Power of Attorney Translation in the UK: Foreign Powers Used Here and UK LPAs Used Abroad

A lasting power of attorney registered with the Office of the Public Guardian can run a bank account in Leeds and sell a flat in Cardiff. On its own, it does nothing in Málaga. GOV.UK says an LPA is "legally binding only in England and Wales", and a property and affairs LPA "can only be used for your properties and assets in England and Wales."

The traffic runs the other way too. A mother in Kraków signs a pełnomocnictwo so her son can sell her Manchester flat, and the conveyancer finds that HM Land Registry wants more than a translation: a lawyer in Poland must confirm the power works under Polish law.

Either way, the translation is what the other side reads, and a power "to administer" that becomes "to manage and sell" changes what the attorney may do. Below: both directions, apostilles, Scotland and Northern Ireland, probate, and the translation itself.

Does a foreign power of attorney need a certified translation in the UK?

Yes, whenever a UK organisation must rely on it and it is not in English. There is no UK register of foreign powers, so each bank, conveyancer, registry or court decides what it accepts. Scotland's Office of the Public Guardian is candid: a non-Scottish power "can be used in Scotland if an organisation (e.g. a bank) accepts its authority", and "The law in this area lacks certainty."

The governing law matters as much as the wording. Under Schedule 3 to the Mental Capacity Act 2005, if a donor living abroad grants a power that survives incapacity and has a connection with England and Wales, such as property here, the law of the country where the donor lived governs its "existence, extent, modification or extinction" unless English law was chosen in writing; only "the manner of the exercise" follows English law. The Schedule covers "any other power of like effect", so a Vorsorgevollmacht made by someone living in Germany is read under German law.

HM Land Registry is the strictest reader (next section). Courts follow their procedure rules, covered in our HMCTS translation requirements guide, and banks set their own, so ask in writing which copy and format they want.

What does HM Land Registry need for a foreign power of attorney?

The power with a translation, and a legal opinion. Section 8 of Practice guide 9 covers any power "created in and governed by the law of a jurisdiction other than England and Wales". The applicant must provide "a certified copy of the power (together with a verified translation of the power if it is not in English or Welsh)" and a legal opinion "from a lawyer qualified to practice in that territory" confirming that:

1. execution by an attorney is permitted there;
2. the donor had capacity to appoint an attorney;
3. the donor complied with the local formalities and "is bound by the power of attorney";
4. the power authorised the attorney to sign the document in question; and
5. "the power remained valid at the time of execution".

The opinion "must not be qualified or conditional", and if it is not in English or Welsh, "the applicant must provide a certified translation of it."

The trigger is the governing law, not where the donor signs: a power governed by English law and signed abroad as a deed falls outside section 8, so raise it with the conveyancer before anyone signs overseas.

Can I use a UK lasting power of attorney abroad?

Not automatically; each country decides:

• Spain. "Spain will recognise a lasting power of attorney organised in the UK" once it is registered and legalised, says the FCDO, but you must "Get the document translated by a sworn translator registered in Spain." The alternative is a Spanish poder notarial, which the Spanish Consulate General in London can authorise; "A personal appearance is always necessary on the day the document is signed."
• Greece. "A lasting power of attorney made in the UK may not be valid in Greece," the FCDO warns.
• Elsewhere. Scotland's Office of the Public Guardian, writing about Scottish powers, sums it up: "Each country will have its own position on this", and the translation "is likely to be by a nominated official translator of that country."

Ask a lawyer there before paying for legalisation; a local power signed before a notary may be the only route.

How do you get a power of attorney apostilled and translated for use abroad?

In four steps:

1. Register the LPA. It costs £92 (up from £82 on 17 November 2025) and takes "8 to 10 weeks" if there are no mistakes. The Powers of Attorney Act 2023 will change how LPAs are registered, but as of October 2026 those changes are not in force.
2. Certify a copy. A donor can certify each page with GOV.UK's wording, but the FCDO legalises a power of attorney only once "certified by a UK 'public official', such as a UK notary or solicitor."
3. Get the apostille. The FCDO Legalisation Office charges £45 for a paper apostille plus courier or postage, "usually up to 25 working days", or £35 for an e-Apostille, "up to 2 working days", on a PDF electronically signed by a UK notary or solicitor. Ask which the recipient accepts.
4. Translate everything: power, certification and apostille, by the translator the destination accepts.

If a UK translation is acceptable, an authority abroad may still want it notarised and apostilled, since an apostille only goes on a public document such as a notary's certificate. Through our apostille service, the certified translation is notarised and then apostilled; the apostille is attached to our translation, not to your original. Where a country insists on its own sworn translator, as Spain does, use one: the Spanish Consulate General in London says "you should use a Sworn Translator-Interpreter duly registered in Spain" and lists those living in the UK. See what an apostille is and certified vs notarised translation.

Powers of attorney at a glance: who wants what

Scotland and Northern Ireland: different powers, different rules

Scotland. A power over money and property "is called a 'continuing power of attorney'", and a welfare power covers welfare decisions. "The power of attorney document must be certified by a solicitor or a medical practitioner" and registered with the Office of the Public Guardian (Scotland) for £99 (£102 from 1 April 2027). On language: "We can only accept PoAs drafted in English." For a granter who cannot read English, it suggests a power in the granter's own language plus "an English translation of the PoA" that is "notarially executed", placed "at the front of all the PoA documentation."

For powers made elsewhere, it has "devised a certificate which recognises foreign PoAs in Scotland" and aims to issue it within ten working days. A Scottish power going abroad will likely need "a hand signed copy" rather than an electronically signed one.

Northern Ireland. Enduring powers are used, not LPAs. "In Northern Ireland, an EPA covers financial matters only", and it is registered with the High Court (Office of Care and Protection) once the attorney believes the donor is becoming incapable.

What must a power of attorney translation show?

Everything that decides what the attorney may do:

• Donor and attorneys: full names as in their passports, dates of birth, addresses and identity numbers as written.
• The instrument's own title, kept in italics after the English: poder notarial, Vollmacht, pełnomocnictwo, доверенность, довіреність, procuração, procura.
• Every power, in the original order. "Administer", "dispose of", "encumber" and "sell" are different powers.
• Every limit: named properties, accounts, amounts and exclusions.
• Substitution, duration and revocation, including any expiry date and what happens on incapacity or death.
• Execution: date, place, witnesses, the notary's certificate and register or protocol number.
• Annexes, stamps, every reverse side and the apostille.

Can someone abroad appoint an attorney to deal with probate in England?

Yes. Rule 31 of the Non-Contentious Probate Rules 1987 lets "the lawfully constituted attorney of a person entitled to a grant" apply "for the use and benefit of the donor". An executor signs form PA11 "as a deed" before an independent witness, "someone that is not related to the person appointing the Attorney and has no interest in the estate"; where there is no will, the entitled relative signs PA12 before an independent witness. A registered LPA or signed EPA also works. The forms are in English and Welsh, so an executor who reads neither should have one translated before signing. See probate with foreign assets and heirs.

Why power of attorney translations get questioned

• Powers paraphrased: "deal with the property" for a clause listing specific acts, so nobody can tell whether a sale is authorised.
• A limit, expiry date or notarial certificate left out.
• Names that differ from the passports, the title register or the transfer.
• A translation of a different copy from the one actually lodged.
• A legal opinion missing, qualified or untranslated in a Land Registry application.

Checklist: before you order a power of attorney translation

Questions people ask