Adoption abroad: translating the adoption judgment and having it recognised in France

By Keran Chaussard, administrator of the Directory of Sworn Translators of France — updated on 6 November 2026

Two stages where translations matter

Before the adoption: the file sent to the country of origin

International adoption requires an approval issued by the French département, followed by an application through an authorised adoption body (OAA) or the French Adoption Agency, under the supervision of the International Adoption Mission. Each country of origin sets its own list of documents, language and formalities:

• French documents are generally apostilled (for countries party to the 1961 Hague Convention) or legalised, then translated into the country’s language
• some countries require the translation itself to be apostilled or legalised, which means the translator’s signature must first be certified
• documents often have a short validity period (criminal records, medical certificates): order them last

After the adoption: having the foreign judgment recognised in France

Full or simple adoption?

French law does not require the adoption to be granted again: a regular foreign decision is in principle recognised. Everything depends on its effects:

• if it completely and irrevocably severs the previous parent-child relationship, it has the effects of a full adoption
• if not, it has the effects of a simple adoption, which can be converted into a full adoption if the required consents were given expressly and with full knowledge of the consequences

The foreign judgment does not always state clearly whether it severs that relationship. This is where the translation is decisive: the court and the prosecutor read the operative part and the reasoning in French.

Transcription by the Nantes public prosecutor

Where at least one of the adoptive parents is French, the simplest route is to request transcription of the adoption judgment in the registers of the Central Civil Registry Office (Service central d’état civil), by applying to the public prosecutor at the Nantes court (tribunal judiciaire de Nantes). The transcription serves as the child’s birth certificate. The prosecutor checks that the procedure was regular, that it complies with French international public policy and that there was no fraud; these checks are lighter when the adoption followed the Hague Convention of 29 May 1993.

Transcription is only possible for an adoption with the effects of a full adoption. An incomplete file, including missing translations, is a ground for refusal.

Court proceedings

If transcription is refused, or if the adoptive parents are unsure about the nature of the adoption, they can apply to the court:

• to challenge the refusal of transcription before the Nantes court
• or through an exequatur action, to have the foreign decision declared enforceable in France and confirmed as having the effects of a full adoption (sometimes called an application to qualify the adoption). The competent court is in principle the specialised court in the court of appeal district where the adoptive parents live; for adoptive parents living abroad, the question arises differently, and the Nantes court is usually the one seised

A lawyer is mandatory. If the application is granted, the court orders transcription in the Nantes registers.

Which documents need translating for Nantes?

• the full adoption judgment, with its operative part and any statements that it is final or enforceable
• the child’s birth certificate: the original certificate and, if the country issues one, the new certificate after adoption
• the consents to adoption given by the parents or legal representative, where they are in the file
• the certificate of conformity under Article 23 of the 1993 Hague Convention, for a Convention adoption
• the apostilles or legalisations on each of these documents

A common example: an adoption judgment granted in the United States and two US birth certificates, all apostilled, to be filed with the Nantes court. Each document is translated into French by a court-appointed expert registered for English, including the apostille.

What the translation must respect

• Completeness: every page, stamp, handwritten note and apostille.
• The child’s names before and after adoption, reproduced exactly, with the spelling used in passports.
• Legal terms: the translation must not describe the adoption as “full” or “simple” if the judgment does not say so; it renders the foreign terms faithfully (final decree of adoption, adoption order, etc.), and the French court draws its own conclusions.
• Dates in the DD/MM/YYYY format, without confusing month and day on US documents.

Planning when you live abroad

Adoptive parents living outside France can send scans to the translator straight away and receive the signed translation electronically, then the paper originals at an address in France or at their lawyer’s office. For a short stay in France, arrange for the translation to be ready before you arrive, so that you can sign and file the application in person.

Finding a translator for an adoption file

The Directory of Sworn Translators of France lets you search for a court-appointed expert translator by language, département, region and court of appeal. Send complete colour scans, including apostilles, and state the court or authority that will receive the translation. The express file submission service lets you hand the request over to the Directory, particularly for a rare language or a short deadline.

Frequently asked questions

Is an adoption granted abroad valid in France?

Yes, in principle, if it is regular: it has the effects of a full adoption if it completely and irrevocably severs ties with the birth family, and those of a simple adoption in other cases.

Who transcribes a foreign adoption judgment?

The public prosecutor at the Nantes court, in the registers of the Central Civil Registry Office, where at least one adoptive parent is French and the adoption has the effects of a full adoption.

Does the foreign adoption judgment need translating?

Yes, if it is not in French: in full and by a court-appointed expert translator, including the apostille or legalisation.

Is a lawyer needed?

Not to request transcription from the prosecutor, but yes for court proceedings such as exequatur.

Can the translation state that it is a full adoption?

No: the translator renders the terms of the judgment faithfully. It is for the prosecutor or the court to determine the effects of the adoption in France.

Sources

• French Civil Code, Articles 370-2-1 to 370-5 (international adoption), as amended by Law No. 2022-219 of 21 February 2022 (in French)
• French Ministry for Europe and Foreign Affairs, International Adoption Mission, “Effets en France des décisions d’adoption étrangères” (2025, in French)
• Hague Convention of 29 May 1993 on Protection of Children and Co-operation in Respect of Intercountry Adoption, Article 23
• Hague Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents
• Rennes Court of Appeal, 10 February 2020 and 28 September 2020, on the jurisdiction of the Nantes courts (commentary, in French)