), Section 142(3) (in German)
- French Law No. 71-498 of 29 June 1971 and Decree No. 2004-1463 of 23 December 2004 on court-appointed experts
