Getting married or entering a PACS abroad: the guide

Getting married or entering a PACS while living abroad is perfectly doable — as long as you plan ahead. Between the documents you need before the ceremony, the essential transcription on French registers, and the matrimonial regime that shapes your entire financial life together, there are plenty of pitfalls waiting for the unprepared. Here is what expat couples need to know in 2026.

Getting married civilly abroad: the basic conditions

What French law requires of you

Even if you marry abroad, a French national remains subject to the substantive requirements of French law (Article 202 of the Civil Code): legal capacity to marry, no prohibited family relationship, free and informed consent. French law applies to each French spouse, regardless of the country of celebration and the nationality of the other partner.

In practice, before setting a wedding date abroad, you must obtain a certificat de capacité à mariage (certificate of no impediment to marriage) from the French consulate in your country of residence. This document certifies that you meet the conditions set by French law. Without it, the local registrar may refuse to celebrate the marriage — and more importantly, any subsequent transcription in France will be compromised.

Publication of banns

The French consulate generally requires the publication of banns (a public notice of the intended marriage) for ten days, as in France. This formality takes place at the consulate itself. Factor this lead time into your schedule: it cannot be done on the day of the ceremony.

Documents to gather

The full list is available on service-public.fr, but these are the documents most commonly required:

• Identity document and proof of residence abroad
• French birth certificate less than 3 months old (or less than 6 months for a marriage in the EU)
• Proof of dissolution of any previous marriage (divorce decree or death certificate)
• In some countries: a certificate of custom or certificate of celibacy required by local authorities

Processing time for the certificate of no impediment varies by consulate: allow 2 to 6 weeks on average. Do not underestimate this if you are booking a venue with fixed dates.

Transcription of the marriage on French civil registers

Why it is essential

A marriage celebrated abroad according to local forms is recognised in France provided it was validly celebrated by the competent local authority. But without transcription on the French civil registers, that marriage has no legal effect in France: you remain legally single in the eyes of French authorities (tax office, social security, inheritance, and so on).

Transcription is therefore the critical step. You request it from the French consulate in the country where the marriage was celebrated, or directly from the Service central de l’état civil (SCEC) in Nantes if you have already returned to France.

The process step by step

1. Submit the transcription request at the consulate with the original foreign marriage certificate, translated by a sworn translator (see the pitfalls section below), together with an apostille if the country is a signatory to the Hague Convention.
2. The consulate checks that the marriage complies with French substantive requirements.
3. If validated, the consulate transcribes the record on its civil registers.

Average processing time: 3 to 6 months depending on the consulate’s workload and the complexity of the file. Some under-resourced consulates (parts of Africa, South-East Asia) may exceed this. The request can be submitted at any point after the marriage — there is no statutory limitation period — but the longer you wait, the more likely some documents (birth certificate, certificate of celibacy) will have expired and need renewing.

Official procedures are detailed on diplomatie.gouv.fr.

The PACS at the consulate

An underrated and often overlooked option

A PACS (civil partnership) can be entered into abroad at the competent French consulate or embassy. This is a useful option for couples who do not wish to (or cannot) marry under local forms, or who prefer a more flexible legal arrangement.

Since 2017, PACS agreements are no longer registered at the tribunal but directly at the town hall in France, and at the consulate abroad. The consular procedure is available to couples where at least one partner holds French nationality.

Documents required

• PACS agreement signed by both partners (Cerfa form no. 15726)
• Joint PACS declaration (Cerfa form no. 15725)
• Identity documents and birth certificates for both partners
• Sworn statement confirming no family relationship, common residence, and the absence of any existing PACS or marriage

The consulate registers the PACS, then forwards it to the Service central de l’état civil, which adds a note in the margin of both partners’ birth certificates. This registration step generally takes 2 to 4 weeks after the consular recording.

Matrimonial regime: a choice that shapes your entire financial life

The applicable law: EU regulation 2016/1103

This is the point that almost every expat couple handles poorly. Since 29 January 2019, EU Regulation 2016/1103 determines which country’s law governs your matrimonial property regime when you have ties to more than one country.

In the absence of an express choice, the applicable law is that of the country of first common habitual residence after the marriage. If you settle in Spain right after your wedding, Spanish law will govern your assets — even if you are both French nationals.

This “imposed regime” can have significant consequences:

• In Spain or Portugal, the default legal regime is community of property (similar to the French régime de la communauté réduite aux acquêts, but with regional variations in Spain).
• In Dubai and the UAE, local law (influenced by sharia for nationals) does not apply in the same way to non-Muslim expats; foreign marriages are in principle recognised, but property matters are complex and require local legal advice.
• In some countries outside the EU, the very concept of separation of assets does not exist.

How to choose and formalise your regime

You can choose the law applicable to your matrimonial regime before or after the marriage, by notarial deed. The eligible laws are limited by EU Regulation 2016/1103 (the law of habitual residence or the nationality of either spouse at the time of the choice).

A French notary, even if you live abroad, can draw up this deed. Some consulates have access to legal advisers. If you are based in Spain or Portugal, also consult a locally qualified notary who specialises in private international law.

Not making an explicit choice means letting the law decide for you — often with consequences you never anticipated.

Same-sex marriage abroad

France has recognised same-sex marriages celebrated abroad since 2013, provided the marriage was validly celebrated under local law. The transcription follows the same procedure as for any other marriage.

The situation varies considerably depending on your host country, however:

• In the EU (Germany, Netherlands, Belgium, Spain, Portugal…), same-sex marriage is legally recognised and the ceremony can follow local forms.
• In countries like Dubai or many states in Africa and the Middle East, homosexual relationships are criminalised. Marriage is impossible, and simply having a same-sex marriage mentioned in official documents can expose the couple to legal risks.

If you live in a country that does not recognise your marriage, consult a lawyer specialising in international family law before taking any steps.

Summary table of key steps

Pitfalls to avoid

Marriage never transcribed. Without transcription, you are legally single in France. This affects your tax return (no access to the married couple’s household quotient), your inheritance rights, your social security entitlements on return, and potentially your partner’s right to reside in France if they are a foreign national.

Documents without apostille or sworn translation. A foreign marriage certificate without an apostille (where the country is a signatory to the Hague Convention of 5 October 1961) will be rejected at transcription. Likewise, the translation must be done by a sworn translator (an expert registered with a French court of appeal), not a bilingual acquaintance or an automated service.

Imposed matrimonial regime. As explained above, without an explicit choice of applicable law, the law of the first country of common residence applies. Some couples discover years later that they are subject to universal community of property (all assets pooled, including pre-marital ones) when they assumed they were under a separation of assets regime.

Religious ceremony only. In many countries (Morocco, Lebanon, parts of sub-Saharan Africa), a religious ceremony has no legal standing in France. Only a civil marriage, celebrated by the local civil registrar or by the consulate, can be transcribed.

For couples who have not yet formalised their situation, expat life as a couple and living abroad in general are worth reading well before you leave.

Frequently asked questions

Is a marriage celebrated only at a foreign town hall valid in France?

Yes, provided it was celebrated according to local forms by the competent authority and the substantive conditions of French law were met (which the certificate of no impediment obtained beforehand confirms). Transcription is then required for the marriage to take effect in France.

Can we enter a PACS at the consulate if one partner is not French?

Yes. It is enough for at least one partner to hold French nationality. The foreign partner will need to provide civil status documents from their country of origin, apostilled and translated where required.

How long after the wedding can we request transcription?

There is no statutory limitation period: you can request transcription years after the ceremony. However, some required documents (birth certificate, certificate of celibacy) have a limited validity and will need to be renewed. It is best to submit the request within 6 to 12 months of the wedding.

We are not sure where we will be living after the wedding. Which matrimonial regime should we choose?

This is precisely the situation where a marriage contract with an explicit choice of applicable law is recommended. Choosing French law locks you into one of the known French regimes (community of acquests or separation of assets), regardless of which country you eventually settle in. Consult a notary before the ceremony if at all possible.

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Getting married or entering a PACS abroad is not inherently more complicated than doing so in France, but it requires more advance planning. Get the certificate of no impediment early, think about transcription as soon as the ceremony is over, and above all, do not let your matrimonial regime be decided by default. If you also have questions about giving birth abroad or other family-related formalities as an expat, the dedicated guides on this site have you covered.

This guide reflects the rules in force in Q3 2026. Consular procedures change regularly: always verify information directly with the competent French consulate and on service-public.fr before starting any process.