Is an Australian grant of probate recognized in Israel, or do I need a separate Israeli order?

An Australian executor holds a grant of probate from the Supreme Court of New South Wales, walks into the process expecting it to open the deceased's Tel Aviv bank account, and hits a wall. The grant is valid and properly issued. It simply has no direct force in Israel, and the sooner an executor accepts that, the sooner the Israeli side of the estate actually moves.

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Detailed Explanation

Some legal systems recognise each other's grants through resealing, where a grant issued in one country is stamped and given effect in another with a shared legal heritage. Israel is not part of that arrangement. It does not reseal an Australian, British, or any other foreign grant, and it does not treat a foreign probate as automatically operative over Israeli assets. Instead, under the Succession Law 1965, the estate's Israeli assets need their own Israeli order, obtained from the Inheritance Registrar (Rasham HaYerushot).

Which Israeli order depends on whether there is a will. If the deceased left a will, the heirs apply for a will execution order (tzav kiyum tzavaa); if there is no will, they apply for a succession order (tzav yerusha) distributing the Israeli assets under the statutory rules. The Australian grant does not disappear from the picture: it is filed as supporting evidence of the death, the will, and the executor's authority, and the Israeli process is generally faster and cheaper where a clean foreign grant already exists. But the document an Israeli bank, broker, or the Land Registry (Tabu) will actually rely on is the Israeli order, not the Australian one.

For an Australian executor handling this from afar, the mechanics are manageable but exacting. The grant and the will are authenticated by apostille through the Department of Foreign Affairs and Trade (DFAT), then translated into Hebrew by a recognised translator. An Israeli lawyer, acting under a power of attorney, files the application with the Inheritance Registrar so the executor does not need to travel. The path mirrors what we describe in our guide to an Australian executor administering an Israeli estate, where the Israeli order sits at the centre of everything that follows.

The recurring mistake is treating the Australian grant as the finish line. Executors present it to an Israeli bank, are told it is not enough, and only then begin the Israeli application, having lost weeks or months. The Israeli order can be applied for early, in parallel with winding up the Australian estate, and starting it promptly is the single biggest lever on how long the Israeli assets stay frozen. Where an heir or the will's validity is contested, the matter moves from the Registrar to the Family Court and the timeline lengthens considerably.

In Practice: Israel does not reseal a foreign grant; under the Succession Law 1965, an estate with Israeli assets needs its own succession order (tzav yerusha) or will execution order (tzav kiyum tzavaa) from the Inheritance Registrar (Rasham HaYerushot). The Australian grant, apostilled through DFAT and translated into Hebrew, is filed as supporting evidence; the Registrar's fee is about NIS 500 plus roughly NIS 130 for publication, and an uncontested order typically issues within 6 to 14 weeks, with legal fees for a foreign-heir file commonly NIS 8,000 to 20,000.

Key Considerations

• Israel does not reseal or automatically recognise an Australian grant of probate.
• An estate with Israeli assets needs its own Israeli succession order or will execution order under the Succession Law 1965.
• The Australian grant is filed as supporting evidence, apostilled through DFAT and translated into Hebrew.
• Israeli banks and the Land Registry act on the Israeli order, not the foreign grant.
• Apply for the Israeli order early and in parallel; a contested case moves to the Family Court and takes longer.

When to Consult a Lawyer

This question typically requires professional legal advice when:

• An Israeli bank or the Land Registry has refused to act on your Australian grant and you need the Israeli order.
• The will's validity, an heir's identity, or the distribution is disputed, pushing the matter to the Family Court.
• The estate spans assets in both countries and you need the Australian and Israeli processes coordinated.

A qualified Israeli attorney can obtain the Israeli order under a power of attorney so you administer the Israeli assets without travelling.

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Speak With an Israeli Attorney

We act for Australian executors and heirs on the Israeli side of an estate, obtaining the succession or will execution order from the Inheritance Registrar and dealing with the banks and Land Registry so the Israeli assets are released.

Contact us for a confidential consultation about your Israeli legal matter.