Why international succession requires certified translations
When a deceased person leaves assets in an English-speaking country — the United Kingdom, the United States, Canada or Australia — or when the heirs are resident abroad, the succession procedure inevitably involves documents written in a foreign language. These documents must be translated and certified as conforming by a sworn judicial expert in order to be accepted by the French notary, the relevant courts and the foreign authorities involved.
An uncertified translation — however accurate — will be systematically rejected in any official proceeding.
Documents to be translated in an international succession
The list varies depending on the countries involved and the nature of the assets, but the following documents are most frequently required:
- Death certificate — the foundational document of any succession procedure; to be translated first
- Will — whether handwritten, notarial or a "living will" under Anglo-Saxon law
- Grant of probate or Letters of administration — the English-law equivalents of the French acte de notoriété
- Property title deeds (title deeds, land registry documents)
- Foreign bank account and investment portfolio statements
- Birth and marriage certificates of heirs, to establish inheritance rights
- Foreign court decisions relating to the succession or matrimonial regime
The specific challenge of Anglo-American law
Anglo-Saxon succession law is built around concepts with no direct French equivalent: executor, trustee, probate, intestate succession… A certified translation does more than transpose words: it must accurately render legal concepts in the corresponding French terminology, to avoid any ambiguity before the notary or court.
This is precisely where experience and training matter. My PhD and native familiarity with both legal systems allow me to handle these documents with the precision they require.
Good to know: in international succession matters, EU Regulation No 650/2012 (the "Succession Regulation") determines the applicable law and competent jurisdiction within the EU. Documents from outside the EU (UK post-Brexit, USA, Canada) generally require a certified translation and, depending on the case, an apostille.
How the assignment works
For an international succession, I provide a tailored quote based on the total number of documents, their volume and technical complexity. Here is how we work:
- Send scans of all the documents by email
- I will send you an overall quote within 24 hours
- Once approved, translations are delivered in batches or all at once, according to your needs
- Each translation is provided as a signed PDF; paper copies are available on request
I work directly with notaries and lawyers, and remain available to answer their terminology or procedural questions.
Frequently asked questions
Will the translations be accepted by a British or American notary?
Generally yes, provided they are accompanied by an apostille if required. I will advise on any additional steps depending on the country concerned.
Should documents be apostilled before or after translation?
The apostille is affixed to the original document, not the translation. It is therefore obtained separately from the competent authorities of the issuing country.
Can I have only certain documents translated initially?
Yes, absolutely. I can process documents in order of priority according to the progress of the procedure.