Certified Translation for Inheritance in France

Certified translation for inheritance in France — do you need documents translated for a French notaire, court or tax authority? Has a family member died in France leaving assets in the UK, the USA or elsewhere? Are you a British, American or Australian heir who needs to present documents to a French notaire? In all these cases, official documents must be translated by a sworn translator accredited by a French Court of Appeal. The translation must bear the official stamp and handwritten signature of that sworn translator to be legally valid.

Tradyx is managed by a sworn translator accredited by the Court of Appeal of Caen, working between French and English. Her certified translations are legally valid throughout France and recognised by UK, US and international authorities.

Inheritance in France: the legal framework

Cross-border inheritance in France is governed by EU Succession Regulation 650/2012, also known as Brussels IV, in force since 17 August 2015. The general rule is simple: the law of the country where the deceased was habitually resident at the time of death applies to the entire estate.

However, the deceased may choose — explicitly in a will — for the law of their nationality to apply instead. A British national resident in France can opt for UK law to govern their estate. Without such a choice, French law applies automatically.

Note that since 2021, a reform to the French Civil Code (Article 913) limits the ability to disinherit children under foreign law. This applies when either the deceased or one of their children is a national or resident of an EU member state and concerns assets located in France.

📌 For further reading: Your Europe guide on managing an inheritance in the EU and Regulation 650/2012 on EUR-Lex.

UK nationals inheriting in France: specific rules

The UK left the EU on 31 January 2020. UK nationals are no longer EU citizens for the purposes of Brussels IV. However, EU Regulation 650/2012 still applies to successions involving French assets — even when the deceased or heirs are British.

A UK national habitually resident in France at the time of death will have their estate governed by French law by default. They may have chosen UK law in their will under Brussels IV. However, the 2021 French reform on forced heirship applies: if one of the deceased’s children is an EU national or resident, that child may claim their French forced heirship share on French assets, regardless of the UK will.

In practice, a certified translation for inheritance in France is required for all documents produced in English — including the will, death certificate, grant of probate and any UK property deeds. The translation must be produced by a sworn translator accredited by a French Court of Appeal.

US nationals with assets in France

The United States has not opted into EU Regulation 650/2012. However, the regulation still applies to French assets when the deceased was habitually resident in France. A US national resident in France at the time of death will have their estate governed by French law by default — unless they chose another law in their will.

The USA and France have a bilateral estate and gift tax treaty signed on 24 November 1978. Under this treaty, real estate is taxed in the country where it is located. A French property owned by a US national is therefore subject to French inheritance tax.

For US heirs dealing with a French estate, all US documents — including the will, death certificate and letters testamentary — must be translated into French by a sworn translator accredited by a French Court of Appeal.

Australian and Canadian nationals with French assets

Australia and Canada are not EU member states. Their nationals resident in France are subject to French law by default on death. They may choose their nationality’s law in their will. However, the 2021 French reform may limit this choice if children are EU nationals or residents.

For Australian and Canadian heirs, all documents in English must be translated into French by a sworn translator accredited by a French Court of Appeal. Tradyx translates inheritance documents from English into French for heirs from any English-speaking country.

Which documents need translating for an inheritance in France

An international inheritance involving France requires documents produced in multiple languages. All must be translated with legal precision. A mistranslation can delay the process or lead to rejection by the notaire or tax authorities.

The European Certificate of Succession

The European Certificate of Succession (ECS) is a key instrument in cross-border inheritance within the EU, introduced by EU Regulation 650/2012. It produces the same legal effects in all EU member states and allows heirs to assert their rights in another country without further procedure.

The ECS is issued by the notaire or court of the country handling the succession. It is valid for 6 months, renewable. If issued in France and presented to UK or US authorities, it must be translated into English.

Note: the ECS does not apply in the UK, Denmark or Ireland, as these countries opted out of Brussels IV. For UK heirs, a grant of probate remains the relevant document for asserting rights on a UK estate.

Practical cases

Case 1 — British expat resident in France with UK assets

A British national has lived in France for 20 years. She dies in France leaving a flat in London and a house in Normandy. The succession opens in France. French law applies by default unless she chose UK law in her will. The French notaire handles the French estate. All French succession documents presented to UK authorities must be translated into English. All UK documents presented to the French notaire must be translated into French.

Case 2 — American national with a property in France

An American national owned a property in the South of France. She dies in the USA. Her heirs wish to sell the French property. The French notaire requires certified translations of the US death certificate, the will and the letters testamentary. All documents must be translated into French by a sworn translator accredited by a French Court of Appeal.

Case 3 — Australian heir dealing with a French estate

An Australian national dies in France leaving heirs in Australia. The heirs must deal with the French notaire. All French succession documents must be translated into English. Powers of attorney delegating a representative in France must be translated into French and certified by a sworn translator.

What makes a translation certified for inheritance purposes

A certified translation is produced by a translator registered with a French Court of Appeal. The translated document bears the official stamp and the handwritten signature of that translator — which certifies the accuracy of the translation under their full legal responsibility.

An uncertified translation is systematically refused by notaires, courts and all French public bodies. Furthermore, a sworn translator registered in another country — including the UK, USA or Australia — is not recognised in France. The certification must come from a translator accredited by a French Court of Appeal.

Common mistakes to avoid

How it works: 4 steps with Tradyx

Turnaround and pricing

The cost depends on the number of documents, their length and complexity. A certified translation for inheritance in France typically involves multiple documents. A global quote for the entire inheritance file is available on request.

Standard turnaround is 3 to 5 business days per document. For complex files with many documents, the turnaround is agreed based on total volume. An express service is available on request. A free quote is provided within 24 hours.

Why choose Tradyx for your inheritance translations

Tradyx is managed by a sworn translator accredited by the Court of Appeal of Caen. You work directly with the translator responsible for your documents — no agency, no intermediary. Every translation is personally verified, stamped and signed.

Tradyx has direct experience with the documents required in cross-border inheritance proceedings in France — from wills and death certificates to grants of probate, powers of attorney and European Certificates of Succession. Your documents are ready for submission from the first delivery.

FAQ — Frequently asked questions

Which law applies to an inheritance in France?

Under EU Regulation 650/2012, the law of the country where the deceased was habitually resident at the time of death applies. The deceased may choose the law of their nationality in their will.

Does Brexit affect inheritance proceedings in France for UK nationals?

Yes, partially. UK nationals are no longer EU citizens for the purposes of Brussels IV. However, EU Regulation 650/2012 still applies to successions involving French assets. The 2021 French reform on forced heirship may affect estates where children are EU nationals or residents.

Do I need to file an inheritance declaration in both France and the UK?

If the deceased had assets in both countries, yes. The French declaration must be filed within 6 months of death. UK probate proceedings are separate. Documents produced in one country must be translated for use in the other.

Does the European Certificate of Succession apply to UK nationals?

The UK opted out of Brussels IV. The ECS does not apply in the UK. However, a French ECS may still be useful for French assets when presented to other authorities. Check with your notaire on a case-by-case basis.

Who can translate inheritance documents for use in France?

The translation must be produced by a translator accredited by a French Court of Appeal. A translator registered in the UK, USA or any other country is not recognised by French authorities.

How long does it take to translate a complete inheritance file?

Standard turnaround is 3 to 5 business days per document. For complex files, the turnaround is agreed based on total volume. An express service is available on request.

Can I send documents by email?

Yes. A clear scan or PDF sent by email is sufficient to prepare the translation and issue a quote. The original may be required by the notaire for the final submission.

What if an heir does not speak French?

Heirs who do not speak French may require an interpreter for meetings with the notaire or court. Tradyx provides interpreting services for such meetings on request.

Do you translate holograph wills?

Yes. A holograph will — handwritten, dated and signed by the testator — is translated like any other legal document. The translation is certified with the stamp and signature of the sworn translator.

How much does a certified translation for an inheritance cost?

The cost depends on the number of documents, their length and complexity. A global quote for the entire file is available free of charge within 24 hours of sending the documents.

Does a certified translation have an expiry date?

The translation itself does not expire. However, some authorities require recent documents. The European Certificate of Succession is valid for 6 months and must be renewed after that period.

Is apostille required for inheritance documents used in France?

For documents from EU countries, apostille is generally not required. For documents from the UK, USA, Australia or Canada, requirements depend on the requesting authority. Check with the notaire before commissioning an apostille. More information is available on the HCCH website.