Important: For general educational information only. This is not legal, tax or financial advice, and reading it does not create a professional-client relationship. Laws and procedures vary by jurisdiction and can change. Consult a qualified professional in each place relevant to you and your assets before making decisions.
Ask what proof the German institution will accept
The German Federal Foreign Office’s UK guidance says that a person dealing with an estate partly in Germany may often be asked for a German certificate of inheritance (Erbschein), a European Certificate of Succession or a certificate of executorship. It notes that this issue commonly arises where German real estate is involved and that banks and similar institutions may request evidence of succession.
The same official guidance cautions that an Erbschein is not legally required in every case. It says a certified copy of a notarial will filed with the probate court and the probate record may suffice in the situation it describes, and that other proof may establish heirship in some cases. Ask the land registry, bank or relevant court what it requires before assuming one certificate is necessary.
Questions to bring to an adviser
- Which German asset or institution requires proof of succession?
- Is there a German notarial will, court record, European Certificate of Succession or other evidence?
- Has the receiving institution confirmed its current document requirements?
Understand the limited cross-border context
The Foreign Office page describes German inheritance matters for readers in the UK and notes that German law provides for an estate to pass directly to heirs rather than first being administered by a personal representative in the UK model. This is a useful contrast when assembling questions, but it does not say which law governs an individual estate or how a foreign will will be treated in every case.
The page also says the competent probate court is usually the local court for the district of the deceased’s last residence, while applications and supporting declarations may require formal steps. The appropriate court, proof and acceptance of foreign documents should be confirmed with qualified German counsel and the relevant institution.
Questions to bring to an adviser
- Where did the deceased last reside, and which probate court should be contacted?
- Was a will made or probate granted in the UK or another country?
- Do translations, notarisation or other authentication requirements need confirmation?
Keep this guide within its stated scope
This is a Germany and UK-connected starting point based on the German Foreign Office’s UK guidance. It is not a general guide to UK probate or all German estates, and it does not determine heirship, applicable law, tax, acceptance or renunciation of an inheritance, or requirements for assets in another country. Individual banks, land registries and courts may need different evidence.
This article has not been reviewed by a lawyer or human editor. Consult qualified German counsel and, where relevant, UK counsel before applying for a certificate, transferring property or taking other steps.
Questions to bring to an adviser
- Does the estate connect only Germany and the UK, or are other countries involved?
- Is the question about proving heirship, governing law, tax or estate administration?
- Which qualified professional can review the facts and contact the relevant German authority?
Official starting points
Check these sources for updates; their guidance may have changed since our last source check.
This guide cannot determine which rules apply to you. Speak with a qualified professional in each jurisdiction relevant to your family and assets.