Will Translation for International Inheritance: Requirements by Country

A notary in Munich refused to issue a certificate of inheritance. The reason - a handwritten Ukrainian will with no apostille and no sworn translation. The heir flew in from Kyiv, spent 800 euros on flights, and the process didn’t even start. All because of one document that should’ve been prepared beforehand. If you’re in a similar situation right now - or just planning to claim an inheritance abroad - let’s break down step by step what you need to do with your will translation in different jurisdictions.

Why translating a will isn’t just “translating text”¶

A will (Testament, Last Will, testament, testamento) is a legal document that determines who gets what after someone dies. Sounds simple. But when the deceased lived in one country, assets are scattered across several others, and the heirs live in a third - you’ve got a legal maze on your hands.

Translating a will for international inheritance isn’t just converting words from one language to another. It’s a legal translation where a mistake in a single term can mean the heir gets the wrong share - or nothing at all.

Here’s a real example. A Ukrainian will says “все моє майно” (all my property). The translator renders it in German as “mein gesamtes Vermögen.” But in Germany, there’s a legal distinction between Vermögen (all assets, including debts) and Nachlass (the estate proper). If the court interprets it wrong, the heir might “inherit” debts they could’ve rejected.

That’s exactly why will translation requires not just any translator, but someone who understands inheritance law in both countries. And that’s why courts in different countries demand specific types of translation - sworn, notarized, or certified.

What documents you need for international inheritance (besides the will)¶

The will is the central document, but it’s far from the only one. Claiming an inheritance abroad usually requires a full package, and every document needs translation.

Core package¶

Document	Purpose	Issued by
Will (original or copy)	Confirms the deceased’s wishes	Notary / court
Death certificate	Confirms the death	Civil registry (DRACS)
Heir’s birth certificate	Proves family relationship	Civil registry
Marriage certificate	If the heir is a spouse	Civil registry
Certificate of last residence	Determines jurisdiction	Local government / housing office
Property documents	Prove ownership	Land registry
Certificate of inheritance	Confirms right to inherit	Notary

Each of these documents needs to be: 1) apostilled (if the country is a party to the Hague Convention), 2) translated into the language of the country where the inheritance is being processed, 3) certified according to that country’s requirements.

As stated by the Ministry of Justice of Ukraine:

Documents issued in Ukraine must be authenticated with an apostille stamp under the Hague Convention of 1961, or undergo consular legalization for use abroad.

In plain terms: without an apostille, your Ukrainian will is just a piece of paper with text on it.

Additional documents (depending on your situation)¶

• Renunciation of inheritance - if one of the heirs is giving up their share (notarized, with translation)
• Power of attorney - if the heir is handling everything remotely through a representative (more about powers of attorney)
• Court decision - if the will is being contested
• Certificate of marital status - some countries require proof that the heir is (or isn’t) married

Tip: get the entire package translated at once, by the same translator. It’s cheaper (volume discount) and faster, plus the terminology stays consistent across all documents - and courts care about that.

Apostille on a will: process and cost¶

An apostille is a stamp that confirms a document’s authenticity for use abroad. Without it, no country that’s a party to the Hague Convention will accept your will.

The order is always the same: apostille first, then translation. Not the other way around. The document is translated together with the apostille.

Where to get an apostille on a will in Ukraine¶

Document type	Who issues the apostille	Timeframe	Cost
Notarized will	Ministry of Justice	5-7 business days	500-700 UAH (state fee)
Death certificate	Ministry of Justice	5-7 business days	500-700 UAH
Birth certificate	Ministry of Justice	5-7 business days	500-700 UAH
Court decision (if the will was contested)	Court of Appeal	5-10 business days	500-700 UAH

If you’re abroad and can’t come in person - get a power of attorney for a relative, or use the services of a legal agency. The power of attorney can be issued through a Ukrainian consulate.

As reported by the Cabinet of Ministers of Ukraine:

Ukrainian citizens abroad can apply to a consular office to file an application for acceptance of inheritance. In this case, the application is drafted in Ukrainian and doesn’t require separate apostilling or translation.

This is a useful hack: if you submit your application through the consulate, you save on translation and apostille for that specific application. But the will itself and other documents still need to be apostilled and translated.

Types of will translation: which one your country requires¶

Not every translation works for an inheritance court. The type of translation depends on the country where the inheritance is being processed. Submit the “wrong” type, and the document won’t be accepted.

For more detail on the difference between notarized, sworn, and certified translation - check our separate article. Here’s the short version.

Sworn translation (beglaubigte Übersetzung)¶

Where required: Germany, Austria, Switzerland.

Who does it: a sworn translator (beeidigter Übersetzer) - a translator who took an oath before a German court. Their signature and seal carry legal weight. No separate notarization needed.

Price: 30-60 EUR per page. A 2-3 page will + apostille = 90-240 EUR for translation.

As noted by beglaubigte-übersetzung.de:

Testamente aus dem Ausland müssen für deutsche Nachlassgerichte von einem beeidigten Übersetzer ins Deutsche übertragen werden.

Translation: foreign wills must be translated into German by a sworn translator for German probate courts (Nachlassgericht).

Sworn translation in Romance-language countries¶

Where required: France, Belgium, Italy, Spain.

In France, it’s a traducteur assermenté - a translator registered with a Court of Appeal (Cour d’appel). In Italy - traduttore giurato, and the translation must also be “sworn” before a court (asseverazione). In Spain - traductor jurado, appointed by the Ministry of Foreign Affairs.

Price: 40-80 EUR per page in France, 50-90 EUR in Italy (including asseverazione), 40-70 EUR in Spain.

Certified translation¶

Where required: USA, Canada, UK, Australia, New Zealand.

The translator signs a Certificate of Accuracy. No court oath needed, no notary seal. But the translator must be qualified and prepared to prove their competence.

Price: $20-40 per page in the USA, £25-50 in the UK, AUD 30-60 in Australia (NAATI-certified translator).

Notarized translation¶

Where required: Turkey, some Latin American and Middle Eastern countries.

The translator does the translation, then a notary certifies the translator’s signature. In Ukraine, notarized translation costs 200-500 UAH per page.

Summary table¶

Country	Translation type	Who certifies	Cost per page
Germany	Sworn (beglaubigte Übersetzung)	Sworn translator	30-60 EUR
Austria	Sworn	Sworn translator	30-55 EUR
France	Sworn (traduction assermentée)	Traducteur assermenté	40-80 EUR
Italy	Sworn + asseverazione	Traduttore giurato + court	50-90 EUR
Spain	Sworn (traducción jurada)	Traductor jurado	40-70 EUR
USA	Certified	Translator + Certificate of Accuracy	$20-40
Canada	Certified	Translator (CTTIC or ATA)	CAD 30-50
UK	Certified	Translator + notary (sometimes)	£25-50
Australia	NAATI-certified	NAATI translator	AUD 30-60
Turkey	Notarized (yeminli tercüme)	Translator + notary	500-1500 TRY

Country-by-country requirements: what the inheritance court needs¶

Germany - Nachlassgericht¶

German probate courts (Nachlassgericht) require:

1. Original will or notarized copy
2. Apostille on the will
3. Sworn translation (beglaubigte Übersetzung) into German
4. Translated death certificate with apostille
5. Documents proving family relationship (with translation and apostille)

Key detail: Germany applies EU Regulation 650/2012 on succession. This means the law of the country where the deceased had their last habitual residence applies to the inheritance. If grandma lived in Ukraine - Ukrainian inheritance law applies, even if the apartment is in Munich.

As the European Commission explains:

The general rule is that the law applicable to the succession as a whole is the law of the State in which the deceased had his habitual residence at the time of death. However, individuals may choose to apply the law of their nationality.

Processing time: 3-12 months (depending on case complexity).

France - Notaire¶

In France, inheritance matters are handled by a notary (notaire). For a foreign will, you need:

1. Original will with apostille
2. Sworn translation (traduction assermentée) into French
3. Translated death and family relationship documents
4. Acte de notoriété (notarial certification of heirs’ rights)

France also applies EU Regulation 650/2012. So if the deceased was a Ukrainian who lived in Ukraine but owned property in France - Ukrainian law applies (unless the will specifies otherwise).

Important nuance: France has the concept of “réserve héréditaire” - a mandatory share for children. Even if the will says “everything to my wife,” the children have a legal right to their share under French law. This can create a conflict with Ukrainian law, where the mandatory share is smaller.

Italy - Tribunale¶

Italy requires:

1. Original will with apostille
2. Sworn translation (traduzione giurata) into Italian
3. Asseverazione - translator’s oath before a court (Tribunale)
4. Dichiarazione di Successione - inheritance declaration for tax purposes

Cost of the full package (translation + asseverazione + filing): 300-800 EUR, depending on the number of documents.

Spain - Notario¶

Spain requires:

1. Original will with apostille
2. Traducción jurada (sworn translation) into Spanish
3. Escritura de aceptación de herencia (notarial deed of acceptance of inheritance)
4. NIE for the heir (if not already obtained)

As RRYP Global notes:

International wills are accepted in Spain but must be accompanied by a sworn translation into Spanish and properly apostilled.

USA and Canada - Probate Court¶

American and Canadian probate courts require:

1. Copy of the will, certified by a foreign court or notary
2. Certified translation into English
3. Translator’s affidavit (sworn statement of translation accuracy)
4. Apostille (for Hague Convention countries)

As Irwin Mitchell explains:

When a deceased has a Will from another jurisdiction, the UK requires an official copy of the Will, certified by the foreign court, or notarised, and often apostilled under the Hague Convention.

In the USA, probate can take 6 months to 2 years. A will in a foreign language adds extra delay, because the court may commission an independent translation review.

United Kingdom - Probate Registry¶

The British system is similar to the American one:

1. Original will or certified copy
2. Certified translation into English (by a notary or qualified translator)
3. Apostille (if applicable)
4. Translator’s affidavit

After Brexit, the UK no longer applies EU Regulation 650/2012. So for British inheritance cases, domestic law applies, and the process can be more complex for foreign wills.

European Certificate of Succession¶

If the deceased lived in an EU country or had assets there - you can obtain a European Certificate of Succession (ECS). This document is automatically recognized in all EU countries (except Ireland and Denmark) and significantly simplifies the process.

As the European e-Justice Portal explains:

The European Certificate of Succession enables heirs, legatees, executors of wills and administrators of the estate to prove their status and exercise their rights in other EU countries.

Benefits of the ECS¶

• Automatic recognition in all EU countries (except Ireland and Denmark)
• No apostille required
• Translation not always needed (though authorities may still request one in practice)
• Cost: from 122 EUR (varies by country)
• Timeframe: usually 1-3 months

Limitations¶

The ECS is only available for inheritances where the deceased died after August 17, 2015 (the date EU Regulation 650/2012 took effect). For earlier deaths - only the traditional process with translations and apostilles.

If you’re processing an inheritance in an EU country - ask the notary or lawyer whether the ECS can be used. It’ll save you both time and money.

Step-by-step guide: from will to inheritance¶

Regardless of the country, the process follows roughly the same sequence:

Week 1-2: Collecting documents in Ukraine - Get the original will from the notary (or a copy from the Inheritance Registry) - Get the death certificate - Collect documents proving family relationship (birth certificates, marriage certificates) - Collect property documents (if applicable)

Week 2-3: Apostilling - Submit documents to the Ministry of Justice for apostille - Wait 5-10 business days - Make sure the apostille is on EVERY document you’re planning to submit abroad

Week 3-4: Translation - Find a translator of the right type (sworn, certified, etc. - depends on the country) - Translate ALL documents at once - Verify the translator included proper credentials and translated the apostille too

Week 4-8: Filing - Submit documents to the inheritance court / notary in the country where the inheritance is being processed - Wait for the decision (1 to 12 months, depending on the country and complexity)

Critical: don’t miss the deadlines! In Ukraine, the time limit for accepting an inheritance is 6 months from the date of death. In Germany - 6 weeks (if you live in Germany) or 6 months (if abroad). In France - 4 months. Miss the deadline, and you’ll have to restore your rights through court - more time, more money.

Common mistakes when translating wills¶

Based on experience with dozens of inheritance cases, here are the most frequent mistakes:

1. Translation without apostille¶

The heir translates the will, shows up at court - and the court refuses it because there’s no apostille on the original. Now they have to go back (or send the document) to Ukraine, get the apostille, then translate again (because the translation must include the apostille). That’s 2-3 months wasted.

2. Wrong type of translation¶

A notarized translation done in Ukraine won’t work for Germany. You need a sworn translation (beglaubigte Übersetzung) from a translator who took their oath in Germany. More on this distinction - in our article.

3. Name transliteration errors¶

If the will spells the name as “Наталія” but the heir’s passport says “Nataliia” (or “Nataliya,” or “Natalija”) - the court may not accept that it’s the same person. The translator must use the exact transliteration from the heir’s travel passport. More about this problem - in our article on transliteration.

4. Incomplete translation¶

Some translators skip “technical” parts of the document - stamps, seals, handwritten notes by the notary. For a probate court, every element of the document must be translated. If there’s a seal with text - translate the seal text. If there’s a handwritten note - translate it with a notation: “handwritten note / handschriftliche Anmerkung.”

5. Ignoring differences between legal systems¶

Ukrainian inheritance law and, say, German inheritance law are two different systems. The term “обов’язкова частка” in Ukraine (Article 1241 of the Civil Code) and Pflichtteil in Germany aren’t identical in scope or the circle of people entitled to it. The translator should either use the precise equivalent or provide an explanatory note.

How much does the whole process cost: from apostille to receiving the inheritance¶

Let’s do the math using a German inheritance for a Ukrainian heir as an example.

Expense	Cost
Apostilles (will + death certificate + birth certificate)	1,500-2,100 UAH (3 x 500-700 UAH)
Sworn translation of the document package (5-10 pages)	150-600 EUR
Filing an application with Nachlassgericht	0 EUR (free)
Erbschein (certificate of inheritance)	0.5-1% of the inheritance value
Lawyer (if needed)	200-500 EUR/hour
Inheritance tax (Erbschaftsteuer)	7-50% (depending on degree of kinship and amount)

Total cost excluding tax: roughly 500-2,000 EUR for the paperwork part.

If you need an urgent translation, the price goes up 50-100%. Standard turnaround for a sworn will translation is 3-5 business days, rush is 1-2 days.

And if time is really tight and you need at least a draft translation for a preliminary lawyer consultation - you can upload the document to ChatsControl and get a translation in minutes. You’ll still need a sworn translation for official court submission, but for understanding the content and preparing your case - it’s a serious time saver.

What to do if the will is handwritten¶

Handwritten wills (holographic wills) are common in Ukraine - when the deceased wrote the will by hand without a notary. These wills are legally valid (Article 1247 of the Civil Code of Ukraine), but they can create complications during translation:

• Illegible handwriting - the translator has to work with what’s there. If a word is unreadable, it’s noted: “illegible / unleserlich”
• Non-standard language - grandma might have written in surzhyk (a mix of Ukrainian and Russian), with dialectal words or abbreviations. The translator must convey the meaning accurately, even if the document’s language is far from literary standards
• No notarial certification - some countries (Germany, for instance) do recognize handwritten wills, but the procedure may take longer

If the will is handwritten and you need to confirm its authenticity - you may need a graphological examination. That expert report also needs to be translated.

FAQ¶

Do I need an apostille on a will for inheritance abroad?¶

Yes, if the country where the inheritance is being processed is a party to the Hague Convention of 1961. That includes most EU countries, the USA, Canada, Australia, Turkey, and others. The apostille is obtained in Ukraine BEFORE the translation. For a notarized will, the apostille is issued by the Ministry of Justice. Cost: 500-700 UAH, timeframe: 5-7 business days.

How much does it cost to translate a will for probate court?¶

It depends on the country and the type of translation. Sworn translation in Germany - 30-60 EUR per page, in France - 40-80 EUR, certified translation in the USA - $20-40 per page. A will is typically 1-3 pages, so the translation will run 30-240 EUR. Plus the translation of supporting documents (death certificate, birth certificate, etc.).

Can I use a will translation done in Ukraine for a German court?¶

No. Germany requires beglaubigte Übersetzung - a sworn translation done by a translator who took their oath in Germany. A notarized translation done in Ukraine won’t work for German courts. The exception is if the court specifically stated it will accept a different type of translation (which is rare).

What are the time limits for accepting an inheritance in different countries?¶

In Ukraine - 6 months from the date of death. In Germany - 6 weeks (if you live in Germany) or 6 months (if abroad). In France - 4 months. In Italy - 10 years (but the tax declaration must be filed within 12 months). In the UK - there’s no strict deadline, but it’s recommended to act as soon as possible. Missing the deadline means going through court to restore your rights.

What is the European Certificate of Succession, and does it replace translating the will?¶

The European Certificate of Succession (ECS) is a European document confirming an heir’s rights in all EU countries (except Ireland and Denmark). It doesn’t replace the translation of the will itself, but it can replace several other documents (certificate of inheritance, proof of family relationships). The ECS is issued by a notary or court, costs from 122 EUR, and is automatically recognized in other EU countries. It only works for inheritances where the deceased died after August 17, 2015.