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Updated: · Author: Oleg Zdendiak, owner of XREQUIEM, 10 years in the funeral business

Death certificate abroad

The death certificate is the first document that everything else depends on: the consulate, the border, the funeral, the inheritance and the funeral allowance. Here we explain who issues it in the country where the person died, why an apostille and a translation are needed, and how Ukraine recognises a foreign document.

In brief

  • First, the death is registered in the country where it took place. A local authority issues a death certificate or an extract from the death record.
  • For the document to be valid in Ukraine, an apostille is placed on it. If the country is not a party to the Hague Apostille Convention, consular legalisation is needed instead.
  • After that comes a certified translation into Ukrainian.
  • A consul of Ukraine can register the death and issue a Ukrainian death certificate. The registration and the first death certificate carry no consular fee.
  • To cross the Ukrainian border, you need the death certificate or another document confirming the death, issued by a competent authority. Without such a document, the body or the urn will not be allowed into Ukraine.

Two documents: the medical one and the registry one

Families often mix up two different papers. Both are called a “death certificate”, but they do different jobs.

The medical certificate of death

A doctor issues it after examining the deceased. In Poland it is the karta zgonu. In Czechia and Slovakia it is the form on the examination of the deceased (list o prohlídce zemřelého in Czech, list o prehliadke mŕtveho in Slovak). In Romania it is the certificatul medical constatator al decesului, and in Austria the Todesbescheinigung. It is a medical document, and the death is registered on the basis of it.

The death certificate from the register

It is issued by the office that registers civil status records, the local counterpart of a Ukrainian civil registry office (DRACS). This is the document that the consulate, the border and the Ukrainian authorities ask for. It is the one that receives the apostille and is translated.

A consul of Ukraine registers the death on the basis of both: the medical document confirming the death and a certificate of the death from the authorities of the country. That is why we collect both.

Who issues the certificate in different countries

Document names and deadlines differ from country to country. A few examples:

CountryDocumentIssued by
PolandAkt zgonu (the death record), short extractUrząd Stanu Cywilnego (USC). The death is registered within 3 days, the record is drawn up the same day and the extract is issued free of charge
CzechiaÚmrtní listMatriční úřad (civil registry office); the certificate is issued within 30 days
SlovakiaÚmrtný listMatrika (civil registry) at the place of death
RomaniaCertificat de decesS.P.C.L.E.P. or the town hall (primăria) at the place of death; the death is registered within 3 days
AustriaSterbeurkundeStandesamt (registry office); the death must be reported no later than the next working day
GermanySterbeurkunde, Auszug aus dem Sterbeeintrag or Bescheinigung über die ZurückstellungStandesamt at the place of death
The NetherlandsOverlijdensakte or an extract from itThe municipality
FranceActe de décèsThe town hall (mairie); the institution where the person died must declare the death within 24 hours
ItalyEstratto di morteUfficio di Stato civile of the comune
SpainCertificado de defunciónRegistro Civil
The United KingdomA certified copy of the death certificateThe registrar; if an investigation is under way, a coroner's interim certificate
IrelandDeath certificateThe registrar, Civil Registration Service
CroatiaIzvadak iz matice umrlih / smrtni listMatični ured (registry office)
BulgariaAn extract from the death recordThe local civil registry authority

A pitfall: the “temporary” document in Germany

In Germany, if the registration of a death is postponed, a Bescheinigung über die Zurückstellung eines Sterbefalls is issued instead. It is enough for a burial in Ukraine, but not for inheritance matters. For those, the full certificate has to be ordered separately. We tell the family at once which document they will receive and what it can be used for.

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Apostille or legalisation

A document issued in another country has no effect in Ukraine by itself. It has to be certified. There are two ways.

Apostille

Ukraine has joined the Hague Apostille Convention. For countries that are parties to the Convention, an apostille replaces consular legalisation. It is a special stamp that an authority of the country that issued the document places on it.

Who places the apostille depends on the country. In Germany it is the Bezirksregierung or the Regierungspräsidium. In the Netherlands it is the local court (Rechtbank). Without an apostille, a document on the registration of a death is not valid for Ukraine, and the coffin or the urn will not be allowed in.

Consular legalisation

If the country is not a party to the Hague Convention, the document goes through consular legalisation. This is a longer route through several offices. For such countries we give the timing separately.

When no certification is needed

Ukrainian rules make an exception if an international treaty provides otherwise. Some treaties exempt documents from certification. We check whether such an exception applies in your case for the particular country.

The certificate of no prohibited items for the border is a separate matter. The law requires it to be legalised by the Ukrainian consulate. We arrange this with the consulate in the country where the death occurred.

Translation into Ukrainian

The consul accepts foreign documents with a translation into Ukrainian, and the translation must also be certified. The same applies in Ukraine: documents in a foreign language are submitted to the civil registry offices together with a certified translation.

What the law says:

  • In Ukraine a notary certifies the accuracy of a document translation if the notary knows the languages; otherwise a translator translates and the notary certifies the translator's signature (Art. 79 of the Law on Notaries). zakon.rada.gov.ua

It is not only the certificate that has to be translated. In Germany the embassy also requires a translation of the body passport (Leichenpass), the document for transporting the body. In Austria, a translation into Ukrainian is on the embassy's list of documents. In France the embassy may translate the French death certificate itself if the body or ashes are being taken to Ukraine.

Our advice: do not order a translation blindly. First find out which documents the consulate will accept, and in what form, so that you do not pay twice. We prepare translations to meet the requirements of the particular authority. You can read how we handle all the documents on the page “Arranging the documents to bring the deceased home”.

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Languages: Ukrainian, English, Polish, German. The same number works on Viber, WhatsApp and Telegram.

The Ukrainian certificate from the consul

On the basis of the local documents, a consul of Ukraine can register the death and issue a Ukrainian death certificate, and with it a certificate for the funeral allowance. How this works, what it costs and where the nearest consulate is: see the article “The Ukrainian consulate when someone dies abroad”.

How a foreign certificate is recognised in Ukraine

A foreign death certificate is recognised in Ukraine if it has been legalised or, where the country is a party to the Hague Convention, if it carries an apostille, unless an international treaty says otherwise.

What this means in practice:

  • For the border. The death certificate is the first document shown to the customs officer, together with the certificate of no prohibited items.
  • For a funeral in Ukraine. You will need a death document. It is easier to have either the Ukrainian certificate from the consul or the foreign one with an apostille and a translation.
  • For inheritance and banks. The document must be the full one, not a temporary one, with an apostille and a certified translation.

Whether the death has to be registered a second time in Ukraine, please confirm with the civil registry office. We will advise what will be simpler for your affairs.

Questions about the death certificate

Who can obtain a death certificate abroad?

It depends on the country. We find out the local rules ourselves. Relatives, the hospital, the authorities of the country and other people can apply to the consul of Ukraine to register the death.

How long will the certificate take?

It varies. In Poland the death record is drawn up on the same day the death is registered. In Czechia the certificate is issued within 30 days. How long registration at the consulate takes depends on how quickly the local documents are ready. We work on the local side and the Ukrainian side at the same time.

Why is an apostille needed if the certificate already has a seal?

The seal confirms the document only in the country where it was issued. An apostille makes it valid for Ukraine. Without an apostille (or legalisation), the consul will not accept the document and Ukraine will not recognise it.

Can the certificate be translated in Ukraine?

Yes, if the translation is certified in the way the authority requires. But the consulate abroad often asks for the translation before it registers the death, so the translation is usually made there rather than in Ukraine.

Do I need a death certificate to transport an urn with ashes?

Yes. The same rules apply to an urn as to a coffin: a death certificate and a certificate of no prohibited items that has been legalised by the Ukrainian consulate. Transporting an urn costs from €100, depending on the country.

We only have the medical certificate. Is that enough?

Usually not. To take a body out of most countries, the medical document alone is not enough: a certificate from the register is needed. In Belgium, for example, a permit to take the body out is not given without an acte de décès, and in Spain the certificate is issued by the Registro Civil. The medical document is the basis for registration. We will take care of the rest.

How much does it cost to get the certificate?

In Poland the short extract of the death record is issued free of charge, and the registration of a death by a consul of Ukraine carries no fee either. The apostille and the translation are paid for. When we bring the body home, we arrange both ourselves and they are already included in the price of the transport. We will tell you in advance what exactly your total includes.

The document has been lost. What should we do?

Tell us where the death was registered, and we will tell you where to apply for a replacement.

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