Is a UK grant of probate enough to inherit Israeli assets, or do I need an Israeli order?

A UK executor who has just spent months obtaining a grant of probate from the Probate Registry naturally assumes it is the master key to the deceased's entire estate, including the flat in Netanya or the account at Bank Leumi. When the Israeli bank asks for an Israeli order instead, the executor's first reaction is disbelief. The reality is that Israel runs its own probate process and does not simply accept a foreign grant.

---

Detailed Answer

Israeli succession is governed by the Succession Law 1965 (Hok HaYerusha), administered by the Registrar of Inheritance (Rasham HaYerushot) within the Ministry of Justice, with contested matters going to the Family Court. To deal with assets situated in Israel, the personal representatives need either a succession order (tzav yerusha) where there is no will, or a will execution order (tzav kiyum tzava'a) where there is one. These Israeli orders are the documents an Israeli bank, the Land Registry (Tabu), and a share registrar will recognise. A foreign grant is not one of them.

Israel is not part of any resealing arrangement that would let a UK grant be stamped and treated as an Israeli order. Some Commonwealth jurisdictions reseal one another's grants under reciprocal legislation; Israel does not participate in that scheme. Instead, the UK grant and the underlying will function as evidence within a fresh Israeli application. Where the deceased left a will, the Israeli process is usually an application for a will execution order recognising and giving effect to that will over the Israeli assets. Where the will was already proved in England, the Israeli Registrar will want the will, the grant, and the death certificate, all properly authenticated, to issue its own order.

For a UK executor the practical sequence is document-led and can be run entirely from Britain. The English grant of probate, the will, and the death certificate must each be apostilled by the UK Foreign, Commonwealth and Development Office, then translated into Hebrew, typically with an Israeli notary's certification. An Israeli attorney holding an apostilled power of attorney files the application with the Inheritance Registrar on the executors' behalf, so no one needs to travel to Israel. The Israeli order, once issued, is then presented to the bank or the Land Registry to release or re-register the asset. Heirs sometimes ask whether they can skip the Israeli step for a small bank balance; banks will not pay out meaningful sums without the Israeli order, so the process is rarely avoidable. The broader question of when a foreign will is accepted at all is addressed in the guide on the validity of foreign wills in Israel.

In Practice: Under the Succession Law 1965, the Registrar of Inheritance (Rasham HaYerushot) issues the succession or will execution order that Israeli banks and the Land Registry (Tabu) require — a UK grant of probate is not resealed and does not substitute for it. The application costs NIS 543 plus a NIS 136 publication fee, and an uncontested order is typically issued in 3 to 5 months, after the UK grant, will, and death certificate have been apostilled by the FCDO and translated, which adds roughly 2 to 4 weeks.

Key Considerations

• A UK grant of probate does not transfer Israeli assets by itself
• Israel does not reseal foreign grants; a separate Israeli order is mandatory
• The UK grant, will, and death certificate serve as evidence in the Israeli application
• All UK documents must be apostilled by the FCDO and translated into Hebrew
• An Israeli attorney with power of attorney can run the entire process from the UK

When to Consult a Lawyer

This question typically requires professional legal advice when:

• The deceased left assets in both the UK and Israel and you need the two estates handled in step
• There is a single will meant to cover worldwide assets and you are unsure how it interacts with the Israeli order
• An Israeli bank or the Land Registry has already refused to act on your UK grant

A qualified Israeli inheritance attorney can confirm whether a will execution order or a succession order is needed and file it using the authenticated UK documents.

---

Speak With an Israeli Attorney

UK executors lose months assuming the English grant will be enough in Israel. We can obtain the correct Israeli order from your existing UK documents and present it to the bank or Land Registry to release the asset.

Contact us for a confidential initial consultation.