Inheritance Notarisation Certificate in China — How to Apply After a Death Abroad

Chinese Banks Will Not Release Funds Without This Document

When a Chinese citizen dies abroad, their domestic bank accounts, securities, real estate titles, and digital wallet balances are immediately frozen or inaccessible. Unlike UK banks, which offer discretionary small-estates pathways that bypass probate for balances under certain thresholds, Chinese financial institutions operate under rigid statutory rules. No amount of documentation — not even an apostilled foreign death certificate — will move them to release funds without an Inheritance Notarisation Certificate (继承公证书).

This certificate is issued by a local Chinese notary office and serves as the authoritative proof of who inherits what. It is the keystone document for every China-side financial transaction after a death.

What the Notary Office Requires

The application is submitted at a public notary office (公证处) in the city where the deceased's hukou was registered, or where the assets are located. The notary officer must verify three things: that the person is dead, who the legal heirs are, and the documents supporting the inheritance claim.

Documents to present:

1. The deceased's cancelled hukou record — this means hukou cancellation at the PSB must already be completed before the notary application. The cancellation stamp serves as the Chinese domestic proof of death.

2. The apostilled and translated UK death certificate — the original FCDO paper apostille with the certified Chinese translation bound behind it. The notary office independently verifies the apostille through the Hague Conference electronic register.

3. Proof of relationship for every legal heir — under Article 1127 of the PRC Civil Code, first-order heirs are the surviving spouse, children (natural and adopted), and surviving parents. Second-order heirs (siblings, grandparents) only inherit if no first-order heirs exist. Each heir must provide their identity card, hukou entry, and a document linking them to the deceased — marriage certificates, birth certificates, or adoption certificates.

4. A declaration from all heirs — the notary office will set the required appearance, waiver, or consent procedure for each legal heir. If an heir is abroad, ask the notary office what form of declaration and authentication it accepts.

5. A written statement that no will exists (if intestate) — or the original will, if one was executed under Chinese law. If a UK-drafted will covers Chinese assets, ask the Chinese notary office or a cross-border lawyer what authentication and translation it requires.

The Heir Priority Under PRC Civil Code

The inheritance order is strict and cannot be overridden without a valid will:

First order: Surviving spouse, children, and parents — they inherit equal shares by default.

Second order: Siblings and grandparents — they inherit only when no first-order heirs survive.

If a first-order heir has predeceased the deceased but has their own children, those children inherit by representation (代位继承). This is relevant when a parent dies after their adult child has died abroad, and the grandchildren hold the inherited claim.

Claiming Frozen Bank Accounts

With the notarisation certificate in hand, the designated heir (or their attorney) presents it to each Chinese bank where the deceased held accounts. The bank's bereavement team verifies the certificate and processes the release of funds under the bank's procedure; timing depends on the bank and account type.

For joint accounts, treatment can differ. Ask the bank how it separates the deceased's interest and what documents it needs before releasing any funds.

Digital Wallets — WeChat Pay and Alipay

The process for recovering balances in WeChat Pay and Alipay accounts follows the same principle but involves platform-specific procedures.

WeChat Pay: The heir should contact Tencent's customer service with the inheritance notarisation certificate, the deceased's identity details, and the heir's own identity documents. The platform will set its verification and transfer requirements; processing time varies by case.

Alipay: The heir should contact Alipay's customer service with the notarisation certificate, the deceased's Alipay account details, and their own identity documents. Other Alipay products or credit balances may have separate procedures; confirm how the platform will handle them.

Both platforms will need to verify that the account belonged to the deceased. Gather the registered phone number or linked identity-card details if available.

Securities and Real Estate

For securities accounts (stocks, bonds, funds held at Chinese brokerages), the notarisation certificate is presented to the brokerage's estate settlement team. The process mirrors bank account closure, but positions may need to be liquidated before funds can be transferred.

For real estate, the notarisation certificate enables the heir to apply for title transfer at the local real estate registration centre (不动产登记中心). This involves additional steps — property valuation, tax assessment, and registration fees — but the notarisation certificate is the prerequisite that unlocks the entire chain.

How Long the Full Process Takes

From the date of death to the notarisation certificate being issued, families should plan for several weeks across the full chain. UK death registration, any coronial process, the FCDO apostille, translation, hukou cancellation, and notary processing can each extend the timetable.

The Chinese National Dies in the UK — Family Guide maps the complete chain from UK death registration through Chinese estate settlement, with a document tracker that shows which certificates feed into the notarisation application and timeline estimates for each step.