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Cross-border · First steps · Information, not legal advice — as at 24 June 2026

How to get the death certificate you need — for an estate in Spain, Portugal, France or Italy

Nothing in a foreign estate can move until you have the right death certificate — usually several certified copies, sometimes a special multilingual version, and, to use a home-country certificate abroad, an apostille and a sworn translation. Which one you need depends on where the death was registered. Below is the practical route for a death registered in the UK or Ireland, and for certificates issued in Spain, Portugal, France and Italy. We’ll always tell you exactly what to gather for your matter.

If the death happened in the UK or Ireland

The death is registered locally and you obtain certified copies from the register office (in England & Wales, the GRO or the local register office; in Ireland, the General Register Office). Order several — banks, registries and notaries each tend to want their own. To use a UK certificate in Portugal or Spain, two extra steps usually apply (an Irish certificate is an EU document, so it needs no apostille — ask the Irish registry for the EU multilingual form and you may avoid a translation too):

  • Apostille — the certificate is legalised with a Hague apostille in the country that issued it (in the UK, the FCDO Legalisation Office). This is done at home, not by us, and the apostille fee is a disbursement.
  • Sworn translation — a certified/sworn translation into Portuguese or Spanish, unless a multilingual version is used (below).

The multilingual “international” certificate — often the easy route

Where the death was registered in Portugal, Spain, France or Italy, you can usually obtain a multilingual / international death certificate (under the 1976 Vienna Convention). Because it is issued in standard multilingual form, it is accepted across the contracting states without a separate translation — which can save time and cost in Portugal, Spain, France and Italy. Ask the issuing registry for the international version where it’s available.

Getting the certificate in Spain

A Spanish death certificate (certificado de defunción) comes from the Registro Civil where the death was registered. There are different forms — a simple extract, a literal copy (full detail, usually what a notary/registry wants), or the multilingual/international version. You can request it online through the Ministry of Justice — with a digital certificate or Cl@ve, or even without one (you complete the form and it’s posted to you) — or by post or in person; a representative can obtain it for you. (Cl@ve needs a Spanish DNI/NIE, so a UK heir would typically use the no-ID online route, the post, or us.) In a full administration we obtain the literal copy, and the international version where useful; for an opinion we show you exactly how to get it.

Getting the certificate in Portugal

A Portuguese death certificate (certidão de óbito) comes from a Conservatória do Registo Civil. It can be requested online (via the Civil Online / IRN service) or in person, and a representative can obtain it. As in Spain, ask for the international version where it helps avoid a translation.

Getting the certificate in Italy

An Italian death certificate (certificato di morte, or the fuller estratto dell’atto di morte) comes from the Ufficio di Stato Civile of the Comune where the death was registered. A representative can request it — in person, by post, or (in many comuni) online — and you can ask for the multilingual/international extract to avoid a separate translation.

Getting the certificate in France

A French death certificate (acte de décès) comes from the mairie (town hall) of the place of death or of the deceased’s last home; for a French national who died abroad, from the Service central d'état civil in Nantes. Copies are free, anyone may request one (online, by post or in person), and a multilingual extract (extrait plurilingue) is available to avoid translation.

How many, and which version?

A useful rule of thumb: you’ll need the certificate for every institution that has to act — each bank, the tax office, the land registry, the notary. So order several certified copies, get the literal/full version where an official body needs the detail, and use the multilingual version to dodge unnecessary translation. Getting this right at the start avoids weeks of delay later.

The short version

Identify where the death was registered, obtain several certified copies, prefer the multilingual/international version to save translation, and apostille + translate a home-country certificate before using it abroad. For your matter, we’ll set out the exact list and obtain the local certificates — Spanish, Portuguese, French or Italian — for you.

How Carroll Law can help

We handle the Portuguese, Spanish, Italian or French side of an estate end-to-end, in plain English, for a fixed fee agreed before we start — and where your loved one lived abroad, we work alongside your home-country solicitor: their grant deals with the estate at home, while the assets abroad pass through each country’s own process — a home grant has no direct effect there, and there is no resealing. Transferring a property after a death is a fixed €4,000–€5,000 + VAT, depending on the country.

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This article is general information, not legal or tax advice, and does not create a lawyer–client relationship. For advice on your situation, instruct a lawyer admitted in the relevant jurisdiction. Reviewed by Colin Carroll.

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