UK Probate With a French Death Certificate — PA19, Grant of Probate, and Estate Steps

You Do Not Need a UK Death Certificate

The Probate Registry accepts the French acte de décès directly. You do not need to register the death separately with the FCDO's Overseas Registration Unit to apply for a Grant of Probate — though some families choose to for convenience.

What you do need is an English version. The fastest route is the extrait plurilingue — a multilingual death certificate extract with standardised English headings that the mairie issues alongside the standard acte de décès. The Probate Registry accepts this without any additional translation work.

If you only have the standard French acte de décès, you need a certified English translation. A professional translator's certification is sufficient. If your translator is not a member of a recognised professional body, they complete Form PA19 — a declaration where the translator formally affirms their qualifications and certifies the translation as accurate under penalty of contempt of court. The translator signs, dates, and attaches PA19 to the translation. The Probate Registry treats this as equivalent to a professional certification.

Applying for the Grant of Probate

The probate application itself follows the standard process. You apply online through the GOV.UK service or by post, submitting:

• The probate application form (PA1P if there is a will, PA1A for intestacy)
• The original will (if one exists)
• The French acte de décès with English translation or multilingual extract
• The appropriate inheritance-tax form, if required (for example, IHT205 or IHT400 depending on the estate)
• The probate fee

The key difference from a domestic death is that the estate may span two jurisdictions. UK probate covers UK-sited assets — bank accounts, property, investments, pensions held in the UK. French-sited assets — a French property, French bank accounts, French investments — are handled separately under French succession law through a French notaire.

The French Side — Dual-Jurisdiction Estates

French succession law operates independently from UK probate. If the deceased owned property or held assets in France, a French notaire manages the French portion of the estate. This is not optional — French law requires notarial involvement for any estate that includes French real property.

The notaire will need:

• The acte de décès
• The UK will (apostilled by the FCDO Legalisation Office and translated by a French court-sworn traducteur assermenté)
• The UK Grant of Probate (also apostilled and sworn-translated)
• Birth and marriage certificates for the deceased and beneficiaries

French succession law includes forced heirship rules (réserve héréditaire) that can affect French assets. EU Regulation 650/2012 may allow a deceased person to elect UK law in their will, but the effect of that election and any French claw-back issue depend on the estate and should be checked with a cross-border notaire or solicitor.

Inheritance Tax — Both Sides

The UK–France double taxation convention on estates may provide relief against tax being charged twice on the same asset. In practice, the executor and the notaire need to determine how the relief applies:

• UK IHT applies to the deceased's worldwide estate if they were UK-domiciled. French assets are included in the IHT400 calculation, and relief for French succession tax (droits de succession) may be available subject to the applicable rules.
• French succession tax applies to French-sited assets regardless of the deceased's nationality or domicile. Rates and exemptions depend on the beneficiary's relationship to the deceased — surviving spouses are fully exempt from French succession tax.

HMRC and the French tax authorities do not coordinate automatically. Your executor and the notaire need to ensure the double taxation relief is correctly applied on both sides.

Common Mistakes

Waiting for French succession to close before starting UK probate. The two processes are independent and can run in parallel, although their timing depends on the estate. Starting both simultaneously can avoid unnecessary delay.

Not apostilling UK documents for France. A UK will, Grant of Probate, or marriage certificate is worthless to a French notaire without an FCDO apostille and a sworn French translation. Start this process as soon as the grant is issued.

Ignoring the French bank freeze. French banks freeze sole accounts on formal notification of death, while joint accounts usually remain active under French banking conventions. For a sole account, the €5,000 funeral expense route may be available. Further release of funds waits for the notaire to complete the succession formalities, including the acte de notoriété.

Our complete guide walks through dual-jurisdiction estate administration step by step, with a document flow chart showing what goes where — and what needs translation, apostille, or both.