Sworn translation for an international inheritance in Spain

An inheritance with paperwork from two countries

It happens more often than you would think: your mother dies in Leeds and leaves a flat in Estepona. Or the other way round: the deceased lived in Spain and one of the heirs signs from Chicago or Toronto. The moment a succession has a foreign element —the deceased, the assets or the heirs themselves— the file landing on a Spanish notary's desk fills up with documents written in another language. And Spanish notaries work in Spanish.

Since August 2015, cross-border successions within the EU are governed by Regulation (EU) 650/2012: as a general rule, the law of the country where the deceased was habitually resident applies, unless the will chose the law of their nationality instead. Which law governs your case, what inheritance tax will come to or how Spanish forced-heirship shares work are questions for your notary or lawyer. Our part is smaller and strictly indispensable: getting every foreign document in the file into Spanish, signed and stamped by a sworn translator authorised by the Spanish Ministry of Foreign Affairs (MAEC).

Which documents usually need a sworn translation

Accepting and distributing the estate is done by deed before a Spanish notary, and everything supporting that deed must be in Spanish or come with a sworn translation. In an international inheritance, the usual list looks like this:

• Death certificate from the country where the death occurred. If it comes from an EU country, ask for it with the multilingual standard form under Regulation (EU) 2016/1191: notaries usually accept that without translation. A British or American death certificate, on the other hand, always gets translated.
• The foreign will. We wrote a full guide on the sworn translation of wills.
• Grant of probate or letters testamentary: the court decision from the UK, the US or Canada that proves the will and appoints the executor. How they fit into a Spanish succession is covered in our guides on a UK inheritance with Spanish assets and a US estate with property in Spain.
• Succession certificates from other countries, such as the German Erbschein or the French acte de notoriété.
• The foreign equivalent of Spain's last-wills certificate, when the notary asks for it. Spain keeps a central registry of wills (the Registro General de Actos de Última Voluntad) and notaries always pull the Spanish certificate; some also want the equivalent from the deceased's country. Here is the well-known catch: the UK has no central wills register, so there is no such certificate to request. Your status is proven with the grant of probate itself, which already identifies the valid will.
• Powers of attorney for heirs who will not travel to Spain for the signing, granted before a local notary and apostilled.

And the reminder we repeat on every file: the apostille is part of the document and gets translated too.

The European Certificate of Succession, the shortcut when it exists

If the deceased was resident in another EU country, the authority there —a notary or a court, depending on the state— can issue the European Certificate of Succession created by Regulation 650/2012. It is a uniform form proving across the whole Union who is heir, legatee or executor, with no apostille or any other legalisation, and it circulates as certified copies valid for six months. When one exists, it genuinely saves paperwork: it replaces much of the documentary chain described above. Two limits worth knowing: it does not work with Denmark or Ireland —nor, of course, with the UK or the US— and its content arrives in the language of the issuing authority, so the Spanish notary may ask for a sworn translation of it.

How we do it at Textualia

1. Upload the documents as PDFs; a scan or a sharp photo does the job. The price shows up instantly.
2. We match the turnaround to your signing date at the notary's office. If the file is on a deadline, there is a rush option.
3. A sworn translator authorised by the MAEC signs and stamps each translation, faithful to the original.
4. You receive an electronically signed PDF, fully valid before any Spanish notary. If they ask for paper, we issue it on official stamped paper (papel timbrado) and post it to you.

Wills, account balances, family details: everything you upload travels encrypted and is shared with no one.

Why Textualia

Probate files have a vocabulary of their own. An executor is not quite an albacea, a grant of probate is not a notarial deed, and estate rarely maps onto a single Spanish word. We have translated enough wills, grants and succession certificates to know what a Spanish notary expects to read and which turns of phrase raise questions at the signing. A fixed price from minute one, a clear deadline and a real person on the other end. An inheritance is heavy enough without the translation becoming one more problem: gather the apostilled documents, upload them and we take care of the rest.