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Inheriting from the Netherlands with assets in Spain: European Certificate of Succession, no apostille

Dutch estates with Spanish assets: why the European Certificate of Succession does apply here (unlike Ireland), and why it's worth requesting it in English.

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By Eva Moreno Ortiz ·

We already covered, in our guide on Irish estates, that being an EU country doesn't automatically guarantee access to the European Certificate of Succession — Ireland opted out. The Netherlands is the opposite case: it fully participates in the regulation, which considerably simplifies an estate with Spanish assets, with one practical nuance worth sorting out from day one.

The European Certificate of Succession does apply here

EU Regulation 650/2012, which creates the European Certificate of Succession and unifies much of the EU's cross-border succession rules, applies in the Netherlands with no exclusion. The heir or executor requests the certificate from a notaris (Dutch civil-law notary), who issues it following the standardised form set out in the regulation itself.

The concrete advantage: Article 69 of the regulation establishes that the certificate produces its effects in all member states without any special procedure being required. In practice, that means the Dutch European Certificate of Succession doesn't need an apostille to be presented before a Spanish notary — unlike the Irish, Australian or Canadian Grant of Probate, which does need one because those countries are either outside the regulation or opted out of it.

The alternative national document: the Verklaring van Erfrecht

The Netherlands also has its own domestic document proving heirship, the Verklaring van Erfrecht (statement of inheritance law), which the notaris can issue instead of the European certificate. Here's the important nuance: if the procedure is for Spain, it's worth specifically requesting the European Certificate of Succession, not the national Verklaring. The Verklaring, being a purely Dutch document and not the regulation's standardised form, does need an apostille — issued in the Netherlands by the relevant Rechtbank (district court), not a centralised ministry — and a full sworn translation. Requesting the European certificate from the outset saves you that step.

The nuance that no amount of EU regulation changes: the language

Here's the point that doesn't go away no matter how much EU regulation is involved: the Dutch notaris drafts the certificate's content in Dutch. The form itself is standardised across all EU languages, but the specific data — names, assets, inheritance shares — is filled in by the notary in their own language.

And here it's worth being as honest as we are in our guide for Dutch residents on the Costa Blanca: at Textualia we don't translate directly from Dutch, only from English, French and German into Spanish. The good news is that many Dutch notaries specialising in international estates — the ones who regularly handle inheritances with Spanish assets — are used to working in English and can issue the certificate, or a courtesy version of it, in English. Ask for this specifically when requesting the certificate: it saves you having to find a sworn Dutch translator, a language pair we don't offer.

If the notaris can only issue it in Dutch, that translation falls outside what we can do, and you'll need to find a sworn Dutch translator accredited by the MAEC. We'd rather tell you this here than have you discover it after uploading the document to our quote tool.

The death certificate: also apostille-free

The Dutch death certificate is issued by the gemeente (municipality) where the death occurred, and it's covered by EU Regulation 2016/1191: it doesn't need an apostille between EU countries, and if you request it with the multilingual standard form attached, you won't need to translate it either.

What we're not

We're not a notary's office or a tax or succession adviser, and we don't determine which law governs the estate or what's owed in tax in Spain — that depends on the deceased's habitual residence and where the assets are located, and is a matter for your notary or lawyer. Our job is translating from English, French or German into Spanish, with official validity in Spain, whatever documentation that process asks you for.

In summary

  • The Netherlands fully participates in Regulation 650/2012: the European Certificate of Succession is available and needs no apostille, unlike the Irish case.
  • Request specifically the European certificate, not the national Verklaring van Erfrecht, which does need a Rechtbank apostille and a full translation.
  • Ask the notaris to issue the certificate in English if possible — that's what we can translate directly.
  • The gemeente's death certificate doesn't need an apostille, and with the multilingual form, no translation either.

Related pages


→ Request my sworn translation

At Textualia we translate the European Certificate of Succession and the death certificate for your Dutch estate from English into Spanish, signed by a translator accredited by the MAEC. If your documentation only exists in Dutch, we'll tell you before you order anything.

By Eva Moreno Ortiz, Sworn Translator-Interpreter accredited by the MAEC.

Frequently asked questions

Answers to your questions

Can the European Certificate of Succession be used for a Dutch estate?

Yes. Unlike Ireland, the Netherlands did not opt out of EU Regulation 650/2012, so the European Certificate of Succession is fully available and needs no apostille.

Who issues the European Certificate of Succession in the Netherlands?

A notaris (Dutch civil-law notary), on the heir's or executor's request.

Does Textualia translate the certificate if it's issued in Dutch?

We don't translate directly from Dutch — only from English, French and German into Spanish. That's why it's worth asking the notaris to issue the documentation in English from the start.

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