Thousands of diaspora families divorce in Israel every year, then go back to lives in the US, UK, Germany, France, Canada, or Australia. The divorce is valid in Israel the moment the Rabbinical Court issues the get or the Family Court signs its decree. But to a New York government office, a German Standesamt, or a British solicitor arranging a second marriage, that Israeli proceeding is a foreign legal event they have to evaluate on their own terms.
If recognition fails, the consequences are real. Remarrying before the destination country has recognized your Israeli divorce can expose you to bigamy charges under local law. Children from the second marriage may face legitimacy questions. Pension, inheritance, and social security entitlements all tie back to marital status being correctly recorded where you live. And the longer you wait to sort this out, the harder it gets — the documents exist in Israel, not in whatever country you are living in a decade later.
What follows covers the countries where most of this site's readers end up: the US, UK, Germany, France, Canada, and Australia.
1. The two types of Israeli divorce, and why both matter
Israel has no secular civil marriage or divorce. Matrimonial status is governed by religious law, and which forum can dissolve a marriage depends on the religious affiliation of the parties:
- Jewish couples must obtain a get (גט), a religious bill of divorce issued by a Rabbinical Court (beit din) under the Rabbinical Courts Jurisdiction (Marriage and Divorce) Law 5713-1953. Without a get, neither spouse can remarry under the Jewish religious system regardless of any other court order. The husband must give the get and the wife must accept it, which is why get refusal (discussed in Section 8) can trap a woman in a marriage even after a court has ordered the husband to comply.
- Muslim couples divorce under Sharia law in the Muslim religious courts. Christian couples and members of other recognized religious communities divorce in their respective courts. Couples with no religious affiliation who married abroad under a civil system are divorced by the Family Court using the law of their place of marriage.
For Jewish couples, the process usually produces two separate legal events. The Rabbinical Court issues the get, a purely religious document. The Family Court, in parallel proceedings, handles the financial settlement, property division, child custody, and support. Both courts notify the Population and Immigration Authority (PIBA), which updates the Population Registry to show the divorced status. The date of the get delivery, not the Family Court property order, is the date Israel treats the marriage as dissolved.
That dual structure is exactly why recognition gets complicated abroad. The UK treats the Rabbinical Court get itself as a valid judicial proceeding and recognizes it directly. Germany requires a civil court order and may not accept a purely religious procedure at all.
2. The documents you need before leaving Israel
Before you leave Israel after a divorce, collect all of these. Each serves a different purpose depending on where you are going, and obtaining them later from abroad is slow and expensive.
- Population Registry extract (teudat matzav mishpachti / ishur rishum): An official government certificate from PIBA showing your name, Israeli ID number, current marital status ("divorced" / "garusha" or "garush"), and the date the status changed. This is the most universally useful document — a clean government record rather than a court document, and most foreign authorities recognize it immediately. It costs approximately NIS 30 to 60 at any PIBA office or through the gov.il portal.
- Family Court divorce decree (psak din legeirushin): If the Family Court issued a property or custody order, obtain a certified copy bearing the court's stamp and the date of issue. Request it from the court registry where the proceedings were heard. Court fee: approximately NIS 100 to 200 per certified copy.
- Rabbinical Court get certificate (te'udat gerushin): The certificate issued by the Rabbinical Court confirming that the get was delivered and accepted on the stated date. Request this from the Rabbinical Court registry. If you cannot locate the original beit din, PIBA can sometimes reissue a certificate of the marital status change that identifies the Rabbinical Court that processed the get.
Get at least three certified copies of each document. Authenticating additional copies from abroad takes time and money you would rather not spend.
3. Getting an apostille on Israeli documents
Israel is a signatory to the Hague Apostille Convention (the 1961 treaty that eliminates the need for full legalization between member states). An apostille is a standardized certificate attached to a public document that makes it automatically acceptable in all other member states. Every country covered in this guide is also a member.
In Israel, the Ministry of Foreign Affairs Consular Division apostilles government-issued documents and court judgments, and court secretariats apostille notarial documents, for about NIS 41 per document at the time of writing (updated every January). Not every document goes straight to the MFA — the path depends on what you are apostilling:
- PIBA Population Registry extracts: The MFA apostilles these directly. Bring or mail the original PIBA-issued extract with a payment receipt. The MFA service operates in Jerusalem, with mail and drop-box options. The fee is about NIS 41 per document, not per page, at the time of writing; check the current fee.
- Family Court divorce decree: A court document must first be certified by the court registry with the court's official stamp and the registrar's signature. The apostille on the court decree is then issued by the MFA; total time is usually 2 to 5 business days.
- Rabbinical Court get certificate: Must first be authenticated by the Rabbinical Court's own registrar (the rabbinical court stamp and dayanim / judges' signatures). Then certified by the Rabbinical Courts Administration (Netziv HaBatei Din) in Jerusalem. Then the MFA apostille is affixed. Allow 5 to 10 business days for the full chain, longer if the original beit din is outside the main cities.
After apostilling, have the document professionally translated into the official language of the destination country. The apostille itself is in French (the Convention's working language) plus Hebrew. The underlying document remains in Hebrew and must be translated by a certified translator recognized by the country where you will use it.
4. Recognition in the United States
There is no federal law governing recognition of foreign divorces in the US. Each state applies its own conflict-of-laws rules. Most states follow the doctrine of comity: recognition goes through if the foreign country had proper jurisdiction, both parties received adequate notice, and recognition would not violate a fundamental state policy.
For an Israeli Family Court divorce, recognition is usually straightforward when:
- At least one spouse was resident in Israel at the time of the proceedings (establishing jurisdiction).
- The other spouse received actual notice of the proceedings — either participated directly or was properly served.
- The proceedings produced a written court order (not only a get).
A get without any accompanying civil court order is more vulnerable. Courts in New York, California, and New Jersey have reached different results depending on whether Rabbinical Court proceedings count as "judicial" for comity purposes. New York's Domestic Relations Law Section 253 specifically requires a civil court order for remarriage in some circumstances, and New York courts have held that a get alone may not satisfy this. If you divorced in Israel and plan to live in New York, get both the get certificate and a Family Court order even if no property was divided. The Family Court can issue a simple decree confirming the dissolution, and that is enough.
For US immigration purposes, USCIS requires an apostilled and certified-translated copy of the divorce decree when a petitioner or beneficiary claims to be divorced. The Population Registry extract showing divorced status is generally also accepted as supporting evidence. Consular officers at US embassies will request the actual court order for immigrant visa applications where prior marriages are disclosed.
5. Recognition in the United Kingdom
The Family Law Act 1986, Part II (Sections 45 to 54) governs recognition of overseas divorces in England and Wales. Scotland and Northern Ireland have parallel provisions. Under Section 46(1), an overseas divorce is recognized if it was obtained by means of judicial or other proceedings in a country where, at the date of the divorce, either spouse was habitually resident, domiciled, or a national of that country.
Israel is not a member of the EU, so EU Regulation 2019/1111 (Brussels IIb) does not apply. The 1986 Act applies directly.
Two things matter for UK recognition of Israeli divorces:
- Israeli Family Court decrees are recognized as "judicial proceedings" under Section 46(1) without difficulty, provided at least one spouse was habitually resident or domiciled in Israel at the time, or was an Israeli national.
- Israeli gets issued by the Rabbinical Court have been recognized in England and Wales as valid "other proceedings" under Section 46(2). The Court of Appeal confirmed in El Fadl v El Fadl [2000] that a get can qualify as "proceedings." The Rabbinical Court is a public tribunal with defined procedure, and the get is issued under its supervision, not merely a private agreement between spouses. UKVI and the General Register Office both accept apostilled get certificates for marital status purposes, provided the Section 46 conditions are met.
For remarriage in England and Wales, the Register Office will ask for your divorce document, an apostille, and a certified translation. The MFA-apostilled Population Registry extract showing your divorced status, together with the underlying court order or get certificate, satisfies this requirement in practice.
6. Germany and the EU: the formal recognition procedure
Germany is the most important EU country to address separately. It has a specific statutory procedure for recognizing non-EU divorces under Section 107 of the Gesetz über das Verfahren in Familiensachen und in den Angelegenheiten der freiwilligen Gerichtsbarkeit (FamFG). Under Section 107, a divorce from outside the EU is not recognized in Germany unless the competent state justice authority (Landesjustizverwaltung) has issued a formal recognition decision.
Put differently: even if Israel considers you divorced, and the US and UK accept that divorce, you remain legally married in Germany until you complete Section 107. Remarrying in Germany without a recognition decision is bigamy under German law.
The Section 107 application goes to the Landesjustizverwaltung of the German federal state where you are registered (or, if not registered in Germany, the Berlin Senate Department of Justice). You need:
- The apostilled Israeli divorce decree or get certificate, with a certified German translation.
- Evidence of notice — confirmation that the other spouse was properly served in the Israeli proceedings.
- A statement confirming neither party contested the divorce in a German court.
- Proof of your current address in Germany (Meldebestätigung).
A get without any Israeli court order creates real difficulty here. German authorities require a judicial proceeding and may refuse to recognize a purely Rabbinical Court get as satisfying that standard. If you divorced in Israel using only the Rabbinical Court process and plan to live in Germany, talk to an Israeli family lawyer before leaving about whether you need a supplementary Family Court order.
Processing time for Section 107 recognition is typically 2 to 4 months. Once granted, the decision is entered in the German civil status system and clears the way for remarriage there.
Other EU countries that require equivalent formal recognition for non-EU divorces include Austria (Section 97 IPRG), Switzerland (not EU but follows a similar approach under Article 65 IPRG), and France (where a get without a civil order may face an ordre public challenge based on gender equality). Nordic countries (Sweden, Denmark) generally recognize foreign divorces more liberally under their private international law statutes if domicile is established.
7. Canada and Australia
Canada. Divorce is federal in Canada. The Divorce Act R.S.C. 1985 c.3 governs dissolution of marriages, and Section 22 of the same Act governs recognition of foreign divorces: Canada recognizes a foreign divorce if either spouse was ordinarily resident in the foreign country for at least one year before the proceedings began. An Israeli divorce will be recognized in all Canadian provinces if one spouse was ordinarily resident in Israel for at least a year before the Israeli proceedings started. The traditional domicile test has largely been displaced by this habitual residence standard.
Canadian authorities — provincial vital statistics offices, Service Canada, CRA — accept an apostilled PIBA extract as primary proof of divorced status, typically accompanied by an English or French certified translation.
Australia. The Family Law Act 1975 (Cth) Section 104 provides for registration of overseas divorces. Australia recognizes a foreign divorce if it was obtained in accordance with the law of the foreign country and is not contrary to Australian public policy. If one spouse was domiciled or habitually resident in Israel at the time of the divorce, that is enough for recognition. Documents needed: an apostilled copy of the Israeli divorce decree or PIBA extract, with a certified English translation. The Department of Home Affairs accepts these for immigration purposes, and state and territory registries of births, deaths and marriages accept them for remarriage applications.
8. The get-only complication: when the religious divorce creates problems abroad
Under Israeli law, the get issued by the Rabbinical Court is the legal divorce for Jewish couples — it ends the marriage in Israel's eyes. The Population Registry records this date as the divorce date. But abroad, a get is a religious document rather than a court order, and civil law systems treat those very differently.
The problems that come up:
- Gender equality concerns: The get can only be given by the husband and accepted by the wife, never the other way around. European civil law systems, particularly France under ordre public grounds, have refused to recognize a get as equivalent to a civil divorce because the whole process is built around the husband's unilateral power to grant or withhold it. French courts have held that a procedure placing the power to divorce exclusively in the husband's hands violates French public policy.
- Absence of court order: Germany's Section 107 FamFG procedure requires recognition of a "judicial proceeding." A purely Rabbinical Court get may not satisfy this requirement, depending on how the relevant Landesjustizverwaltung characterizes the Israeli Rabbinical Court.
- US state-by-state variation: New York's DRL Section 253 creates a procedural barrier for parties seeking to use a get without a civil decree for remarriage in some contexts.
The fix in all these countries is the same: get a Family Court order alongside the get, even if the order does nothing more than formally declare the marriage dissolved. Israeli Family Courts issue these routinely. An order from the Jerusalem or Tel Aviv Family Court is an unambiguous civil judicial proceeding that passes even the most demanding foreign recognition tests.
9. Practical checklist before leaving Israel after a divorce
Before you leave Israel:
- Get at least three certified copies of the get certificate from the Rabbinical Court registry.
- Get at least three certified copies of the Family Court decree (if one was issued).
- Get at least three Population Registry extracts from PIBA showing divorced status and the date — specify you need them for use abroad.
- Apostille all documents at the MFA. Scan everything before handing it over to any authority; you will not get originals back.
- Get certified translations into the language of each destination country. In Israel, use a sworn translator (metargem meushrar).
- If you divorced by get only and plan to live in Germany, France, or certain US states, talk to an Israeli family lawyer about getting a supplementary Family Court order before you leave. Total cost runs around NIS 3,000 to 8,000 in attorney fees plus the NIS 368 filing fee — far less than sorting out a recognition problem from another country years later.
- Update your Population Registry record with PIBA. The Israeli passport does not show marital status, but keeping the registry current prevents mismatches across government systems.
Frequently Asked Questions
There is no automatic recognition. US states apply comity principles on a case-by-case basis and will recognize an Israeli divorce if the Israeli court had proper jurisdiction, both spouses received notice, and the proceedings did not violate due process or US public policy. In practice, most Israeli Family Court decrees are accepted with a certified translation and apostille. A get issued by the Israeli Rabbinical Court without any accompanying civil order creates more uncertainty in some states — obtain both the religious and civil documents where possible.
Most countries find the Population Registry extract (teudat matzav mishpachti) most useful because it is a government-issued certificate that states your current marital status as "divorced" and the date the divorce took effect. Apostille it at the Israeli Ministry of Foreign Affairs (fee about NIS 41 per document at the time of writing) and have it professionally translated into the language of the destination country. Some jurisdictions — USCIS in the US and the German Landesjustizverwaltung — additionally ask for the underlying court order or get document.
Yes. Under Section 107 of the German Act on Procedure in Family Matters (FamFG), a divorce obtained in a non-EU country including Israel is not automatically recognized in Germany. You must apply to the competent state justice authority (Landesjustizverwaltung) in the German federal state where you are registered. Submit the apostilled Israeli divorce decree or Rabbinical Court get certificate with a certified German translation and evidence that both parties had proper notice of the proceedings. Processing typically takes 2 to 4 months. Without this formal recognition, German authorities treat you as still married regardless of your Israeli status.
It depends on the country. The UK Family Law Act 1986 explicitly recognizes overseas divorces "obtained by means of proceedings," and English courts have held that an Israeli get conducted under Rabbinical Court supervision qualifies. France, Germany, and most EU civil-law systems are more skeptical — they generally require a judicial order and may refuse to recognize a purely religious proceeding. Canada and Australia follow the domicile-based approach and generally recognize an Israeli get if one spouse was ordinarily resident in Israel at the time. In the US, recognition varies by state. Where in doubt, obtain a civil Family Court decree alongside the get before leaving Israel.
Bring the original Population Registry extract to the Ministry of Foreign Affairs apostille service in Jerusalem, in person, by mail or through its drop boxes; a certified copy of a court order goes to the same service. The Ministry affixes the apostille under the Hague Convention of 5 October 1961, for about NIS 41 per document at the time of writing (updated every January). Processing is typically a few business days. An apostille is valid indefinitely for the document it accompanies — there is no expiry date. Documents issued by a Rabbinical Court must first be certified by the Rabbinical Court's registrar before the MFA will apostille them.