French Succession Terminology Explained
A practical glossary of common French succession and probate terminology, explaining what each term means, its nearest UK equivalent and why your French notaire may request it.
French succession uses legal terminology that often has no direct equivalent in English law.
As a result, requests from your French notaire can sometimes appear confusing or even impossible to satisfy. In many cases, the wording reflects differences between the French and UK legal systems rather than a mistake.
This glossary explains the meaning of common French succession terms, their closest UK equivalent and what they generally represent in practice.
Important: The UK and French legal systems are fundamentally different. The “UK Equivalent” shown below is intended to help you understand the purpose of the document or concept rather than suggesting it is an identical legal instrument.
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Using this Glossary
Click any term above to jump directly to its definition.
Throughout our guides you’ll also find many of these terms linked directly back to this glossary, allowing you to quickly look up unfamiliar legal terminology without interrupting your reading.
As French succession law uses many concepts that have no exact UK equivalent, this glossary is continually updated with new terms and explanations as they arise in real succession cases.
If you’ve encountered a term that isn’t listed here, please let us know—we’re always expanding this resource to make it as useful as possible for families dealing with UK–France succession.
Acte de Notoriété
English Translation
Act of Notoriety
Closest UK Equivalent
A document establishing the legal heirs of the deceased.
Explanation
This is usually one of the first documents prepared by the French notaire. It identifies who is legally entitled to inherit the estate and forms the foundation of the succession.
Unlike the UK, where entitlement is often established through probate and the Will, French law formally records the heirs in this document.
↑ Back to GlossaryDéclaration de Succession
English Translation
Declaration of Succession
Closest UK Equivalent
Inheritance Tax Return (closest comparison).
Explanation
This document declares the estate, its assets, liabilities and beneficiaries for French tax purposes.
It is not identical to a UK inheritance tax return but serves a broadly similar purpose.
↑ Back to GlossaryAttestation Immobilière
English Translation
Property Transfer Certificate
Closest UK Equivalent
Land Registry transfer documentation.
Explanation
Used to update ownership of French property following the death of the owner.
↑ Back to GlossaryCertificat de Coutume
English Translation
Certificate of Custom (or Certificate of Law)
Closest UK Equivalent
Usually a solicitor’s opinion explaining English law.
Explanation
This is one of the most misunderstood requests made by French notaires.
Many online searches incorrectly suggest this relates to marriage documentation. Within succession, however, the certificate is used to explain how foreign law applies, particularly where English law, trusts or wills are involved.
The UK has no official government-issued Certificate of Custom.
Instead, it is common for a UK solicitor with expertise in the relevant area to provide a signed opinion explaining the applicable English law.
If your succession involves trusts, this is frequently sufficient.
↑ Back to GlossaryCertificat d’immatriculation
English Translation
Vehicle Certificate
Closest UK Equivalent
V12/Log Book.
Explanation
The certificate confirming vehicle ownership and address.
↑ Back to GlossaryActe
English Translation
Official Deed or Act.
Closest UK Equivalent
A legal deed or formal legal document.
Explanation
The word Acte appears in many French legal documents.
It generally refers to a formal legal instrument prepared by a notaire.
↑ Back to GlossaryNotaire
English Translation
French Notary.
Closest UK Equivalent
There is no direct UK equivalent. However there are UK Notaries who can witness and certify you swearing documents in the UK, avoiding the need to travel to France to sign documents such as powers of attorney.
Explanation
A French notaire combines responsibilities that in England and Wales are divided between solicitors, conveyancers and certain court functions.
They are responsible for administering most French successions involving property.
↑ Back to GlossaryAvocat
English Translation
Lawyer / Advocate.
Closest UK Equivalent
Solicitor or Barrister.
Explanation
An avocat generally becomes involved where legal advice, disputes or court proceedings are required.
Unlike a notaire, they represent the interests of their client.
↑ Back to GlossaryProcuration
English Translation
Power of Attorney.
Closest UK Equivalent
Limited Power of Attorney.
Explanation
A procuration allows someone else to sign documents on your behalf.
It is commonly used where beneficiaries live overseas and cannot attend appointments in France.
↑ Back to GlossaryLivret de Famille
English Translation
Family Record Book.
Closest UK Equivalent
No direct equivalent.
Explanation
A French family document recording marriages, births, divorces and deaths.
UK families generally do not possess one.
↑ Back to GlossaryUsufruit
English Translation
Usufruct.
Closest UK Equivalent
Life Interest.
Explanation
A person holding a usufruit may use property or receive income from it without owning the capital outright.
Although similar to a life interest trust, the legal concepts are not identical.
↑ Back to GlossaryNue-Propriété
English Translation
Bare Ownership.
Closest UK Equivalent
Remainder Interest.
Explanation
The bare owner owns the capital interest but cannot fully enjoy the property until the usufruit ends.
↑ Back to GlossaryPleine Propriété
English Translation
Full Ownership.
Closest UK Equivalent
Absolute ownership (freehold ownership of the property and all associated rights)
Explanation
Pleine Propriété means a person owns the property outright with complete legal rights over it. They have both ownership of the property itself and the right to use, occupy, rent, sell, mortgage, gift or otherwise dispose of it. It combines the two elements of French ownership: Nue-Propriété (Bare Ownership) and Usufruit (the right to use and enjoy the property). Once someone holds Pleine Propriété, there are no separate ownership interests remaining. In UK terms, it is broadly comparable to owning a property outright as the sole freehold owner, although the French legal concepts of Usufruit and Nue-Propriété have no exact equivalent in UK law.
↑ Back to GlossaryRéserve Héréditaire
English Translation
Forced Heirship.
Closest UK Equivalent
No direct equivalent.
Explanation
French law reserves part of many estates for certain heirs, usually children.
This differs significantly from English testamentary freedom.
↑ Back to GlossaryTestament
English Translation
Will.
Closest UK Equivalent
Will.
Explanation
One of the few documents with a direct equivalent.
↑ Back to GlossaryTrust
English Translation
Trust.
Closest UK Equivalent
Trust.
Explanation
Although the word exists in both systems, French law does not generally recognise trusts in the same way as English law.
This is why additional explanations from UK solicitors are often requested.
↑ Back to GlossaryTrust Deed
English Translation
Trust Deed.
Closest UK Equivalent
Trust Instrument.
Explanation
This can cause confusion.
In many UK family trusts, particularly Will Trusts, there is no separate Trust Deed.
Instead, the trust provisions are contained within the Will itself.
Where a French notaire requests the Trust Deed, it is often appropriate to provide:
- the Will creating the trust;
- any subsequent trust documentation; and
- where necessary, a solicitor’s explanation of how the trust operates.
Grant of Probate
French Reference
Grant of Probate (commonly referred to descriptively).
Closest UK Equivalent
Grant of Probate.
Explanation
France does not issue an identical document.
Where UK assets require probate, the UK Grant of Probate may later be provided to the French notaire as supporting evidence.
↑ Back to GlossaryLettre d’Engagement
English Translation
Letter of Engagement.
Closest UK Equivalent
Client Care Letter / Engagement Letter.
Explanation
The agreement between you and the notaire authorising them to act.
↑ Back to GlossaryDossier
English Translation
File.
Closest UK Equivalent
Case File.
Explanation
Your succession file.
You’ll often be asked for your Numéro de Dossier, which is simply your file reference.
↑ Back to GlossaryWhy This Matters
Many of these terms don’t have an exact UK equivalent because the legal systems are fundamentally different.
Understanding what your French notaire is trying to achieve is often far more useful than attempting to find an identical English document.
Where an exact equivalent doesn’t exist, a suitable alternative—such as a solicitor’s letter explaining English law—may satisfy the requirement.
Need Help?
If you’ve been asked for a document or legal term you don’t understand, our consultation service can help explain what your notaire is requesting, identify the nearest UK equivalent and discuss the most appropriate way to respond.