Probate abroad
Courts in Türkiye, Spain, the US, Germany and elsewhere require apostilled proof of death to start succession proceedings.
Foreign probate courts, banks and insurers need an apostilled death certificate before they release assets or pay out. We obtain it quickly and discreetly from the issuing country, together with the translation the recipient expects.
Let us get this done for you
A death certificate is issued by the civil registry of the place of death. Heirs abroad need it – with an apostille from the issuing country – to open probate, transfer property, close accounts, claim life insurance or survivor pensions, and to register the death in the deceased’s home country.
The apostille is issued by the designated authority of the country where the death was registered; a recent original with the registrar’s signature is required. Where the estate includes property abroad, the death certificate is usually accompanied by a certificate of inheritance, a grant of probate or a notarial will, which are court or notarial documents and are apostilled separately.
We coordinate the whole bundle – death certificate, inheritance documents, powers of attorney for the executor – so the foreign court receives one consistent, apostilled and translated set.
Also known as: Sterbeurkunde (DE) · acte de décès (FR) · certificado de defunción (ES) · certificato di morte (IT) · certidão de óbito (PT) · ölüm belgesi (TR) · akt zgonu (PL) · overlijdensakte (NL)
An apostille is always issued in the country that issued the document. The most frequent issuing countries for a death certificate:
| Issued in | Issued by | Apostille by |
|---|---|---|
| Germany | Standesamt (registry office) of the place of the event | State administrative apostille office (Berlin: LABO; elsewhere Regierungspräsidium, Bezirksregierung or ministry)Multilingual CIEC extracts (Formule A/B/C) are accepted without apostille in CIEC states; inside the EU no apostille at all (Reg. 2016/1191). |
| United States | State or county vital records office; Consular Reports of Birth Abroad by the Department of State | Secretary of State of the issuing state; US Department of State for federal documentsThe certificate must be a certified copy issued by the vital records office – hospital certificates cannot be apostilled. |
| United Kingdom | General Register Office (England & Wales), NRS (Scotland), GRONI (Northern Ireland) | Foreign, Commonwealth & Development Office (FCDO) Legalisation OfficeRecently issued GRO certificates are apostilled directly; older ones may need a solicitor’s certification first. e-Apostille available. |
| France | Mairie (état civil) of the place of the event; Service central d’état civil in Nantes for events abroad | Since 2025 the chambers of notaries (conseils régionaux des notaires) are the competent authoritiesAsk for an extrait plurilingue for CIEC states; inside the EU no apostille (Reg. 2016/1191). |
| Spain | Registro Civil of the place of the event | Ministerio de Justicia / Gerencias Territoriales, or the Tribunal Superior de Justicia for judicial documentsSpain issues electronic apostilles; the certificado plurilingüe replaces translation in CIEC states. |
| Italy | Comune (ufficio di stato civile) | Prefettura – Ufficio Territoriale del Governo of the provinceEstratti plurilingue are accepted without apostille in CIEC states; EU regulation applies inside the EU. |
Other countries: see the issuing-country guides for all 130+ Contracting States.
Courts in Türkiye, Spain, the US, Germany and elsewhere require apostilled proof of death to start succession proceedings.
Release of accounts, securities and life-insurance payouts held in another country.
Survivor pensions from foreign pension funds and social-security institutions.
Registering a death that occurred abroad with the deceased’s country of citizenship.
The route depends on the country pair. Popular destinations for a death certificate – change the issuing country in the checker below:
Apostille, EU exemption or embassy legalisation – the answer per destination.
In most countries only relatives in the direct line, spouses and persons with a legal interest can obtain it. With your authorisation and proof of kinship we order it from the registry and take it straight to the apostille authority.
Usually yes when it is used abroad. It is a court or notarial document, so it is apostilled by the authority responsible for judicial documents in the issuing country. We submit both documents in parallel to save time.
Where the registry issues certificates online and the country has e-apostilles, within days. Elsewhere the bottleneck is obtaining a fresh certificate, which we start on the day you order.
Upload a scan, verify with your phone – the notary reviews the application, we handle authority, translation and delivery.
Questions? Write to [email protected]