Wills don’t travel, and neither do the rules behind them
A general overview, not legal advice, of how will rules vary between countries and which cross-border rules decide the law that applies


Three legal traditions
Most of the world’s wills fall into one of three legal families
Common-law
Descended from the Wills Act 1837: a written will and two witnesses, no notary. Used across much of the Commonwealth and the US.
Civil-law
Usually signed before a notary, who keeps the original. Common in continental Europe and Latin America, often with forced-heirship shares for children.
Mixed / holographic
Handwritten, signed wills with no witnesses. Accepted in many US states, France and Spain; others allow them only in emergencies, or not at all.
This is a general overview, not legal advice. Specific rules vary by jurisdiction. Consult a qualified professional in yours.

Frequently asked questions
Start a will in your jurisdiction
Begin with the rules of the place you live, and read the guides for anywhere else you are connected to

