European Succession Regulation (Europäische Erbrechtsverordnung)

The European Succession Regulation (EU) No 650/2012 (‘the Regulation’), also known as Brussel IV, enacted on July 4, 2012, became effective on August 17, 2015. It applies to all deaths on or after 17 August 2015, and will be binding on all 27 EU member states, except for Denmark, the UK and Ireland. Its objective is to provide a single uniform system for the recognition of inheritance, planning and administration law and the introduction of the European Certificate of Succession. 

The applicable law under the Regulation is that of the country of the deceased's habitual residence at the time of death, unless:

  • The deceased was manifestly more closely associated with another state; or
  • The deceased has elected as the law to govern his succession the law of the State whose nationality he possesses at the time of making the choice or at the time of death.

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