Inheritance, Probate & Wills · European Union

Make Sure a Foreign Will Is Actually Recognised Where the Assets Are

A will drawn up in one country does not automatically carry the same weight in another. Formal validity, language, witnesses and even the deceased’s chosen law can all be challenged when the will crosses a border. We match you, free of charge, with a vetted inheritance lawyer who confirms whether a foreign will is valid and enforceable where it needs to be, and who handles its recognition.

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Who this is for

A will that is valid at home may still face hurdles abroad

When someone dies leaving a will made in another country, or when their assets are spread across borders, the first question is always whether that will is recognised in the country where the estate must be administered. Recognition can turn on formal validity — whether the will was properly signed and witnessed under the law of the place where it was made — and on questions of applicable succession law, capacity and the validity of any choice of law. International conventions and the EU Succession Regulation have made cross-border recognition more predictable, but the practical work of proving validity, obtaining translations and presenting the will to foreign courts, registries and banks remains complex. A specialist lawyer ensures the will is treated as effective where it matters most.


Why executors and heirs get stuck

A foreign will is only as strong as its recognition.
Validity is not automatic across borders.

Formal requirements, language barriers and conflicting national rules can all cast doubt on a will precisely when it needs to be relied upon.

01

The will’s formal validity is being questioned

A will signed or witnessed in a way that satisfied one country’s rules may not satisfy another’s — and a challenge to its formal validity can delay or derail the entire estate.

02

The will is not in the local language

A will written in the deceased’s language must often be translated by a certified or sworn translator before local courts and registries will even look at it, and an inadequate translation can itself cause rejection.

03

It is unclear whether the will even applies to local assets

Some assets, such as land, can be subject to the law of the country where they are situated, which may differ from the law the deceased chose — leaving executors unsure which rules actually govern.


What you get

A lawyer who turns a foreign will into a recognised, enforceable document

We only match you with inheritance lawyers who handle the cross-border recognition and enforcement of foreign wills in the relevant country.

Formal validity confirmed

Your lawyer examines how the will was made against the relevant rules, and confirms whether it is formally valid and therefore recognisable in the country where the estate must be administered.

Applicable law established

Where the deceased held assets in several countries, your lawyer determines which succession law governs the will and its effect, so you know which rules the estate is actually subject to.

Certified translations arranged

Your lawyer arranges sworn or certified translations and any required legalisation or validation, so the will is presented to foreign courts, registries and banks in a form they will accept.

Recognition pursued through the right channels

Whether a formal declaration of validity, a grant of probate or a notarial procedure is needed, your lawyer files it through the correct authority and sees the recognition through to completion.


Coverage

Foreign will recognition lawyers across Europe

Recognition depends on the country where the assets sit and the law governing the succession, so the right lawyer practises in the jurisdiction that matters. We match foreign-will cases across the following countries and beyond:

SpainPortugalGermanyFranceItalyNetherlandsBelgiumIrelandAustriaPolandGreeceSweden+ more EU / EEA countries

Frequently asked

Recognition of foreign wills — common questions

Is a will made in one country valid in another?

Not automatically. A will’s formal validity is usually tested against the law of the place where it was made, and international rules and conventions often help it be recognised — but the country where the estate is administered may still need to confirm this through its own procedures.

Does the EU Succession Regulation apply to my will?

The regulation applies to successions of persons who die on or after its entry into force in the participating countries, and generally points to the law of the deceased’s habitual residence. Whether it applies, and how, depends on the dates and circumstances of your case.

What if the deceased chose a law in the will?

A choice of law made in a will may be recognised within limits, allowing the deceased to select the law of their nationality to govern the succession. Whether such a choice is valid and effective is a technical question a specialist should confirm.

Do I need a translation of the will?

If the will is in a language other than that of the country administering the estate, a certified or sworn translation is usually required before courts and registries will process it. The exact requirements vary by country and by the institution involved.

Can a foreign will be challenged here?

Yes — grounds such as lack of formal validity, incapacity or undue influence can be raised, and the country whose law applies will determine which grounds are available. A lawyer can assess how vulnerable the will is to challenge in your situation.

What is the first step to recognise a foreign will?

Typically you must establish which law governs the succession, confirm the will’s formal validity, and then present it — with translations and any required legalisation — to the appropriate court, notary or authority in the country of administration. A specialist will map the exact route for your case.


Free case review

Make sure the will is honoured where it matters

Tell us where the will was made, where the assets are, and what has happened so far, and we’ll connect you with a lawyer who handles foreign will recognition — free of charge, with no obligation to hire.