Inheritance & Probate

Does a foreign grant of probate need to be resealed in Israel?

No. Israel has no resealing procedure for foreign probate grants of the kind used between Commonwealth countries. A grant issued by a court in England, the United States, or anywhere else has no direct legal effect over assets located in Israel. To release Israeli bank accounts, securities, or real estate, the heirs must either apply to the Israeli Registrar of Inheritance Affairs for a fresh Israeli order under the Succession Law 5725-1965, or have the foreign order formally recognized by an Israeli court.

Israel never joined the Commonwealth resealing system, so a foreign grant of probate or letters of administration cannot simply be stamped and given local force. Israeli banks, the Companies Registrar, and the Land Registry (Tabu) treat assets situated in Israel as governed by Israeli succession procedure. The standard route is a fresh application to the Registrar of Inheritance Affairs for an Israeli probate order (tzav kiyum tzavaa) where there is a will, or a succession order (tzav yerusha) where there is none. The Registrar examines the will or the heirship and issues an order that Israeli institutions will honor. Where a foreign court has already ruled, an heir may instead ask the Family Court to recognize that judgment under the rules governing foreign wills and orders, but a fresh Israeli order is often faster.

For a foreign family, the practical effect is that the estate must be addressed twice: once in the home country for assets there, and separately in Israel for the Israeli assets. Documents proving the death and the foreign grant must be apostilled and translated into Hebrew, and a notarized power of attorney lets an Israeli lawyer act without the heirs traveling. A common mistake is assuming the bank will release funds on a foreign death certificate or grant alone. It will not. Starting the Israeli application early matters, because objections, missing heirs, or contested wills can extend the timeline by months.

⚖ In Practice
  • Governing law: Succession Law 5725-1965; recognition of foreign judgments under the Foreign Judgments Enforcement Law 5718-1958
  • Competent authority: Registrar of Inheritance Affairs (HaRasham LeInyenei Yerusha); Family Court for contested or recognition cases
  • Fees: succession or probate order application approximately NIS 530, plus an opening fee of approximately NIS 530 (2026)
  • Timeline: roughly 3 to 6 months for an uncontested order; longer if there are objections or missing heirs
  • Documents: apostilled foreign death certificate and grant, Hebrew translations, and a notarized power of attorney for an Israeli representative

From the full guide: The Probate Process in Israel: A Step-by-Step Guide


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