Written by Anna Szymielewicz, Attorney (radca prawny), Supervising Partner, Inheritance
First published: 4 November 2026
Reviewed by Marta Oleśkowska, Barrister (adwokat), Head of Inheritance, Succession & Probate
Last updated: 4 November 2026
In summary
Will a foreign probate document work in Poland?
A European Certificate of Succession issued in another EU country – other than Denmark or Ireland – works in Poland without any further procedure: Polish land registers, banks and companies accept it as evidence of who inherits (Article 69 of Regulation 650/2012). A UK grant of probate, US letters testamentary or a Canadian or Australian grant may not be enough on its own, especially for real estate in Poland. Foreign succession decisions are in principle recognised in Poland like other foreign judgments; where a bank or a land register will not act on one, a Polish court or notary confirms the heirs to the Polish assets. Executors and trustees abroad can complete the Polish part of an estate through Polish counsel – without travelling to Poland.
Anna SzymielewiczAttorney (radca prawny), Partner – Supervising Partner of the inheritance practice, Dudkowiak & PutyraOur figures
Your document in Poland – at a glance
European Certificate of Succession
Works directly
Issued in any EU country except Denmark and Ireland – no recognition, no apostille.
Succession decision of an EU court
Recognised
Without a special procedure; banks and registers often prefer an ECS.
UK grant · US letters · Canadian or Australian grant
May not be enough
Especially for real estate – recognition, or a Polish confirmation of the heirs.
Polish court order or notarial certificate
Accepted in Poland
Obtained under a power of attorney – no travel on the court route.
More key facts
Countries
EU minus Denmark, Ireland
The EU Succession Regulation applies to deaths from 17 August 2015; the United Kingdom, Switzerland and Norway are outside it.
Certified copy
Valid for 6 months
A Polish bank or register relies on a certified copy of the ECS; the issuing authority can extend it or issue a new one.
Apostille
Not for an ECS
No legalisation or apostille for an ECS; grants, letters and civil records from outside the EU usually need one.
Non-EU decisions
PLN 300
Court fee for an application to establish that a foreign decision is recognised in Poland.
Polish confirmation
PLN 105
Court fee for a declaration of succession (PLN 100 petition + PLN 5 register entry) – the alternative to recognition.
ECS issued in Poland
Court or notary
A Polish district court or notary issues the certificate when Polish courts have jurisdiction – usually because the deceased lived in Poland.
Travel
Not needed
Recognition, the court route and the use of an ECS all run under a power of attorney signed in your country.
Which foreign probate document do you have – and what does it do in Poland?
Polish banks, land registers, notaries and the commercial register act only on a document that shows who the heirs are. Which document works depends on the country that issued it. Choose yours:
Which document do you have?Select it to see what it does in Poland and the next step
Works in Poland directly
A European Certificate of Succession from another EU country (not Denmark or Ireland) is accepted by Polish land registers, banks, notaries and the commercial register without recognition or an apostille. A certified copy is valid for six months.
Next step: send us a certified copy – we file it with the land register or the bank and deal with the inheritance tax return.
The result follows the general rules on this page – it is not legal advice. Nothing you select leaves your browser.
The same rules, in one table:
| Document | In Poland | Usual next step |
|---|---|---|
| European Certificate of Succession (EU, not Denmark or Ireland) | Works directly – no recognition, no apostille | File a certified copy (valid six months) with the register or bank |
| Succession decision of an EU court | Recognised without a special procedure | Banks and registers often ask for an ECS instead |
| UK grant of probate or letters of administration | May not be enough on its own, especially for real estate | Recognition of the decision, or a Polish confirmation of the heirs |
| US letters testamentary or of administration | May not be enough on its own, especially for real estate | Recognition, or a Polish confirmation with the US probate record as evidence |
| Canadian, Australian or New Zealand grant | May not be enough on its own, especially for real estate | As for the UK and the US |
| Swiss, Norwegian, Danish or Irish document | No ECS – treated like other foreign decisions | Recognition, or a Polish confirmation of the heirs |
| Polish court order or notarial certificate of succession | Accepted by every Polish institution | Tax return, then the registers and the banks |
“Recognised” describes the legal effect; whether a particular bank or land-register court acts on the document without further evidence is what we check first, before any application is filed.
EU document · European Certificate of Succession
Using a European Certificate of Succession in Poland
A European Certificate of Succession (ECS) issued by a court or notary in another EU Member State is presumed to state accurately who the heirs, legatees and executors are and what their shares and powers are (Article 69 of Regulation 650/2012). A Polish bank may pay, and a buyer may rely on it. The certificate is also a valid document for an entry in the Polish land and mortgage register.
No recognition procedure, legalisation or apostille is needed. Two practical points decide whether it works at once: the copy must be a certified copy that is still valid – six months from issue, unless extended – and the land-register court or bank may ask for a sworn translation of the parts written in another language.
A European Certificate of Succession is the one foreign probate document a Polish land register accepts without any further procedure. With a grant from outside the EU the question is not whether it is valid, but whether the bank or the register will act on it – and that is what we check first.
Anna Szymielewicz, Attorney (radca prawny), Partner – Supervising Partner of the inheritance practice, Dudkowiak & PutyraWhat an ECS lets you do in Poland
Land register
Enter the heirs as owners of a flat, house or land; then sell or divide.
Banks and brokers
Release accounts and securities to the heirs or the executor named in it.
Companies
Register the heirs as shareholders and update the commercial register (KRS).
The Polish inheritance tax return still has to be filed – a foreign certificate does not replace it. The deadlines and the close-family exemption are on our page on inheritance tax in Poland; selling the property is covered in inheriting property in Poland.
Polish document · European Certificate of Succession issued in Poland
Obtaining a European Certificate of Succession from a Polish court or notary
When the deceased’s last habitual residence was in Poland, Polish courts deal with the whole estate – also with a flat in Spain or land in Germany. A Polish district court, or a Polish notary where the conditions are met, then issues a European Certificate of Succession that heirs use in every other participating Member State. One Polish certificate can list assets in several countries.
1Deceased lived in Poland
Polish courts have jurisdiction over the whole estate; the Polish ECS opens assets elsewhere in the EU.
2Deceased lived outside the EU
Polish courts can still rule on the assets in Poland (subsidiary jurisdiction, Article 10) – sometimes on the whole estate.
The certificate is applied for on the EU standard form, with the civil-status records, the will if there is one and evidence of the assets abroad. We draft the application in Polish, attend the hearing and obtain bilingual certified copies for the authorities abroad.
Non-EU documents · United Kingdom, United States, Canada, Australia
UK grant of probate and US letters testamentary in Poland
A UK grant of probate, US letters testamentary, a Canadian certificate of appointment of estate trustee or an Australian grant may not be enough on its own, especially for real estate in Poland. Foreign succession decisions are in principle recognised in Poland like other foreign judgments, but a Polish land register records heirs, not a personal representative, and Polish banks often ask for a Polish confirmation of the heirs or a recognition order before they pay. There are two routes:
Recognition of the foreign decision
A Polish court establishes that the foreign decision is recognised in Poland. It suits estates where the foreign decision itself names the heirs and the Polish institution wants a Polish order before acting on it.
- Evidence: the decision with an apostille and a sworn translation, and proof that it is final
- The court checks the statutory grounds for refusal; it does not re-hear the succession
- Court fee: PLN 300
Polish confirmation of the heirs
A Polish court – or, where all heirs agree and appear, a Polish notary – confirms who inherits the Polish assets, applying the law that governs the succession. The foreign grant, the will and the foreign probate record are the evidence. This is often the simpler route where the grant only appoints an executor and does not decide who the heirs are.
- Under a simple power of attorney signed at home – no travel on the court route
- The order is accepted by every Polish bank, register and buyer
- Court fee: PLN 105 (PLN 100 petition + PLN 5 register entry)
Which route is faster depends on the document, the assets and the institution. We read the grant and the will before anything is filed and tell you which one we would choose. The general steps of a Polish succession are explained in our guide to inheritance in Poland.
Foreign wills and foreign law
Foreign wills and foreign succession law in a Polish case
A will made abroad
Normally valid in Poland if it complies with the law of the place where it was made or of the testator’s nationality or residence. It is opened and announced by the Polish court, with a sworn translation.
Foreign succession law
A Polish court applies the law of Illinois, Ontario or England when that law governs the succession – and the parties often have to supply it.
Which country’s law governs the succession depends on several factors and should be checked by a lawyer. For deaths from 17 August 2015 it is usually the law of the deceased’s habitual residence, unless they chose the law of their nationality (EU Succession Regulation 650/2012). Different rules can apply where the death occurred before that date – nationality then decided – or where the applicable law refers back (renvoi) to the law of the place where real estate is located, as the law of many US states, Canadian provinces and England does for Polish property.
For executors, trustees and foreign lawyers
Polish assets in a foreign estate: Polish counsel for executors, trustees and law firms
Trust companies, executors, court-appointed administrators, public trustees and probate solicitors abroad instruct us when an estate they administer has beneficiaries in Poland or assets in Poland. We act as their Polish counsel; the client relationship stays with them. Twenty foreign law firms, trust companies, executors and estate administrators have instructed Dudkowiak & Putyra on Polish estates.
- Opinions on Polish law for foreign courts, probate registries, deputies and banks – who inherits, the validity of a will, the forced share, the applicable law.
- Verifying Polish beneficiaries – civil-status records, bilingual notarial declarations of identity and payment instructions, waivers and releases for your file.
- Collecting Polish assets – bank accounts, company shares, real estate; a Polish order or ECS where the bank or register requires one.
- Distributions in Poland – through our client escrow account, with verified bank details and receipts for your accounts.
Executors abroad rarely need probate in Poland. They need the Polish beneficiaries verified, documents their own court will accept, and payments made against a receipt – the Polish part of the file we run for them. What a will made abroad can do for Polish assets, and how a Polish will appoints an executor who can act in Poland, is explained in our guide to wills in Poland.
Marta Oleśkowska, Barrister (adwokat), Senior Counsel – Head of Inheritance, Succession & Probate, Dudkowiak & PutyraHow to instruct us
1Send the documents
The grant or appointment, the will, the death certificate and what you know of the Polish beneficiaries or assets.
2Scope and fee
Within 24 hours: a written scope – opinion, verification, collection or distribution – and a fee proposal.
3Form of the advice
A memorandum, an opinion for your court or registry, or declarations ready for your probate file – in English.
4Reporting
One point of contact; reports in English after every step and receipts for every payment.
Documents from abroad: apostille, sworn translation and civil records
Whichever route you take, a Polish court or institution works with documents in Polish and with foreign documents in a form it can rely on.
Foreign probate documents
- Grant, letters or certificate of appointmentcourt-certified copy with an apostille
- The willcopy certified by the court that admitted it, with an apostille
- Proof that the decision is finalfor recognition only
- European Certificate of Successioncertified copy, no apostille
Civil records and authority
- Death certificatewith an apostille; a death abroad is often transcribed into the Polish civil register
- Birth and marriage certificates of the heirsto prove kinship
- Sworn translations into Polishmade by a Polish sworn translator
- Power of attorney for ussimple signature for court cases; certified where a bank asks
Some countries have agreements with Poland that waive the apostille; for others a consular legalisation is needed. The country-by-country check is on our page on inheritance in Poland.
What using a foreign probate document in Poland costs – official fees
Polish advocates and attorneys-at-law do not publish fee schedules; our fees are agreed with the law firm in writing before the work starts. The official costs below are set by statute and tariff.
Official costsverified 4 November 2026
Using an ECS from another EU countryno court fee for the certificate itself; register or bank fees as usual
–
Recognition of a foreign decisionAct on court costs, Art. 24(1)(1)
PLN 300
Polish court declaration of successionArt. 49(1)(1) · PLN 100 petition + PLN 5 register entry
PLN 105
European Certificate of Succession issued in Polandcourt fee by statute, or the notarial tariff plus VAT
by statute
Land-register entry (inheritance)Art. 42(3)
PLN 150
Sworn translations, apostilleper page; apostille fee of your country
by tariff
Your lawyeragreed in writing before the work starts
agreed with the law firm
How Dudkowiak & Putyra handles foreign probate documents in Poland
Nine in ten of the 300+ inheritance matters the firm has opened since 2023 were for clients living outside Poland, and twenty foreign law firms, trust companies, executors and estate administrators have instructed Dudkowiak & Putyra on Polish estates. For foreign documents, one team does the whole Polish part:
First check
Whether your ECS, grant or letters will be accepted as it is – and, if not, the faster route.
ECS in Poland
Used before the land register, banks, brokers and the commercial register.
ECS from Poland
Obtained from a Polish court or notary for assets elsewhere in the EU.
Recognition
Foreign decisions recognised by a Polish court, with apostilles and sworn translations.
Polish confirmation
Heirs confirmed for the Polish assets, with the foreign grant and will as evidence.
Foreign law
Wills, renvoi and the law of a US state, a Canadian province or England proved in court.
Executors and trustees
Opinions, beneficiaries verified, assets collected, distributions paid through escrow.
Tax
The Polish inheritance tax return, with the firm’s tax advisers and your adviser abroad.
Property and money
Land register, sale under your power of attorney and transfer abroad.
No travel
One power of attorney signed in your country covers the court, the registers and the banks.
Both sides of the border
Certificates from Belgian, Dutch and English probate teams used in Poland; Polish certificates used in Germany, France and Sweden.
Courts and evidence of foreign law
The team belongs to the firm’s Litigation & Arbitration practice – recognition and contested cases stay in the same hands.
Reporting in English
Proceedings in Polish, reports in English after every step; the firm also works in German, Spanish, Italian and French.
Send us the foreign document and tell us what the estate holds in Poland – we reply within 24 hours.Polish lawyers do not publish fee schedules; our fees are agreed with the law firm in writing before the work starts.
Results from our files: European Certificates of Succession and foreign estates
Outcomes from Dudkowiak & Putyra’s own inheritance files. They show what has been done in individual matters; they are not a promise of the same result in yours.
6 results · foreign probate documents
-
3 countries
one Polish ECS for assets in Germany and France
A bilingual European Certificate of Succession issued by a Polish court for a New Zealand family, listing each German and French asset.
Polish ECS · 2025
-
PL + SE
one ECS from Warsaw for a flat and a house
For the sole heir of a Polish citizen who died in England: subsidiary jurisdiction accepted and the English renvoi applied to Polish and Swedish property.
Polish ECS · 2024–2025
-
BE → PL
a Brussels notary’s ECS used in Poland
Belgian law, an heir in Szczecin, the Polish tax return with our fees deducted and the Polish tax credited in Belgium.
Foreign ECS · 2025–2026
-
CAD 2.5m+
Ontario estate, beneficiaries in Poland
The Polish beneficiaries verified for the estate trustee through bilingual notarial declarations.
Trustee · Canada · 2025–2026
-
CHF 1m+
Swiss estate unblocked
A missing heir found in Poland for a Geneva court-appointed administrator, so the estate could be distributed.
Administrator · Switzerland · 2023–2025
-
7 legatees
paid in Poland for an Australian executor
Legatees located and verified, and the bequests paid through our escrow account – the executor never travelled.
Executor · Australia · 2023–2024
Case studies – European Certificates of Succession, foreign grants and foreign executors
Matters from the firm’s inheritance practice page, described from the case files. Private clients are never named; institutions are named with their consent. Amounts are rounded.
CAD 2.5m+Ontario estate, beneficiaries in Poland
Foreign estate trustee · Canada · 2025–2026
The Bank of Nova Scotia Trust Company: a Canadian estate with beneficiaries in Poland
Scotiatrust, as sole estate trustee of an Ontario estate of over CAD 2.5 million, needed to complete the distribution to two residuary beneficiaries living in Poland. As its Polish counsel, Dudkowiak & Putyra verified them through bilingual notarial declarations of identity and payment instructions, and answered one beneficiary’s formal challenge to the estate accounts, which kept the final distribution on track.
What it shows: a foreign executor or trustee can complete the Polish part of an estate through Polish counsel, without probate proceedings in Poland.
3 countriesone Polish ECS for DE and FR
European Certificate of Succession · New Zealand · 2025
A European Certificate of Succession from a Polish court for property in Germany and France
A New Zealand national died in Poland, leaving an industrial site in Germany and land in France. Because his last habitual residence was in Poland, only a Polish court could issue a certificate usable across the EU. Dudkowiak & Putyra showed that Polish law applied and that an earlier English will had been revoked; in December 2025 the court issued a bilingual European Certificate of Succession listing every German and French asset.
What it shows: the last habitual residence decides which country’s court acts – and one Polish ECS opens assets in several EU countries.
PL + SEa Warsaw flat and a Swedish house
Death in England · ECS · 2024–2025
A death in England, a flat in Warsaw and a house in Sweden: one European Certificate of Succession
The sole heir of a Polish citizen who died in England needed to deal with a Warsaw flat, a house in Sweden and UK accounts. Dudkowiak & Putyra obtained a European Certificate of Succession from the Warsaw court, which accepted subsidiary jurisdiction and applied the English renvoi to Polish and Swedish law for the immovables, then filed the Polish tax return and the land-register application – working with the English probate team.
What it shows: where the deceased lived in the UK, a Polish court can still issue an ECS for the property in Poland and elsewhere in the EU.
½ shareunder Illinois law, not Polish law
Foreign law · United States · 2023–2025
A widow in Chicago: proving Illinois law in a Polish succession case
A widow in Chicago claimed her share of her husband’s Polish estate; his daughter in Poland argued that he had lived in Poland. Dudkowiak & Putyra proved his habitual residence in Illinois and the marriage, and supplied the court with Illinois law, which the Ministry of Justice did not have. In March 2025 the court awarded the widow a half share, as Illinois law provides.
What it shows: a US estate can be governed by US law in a Polish court – and the heirs’ shares then differ from what Polish law would give.
+ Show 3 more matters
BE → PLBelgian notary, heir in Szczecin
Foreign ECS · Belgium · 2025–2026
A Belgian will, a Brussels notary and an heir in Szczecin
An unrelated heir in Szczecin was named in the handwritten will of a Belgian national. A European Certificate of Succession was obtained with a Brussels notary under Belgian law; Dudkowiak & Putyra filed the Polish tax return with the firm’s fees accepted as a deductible estate debt, and the Polish tax was credited against the Belgian return.
CHF 1m+Swiss estate, missing heir found
Foreign administrator · Switzerland · 2023–2025
Finding a missing Polish heir for a Geneva court-appointed administrator
A Geneva law firm administered an estate of over CHF 1 million for an absent heir. Dudkowiak & Putyra represented it before the Warsaw court, used the court file to locate the missing half-brother in Poland and, once he was confirmed alive in June 2025, the Swiss estate could be distributed among three heirs.
7 legateespaid without the executor travelling
Foreign executor · Australia · 2023–2024
Paying an Australian will’s bequests to relatives in Poland
A Melbourne law firm acting for the executor of an Australian will needed to pay cash bequests to seven relatives in Poland. Dudkowiak & Putyra located the legatees, verified their identity and bank accounts through notarised statements, dealt with the heirs of a legatee who had died and paid the bequests through the firm’s escrow account.
Who you talk to first
Foreign probate documents are handled by the partner who supervises the inheritance practice and the head of the practice. The full inheritance team is on the practice page.
Author of this guide · Supervising Partner
Attorney (radca prawny), Partner · Supervising Partner of the inheritance practice, Head of Litigation & Arbitration
Admitted as an attorney-at-law in 2017; law at Adam Mickiewicz University in Poznań. At Dudkowiak & Putyra she handles the recognition of foreign decisions, evidence of foreign law in Polish courts, opinions on Polish succession law for foreign courts, trustees and banks, and contested estates.
Reviewer of this guide · Head of the practice
Barrister (adwokat), Senior Counsel · Head of Inheritance, Succession & Probate
Admitted as an advocate in 2019; law at Adam Mickiewicz University in Poznań. Leads Dudkowiak & Putyra’s cross-border estates: Polish and European Certificates of Succession, foreign wills and grants in Polish proceedings, and Polish counsel to foreign executors and trustees.
Supporting practices
TaxMarcin Kręglewski · 9 tax advisers and lawyers
The Polish inheritance tax return, foreign tax credits, coordination with your tax adviser abroad.
Real EstateWojciech Kasprzak · 5 lawyers
Land-register entries on an ECS or Polish order, and the sale of inherited property.
Banking, Payments & FinTechAleksandra Walas · 9 people
Banks that refuse a foreign grant, brokerage accounts, transfers abroad and your bank’s compliance questions.
Immigration & Polish CitizenshipDenis Ushakov · 4 people
Transcription of foreign death and birth certificates, PESEL numbers, confirmation of Polish citizenship.
Sources and methodology
Legal basis:
- European Certificate of Succession – Regulation (EU) No 650/2012, Articles 4 and 10 (jurisdiction), 21–22 and 34 (applicable law and renvoi), 39 (recognition of decisions), 62–73 (the certificate: Article 69 effects, Article 70 certified copies valid for six months), 74 (no legalisation); Code of Civil Procedure, Articles 1142–114210; Notarial Law (certificates issued by notaries);
- Decisions from outside the EU – Code of Civil Procedure, Articles 1145–11481 (recognition of foreign decisions);
- Confirming the heirs in Poland – Code of Civil Procedure, Articles 669–679; Notarial Law, Articles 95a–95p;
- Foreign wills – Hague Convention of 5 October 1961 on the conflicts of laws relating to the form of testamentary dispositions; Regulation 650/2012, Article 27;
- Costs – Act of 28 July 2005 on court costs in civil matters, Articles 24, 42 and 49;
- Documents from abroad – Hague Convention of 5 October 1961 abolishing legalisation (apostille) and Poland’s bilateral legal-assistance agreements.
Official sources: European e-Justice Portal – succession and the European Judicial Atlas (authorities issuing the European Certificate of Succession in Poland); Inheritance Register – rejestry-notarialne.pl; land and mortgage registers – ekw.ms.gov.pl.
Own data: figures under “Our figures” come from Dudkowiak & Putyra matter records (DP-Stats). 20 foreign law firms, trust companies and executors: foreign professionals who have instructed the firm on Polish estates, counted over all years. 300+ inheritance matters, 9 in 10 and 78%: inheritance, succession and probate matters opened 1 January 2023 – 8 October 2026 (301 matters for 171 clients; 89% living outside Poland; 78% in English-speaking countries, 36% United States, 20% United Kingdom). 18 countries: countries of residence of inheritance clients with matters opened 2022–2026, taken from the case files. 50+ supporting lawyers: lawyers in the firm’s other practices as at October 2026. Results and case studies are taken from the case files and from the firm’s inheritance practice page; private clients are never named, institutions are named with their consent, amounts are rounded.
State of the law: November 2026. This page is general information, not legal advice.
FAQ – European Certificate of Succession and foreign probate documents in Poland
Is a European Certificate of Succession valid in Poland?
Yes. A European Certificate of Succession issued in another EU Member State – all except Denmark and Ireland – has effect in Poland without any special procedure: Polish land registers, banks and companies accept it as evidence of who the heirs, legatees and executors are. A certified copy is valid for six months, and no apostille is needed.
Does a UK grant of probate work in Poland?
It may not be enough on its own, especially for real estate in Poland. Foreign succession decisions are in principle recognised in Poland like other foreign judgments, but Polish banks and land registers often ask for a Polish recognition order or a Polish confirmation of the heirs. The United Kingdom never took part in the EU Succession Regulation, so it does not issue European Certificates of Succession.
Are US letters testamentary valid in Poland?
US letters testamentary appoint an executor; they may not be enough on their own in Poland, especially for real estate. The two routes are recognition of the US decision by a Polish court or a Polish confirmation of the heirs, with the US probate record and the will as evidence. Which is faster depends on the document and the asset.
Will a Polish bank release an account on a foreign grant?
Some do, many do not: a Polish bank may ask for a European Certificate of Succession, a Polish recognition order or a Polish court order or notarial certificate before it pays. We ask the bank what it will accept before any application is filed, and deal with it on your behalf.
How do I get a European Certificate of Succession in Poland?
If the deceased’s last habitual residence was in Poland, a Polish district court – or a Polish notary where the conditions are met – issues the certificate on the EU standard form, on the basis of the civil-status records, the will and evidence of the assets abroad. We prepare the application and obtain bilingual certified copies; you do not need to travel.
Does a European Certificate of Succession need an apostille or a translation in Poland?
No apostille or legalisation is needed for an ECS. The certificate uses the EU standard form, but a Polish land-register court or bank may ask for a sworn translation of the parts written in another language.
How long is a certified copy of an ECS valid?
Six months from the date of issue, stated on the copy. In exceptional cases the issuing authority can set a longer period; otherwise you ask for an extension or a new certified copy. A Polish register or bank looks at whether the copy was valid when it was presented.
Can a foreign executor deal with Polish assets?
Through Polish counsel, yes: beneficiaries in Poland are verified, documents prepared for the foreign probate file and distributions paid in Poland. Whether the executor can act directly on a particular asset depends on the document and on the institution – a bank or a land register may ask for an ECS or a Polish confirmation of the heirs first.
Is a will made abroad valid in Poland?
Normally yes, if it complies with the law of the place where it was made, or of the testator’s nationality or residence. In a Polish case the will is opened and announced by the court and needs a sworn translation; which law decides its effect is a separate question to check.
Do I need to travel to Poland?
No. Using an ECS, recognition of a foreign decision and the Polish court route all run under a power of attorney signed in your country. Only a notarial certificate of succession made before a Polish notary normally requires all heirs to appear.
What does it cost?
The court fee for recognising a foreign decision is PLN 300; a Polish court declaration of succession costs PLN 105 (PLN 100 for the petition and PLN 5 for the register entry); the land-register entry is PLN 150. Translations and apostilles are charged by tariff. Lawyers’ fees are not published in Poland and are agreed in writing before the work starts.
