Notarization & Witness Requirements by Country

Name: Notarization & Witness Requirements Across 36 Jurisdictions
Published: 2026-06-20
License: https://creativecommons.org/licenses/by/4.0/

Whether a legal document must be notarized or witnessed — and by how many people — varies sharply by country and by document type. This reference compares the typical execution formalities for 9 common documents across 36 jurisdictions: affidavits almost always need notarization, wills usually need two witnesses in common-law countries, and civil-law systems often require a full notarial deed for deeds, powers of attorney and prenuptial agreements.

General informational reference compiled by the Forms-Legal editorial team — not legal advice. Formalities change and vary within federal countries; confirm current requirements with a qualified local professional before relying on them. Last updated 2026-06-20.

Why notarization and witness rules differ by country

Common-law jurisdictions (the United States, United Kingdom, Australia, India, Singapore and others) treat a signed document plus witnesses as the default, reserving notaries public for specific acts such as affidavits and deeds. Civil-law systems (continental Europe, Latin America and Quebec) place a civil-law notary at the centre of important transactions: a "notarial deed" — escritura pública, acte authentique or notarielle Urkunde — is a drafted, state-backed instrument required for property transfers, prenuptial agreements and many powers of attorney. Registration regimes (land registries, probate courts, marriage registries) add further formalities. The result: an instrument valid in one country can be unenforceable in another, which is why execution requirements must be checked per jurisdiction.

Affidavit / Sworn Statement: notarization & witnesses by country

Jurisdiction	Notarization	Witnesses	Key point
Argentina	Required	0	Declaracion jurada before escribano publico or authorised authority.
Australia	Required	0	Sworn before justice of peace, solicitor, or notary.
Austria	Optional	0	Eidesstattliche Erklarung; notarized for official use.
Belgium	Not typically required	0	Declaration sur l'honneur; notarized for official proceedings.
Brazil	Required	0	Declaracao juramentada before tabeliao (notary) or sworn commissioner.
Canada	Required	0	Commissioner of oaths or notary public required by province.
Chile	Required	0	Declaracion jurada before notario; common for public-sector use.
Colombia	Required	0	Declaracion juramentada before notario or authorized official.
Denmark	Not typically required	0	Tro og love erklaering; sworn before court for formal use.
Finland	Not typically required	0	Vakuutus; sworn before court or magistrate for formal use.
France	Not typically required	0	Attestation sur l'honneur; no notary for civil declarations.
Germany	Optional	0	Eidesstattliche Erklarung; notarized for official use.
Ghana	Required	0	Sworn before Commissioner for Oaths, notary, or court.
Hong Kong	Required	0	Sworn before solicitor, notary, or commissioner for oaths.
India	Required	0	Sworn before notary, magistrate, or oath commissioner.
Ireland	Required	0	Sworn before solicitor, commissioner for oaths, or notary.
Italy	Not typically required	0	Dichiarazione sostitutiva (DPR 445/2000); self-certified declaration.
Kenya	Required	0	Sworn before Commissioner for Oaths or notary public.
Malaysia	Required	0	Sworn before commissioner for oaths, notary, or court officer.
Mexico	Required	2	Declared before notario publico; ratified with witnesses.
Netherlands	Not typically required	0	Verklaring onder ede; sworn before court or notary.
New Zealand	Required	0	Sworn before solicitor, notary, or Justice of Peace.
Nigeria	Required	0	Sworn before notary public, commissioner for oaths, or court.
Norway	Not typically required	0	Egenerklaring; sworn before court or notary for official use.
Pakistan	Required	0	Sworn before notary, oath commissioner, or judicial magistrate.
Philippines	Required	0	Notarization mandatory before notary public (2004 Notarial Rules).
Poland	Not typically required	0	Oswiadczenie; notarized or before authority for formal use.
Portugal	Not typically required	0	Declaracao sob compromisso de honra; notarized for official use.
Quebec	Required	0	Sworn before commissioner for oaths or notary; no additional witnesses.
Singapore	Required	0	Sworn before Commissioner for Oaths or notary public.
Spain	Not typically required	0	Declaracion jurada; notarized for official or foreign use.
Sweden	Not typically required	0	Skriftlig forsakran; sworn before court or notary for formal use.
Switzerland	Optional	0	Eidesstattliche Erklarung; notarized for formal proceedings.
UAE	Required	0	Notarised before notary public or via Ministry of Justice.
United Kingdom	Required	0	Sworn before solicitor, commissioner for oaths, or notary.
United States	Required	0	Notary public required; witnesses not typically mandated.

Download a free Affidavit template →

Last Will & Testament: notarization & witnesses by country

Jurisdiction	Notarization	Witnesses	Key point
Argentina	Notarial deed	3	Testamento por acto publico: escribano + 3 witnesses (CCyCN Art. 2479).
Australia	Not typically required	2	Two witnesses required; must witness simultaneously; not beneficiaries.
Austria	Optional	3	Holographic or notarial; witnessed will needs 3 witnesses.
Belgium	Optional	2	Holographic or authentic (notarial); Civil Code Art. 972.
Brazil	Notarial deed	5	Testamento publico: tabeliao + 2 witnesses; closed will: 5 witnesses.
Canada	Not typically required	2	Two witnesses required; must not be beneficiaries (most provinces).
Chile	Notarial deed	3	Testamento solemne abierto: notario + 3 witnesses required.
Colombia	Notarial deed	3	Testamento solemne abierto requires notario and 3 witnesses.
Denmark	Optional	2	Holographic or notarial; notarial via probate court (testamente).
Finland	Not typically required	2	2 witnesses mandatory; PK 10:1.
France	Optional	2	Olographic or notarial (authentic) will; Code Civil Art. 970-971.
Germany	Optional	0	Holographic or notarial will; notarial preferred.
Ghana	Optional	2	Two witnesses required; Wills Act 1971; registration recommended.
Hong Kong	Not typically required	2	Two witnesses required; must not be beneficiaries; signed by testator.
India	Optional	2	Two witnesses required; registration optional but strongly advised.
Ireland	Not typically required	2	Two witnesses required; must not be beneficiaries under the will.
Italy	Optional	2	Olographic or public (notarial); notarial needs 2 witnesses.
Kenya	Not typically required	2	Two witnesses required; Law of Succession Act Cap 160.
Malaysia	Not typically required	2	Two witnesses required; must not be beneficiaries; Wills Act 1959.
Mexico	Notarial deed	3	Testamento publico abierto before notario; 3 witnesses.
Netherlands	Notarial deed	0	Notarial will mandatory (BW Art. 4:94); codicil limited.
New Zealand	Not typically required	2	Two witnesses required; witnesses must not be beneficiaries.
Nigeria	Not typically required	2	Two witnesses required; must not be beneficiaries.
Norway	Not typically required	2	2 witnesses mandatory; AL §49+.
Pakistan	Optional	2	Two witnesses required; Muslim personal law (Sharia) governs Wasiyat.
Philippines	Required	3	Notarial will: three witnesses. Holographic will: no notary or witnesses.
Poland	Optional	2	Holographic or notarial; allographic needs 2 witnesses; KC Art. 949+.
Portugal	Optional	2	Public (notarial) or closed will; CC Art. 2204+; holographic valid.
Quebec	Notarial deed	1	Notarial will (CCQ Art. 716): notary + 1 witness; no probate.
Singapore	Not typically required	2	Two witnesses required; must not be beneficiaries.
Spain	Optional	3	Notarial (open) or holographic; open will standard; CC Art. 694.
Sweden	Not typically required	2	2 witnesses mandatory; no notarization required (AB 10:1).
Switzerland	Optional	2	Holographic or public (notarial) will; ZGB Art. 498-504.
UAE	Required	2	Non-Muslims: DIFC/ADJD Wills; Muslims: Sharia applies; registration required.
United Kingdom	Not typically required	2	Two witnesses required; neither may be beneficiary or spouse.
United States	Optional	2	Two witnesses required; notarized self-proving will common.

Download a free Last Will & Testament template →

Living Will / Advance Directive: notarization & witnesses by country

Jurisdiction	Notarization	Witnesses	Key point
Argentina	Required	2	Directivas anticipadas: notarial form common; 2 witnesses typical.
Australia	Not typically required	varies	Formalities vary by state/territory; usually one or two witnesses.
Austria	Optional	2	PatVG: written, signed, 2 witnesses or notarized.
Belgium	Not typically required	2	Written, dated, signed; 2 witnesses required by law.
Brazil	Optional	2	Diretivas antecipadas: notarial form recommended; 2 witnesses needed.
Canada	Optional	varies	Requirements vary by province; witnesses often required not notary.
Chile	Required	2	Ley 20.584; notarized with 2 witnesses or civil-registry officer.
Colombia	Required	2	Notarial deed common; witness requirements vary by entity.
Denmark	Not typically required	0	Livstestamente; registered with the national patient register.
Finland	Not typically required	0	Hoitotahto; written, signed; no formal registration required.
France	Not typically required	2	Directives anticipees; written, dated, signed; 2 witnesses if unable.
Germany	Not typically required	0	Written, signed; witness or notarization optional.
Ghana	Optional	varies	No specific statute; written document with notarization advisable.
Hong Kong	Not typically required	1	No statutory form; written document with witness generally acceptable.
India	Required	2	Two witnesses plus Judicial Magistrate per Supreme Court 2018 ruling.
Ireland	Not typically required	2	Two witnesses required; must be independent adults.
Italy	Not typically required	0	DAT (Law 219/2017); written, signed; registered with municipality.
Kenya	Optional	varies	No specific statute; written directive with notarization advisable.
Malaysia	Not typically required	varies	No specific statute; written directive; legal status uncertain.
Mexico	Required	2	Notarization required; witness count varies by state.
Netherlands	Not typically required	0	Wilsverklaring; written, signed; no notary required.
New Zealand	Not typically required	1	Advance directive; no statutory form; written and signed suffices.
Nigeria	Optional	varies	No specific statute; written advance directive with witnesses advisable.
Norway	Not typically required	0	Forhandssamtykke; written, signed; no formality prescribed.
Pakistan	Optional	varies	No specific statute; written directive; Islamic law context applies.
Philippines	Not typically required	varies	No specific statute; written advance directive used in practice.
Poland	Not typically required	0	No formal statute; advance directives recognized in practice.
Portugal	Not typically required	0	Testamento vital (Law 25/2012); written, signed, registered in RENTEV.
Quebec	Optional	2	Mandate/advance directive: notarial or private with 2 witnesses (CCQ Art. 2166).
Singapore	Not typically required	2	Two witnesses required under the Advance Medical Directive Act.
Spain	Optional	3	Instrucciones previas; notarized or 3 witnesses; regional variation.
Sweden	Not typically required	0	Framtidsfullmakt (2017:310); written, signed; witness optional.
Switzerland	Not typically required	0	Written, signed; ZGB Art. 370; no notary required.
UAE	Required	varies	No comprehensive statute; Islamic law context; notarisation advisable.
United Kingdom	Not typically required	1	One witness required; cannot be paid carer or beneficiary.
United States	varies	varies	Requirements vary by state; usually notary or two witnesses.

Download a free Living Will template →

Power of Attorney: notarization & witnesses by country

Jurisdiction	Notarization	Witnesses	Key point
Argentina	Notarial deed	0	Escritura publica before escribano; required for real estate acts.
Australia	Required	varies	Enduring POA requires notary or JP; witness rules vary by state.
Austria	Optional	0	Notarization required for real estate or banking POA.
Belgium	Optional	0	Notarization required for real estate or lasting mandate.
Brazil	Notarial deed	0	Procuracao publica via tabeliao for real property; private POA otherwise.
Canada	Optional	varies	Witness or notary requirements vary by province.
Chile	Notarial deed	0	Escritura publica before notario; or private with notarial authorisation.
Colombia	Notarial deed	0	Escritura publica before notario; authenticated for foreign use.
Denmark	Optional	0	Fremtidsfuldmagt needs court registration; general POA no formality.
Finland	Optional	0	Edunvalvontavaltuutus: 2 witnesses + DVV registration required.
France	Optional	0	Notarization for real estate or mandat de protection future.
Germany	Optional	0	Notarization required for real estate or banking POA.
Ghana	Required	2	Must be stamped; Powers of Attorney Act 1998; two witnesses required.
Hong Kong	Optional	1	Enduring POA requires one witness; registration not mandatory.
India	Required	varies	Registration required if authorising property transactions; notarised.
Ireland	Not typically required	1	Enduring POA: one witness; must be registered with Wards Office.
Italy	Optional	0	Notarization required for real estate or broad mandates.
Kenya	Required	1	Powers of Attorney Act; must be stamped; advocate certification required.
Malaysia	Required	1	Powers of Attorney Act 1949; must be stamped and registered.
Mexico	Notarial deed	2	Escritura publica before notario publico required.
Netherlands	Optional	0	Notarization for real estate or lasting POA (levenstestament).
New Zealand	Required	1	Enduring POA requires witness; certification by solicitor or notary.
Nigeria	Required	2	Must be stamped; for land transactions, registration required.
Norway	Optional	0	Notarization for real estate; fremtidsfullmakt 2 witnesses.
Pakistan	Required	2	Registered with sub-registrar; stamp duty required; two witnesses.
Philippines	Required	2	Notarization required; two witnesses under 2004 Notarial Rules.
Poland	Optional	0	Notarization required for real estate or broad authority.
Portugal	Optional	0	Notarization required for real estate or irrevocable mandates.
Quebec	Notarial deed	1	Protection mandate: notarial preferred (CCQ Art. 2169).
Singapore	Required	1	LPA registered with OPG; donee declaration witnessed by certificate issuer.
Spain	Optional	0	Notarization required for real estate, banking, or court POA.
Sweden	Not typically required	2	Framtidsfullmakt needs 2 witnesses; general POA no formality.
Switzerland	Optional	0	Notarization required for real estate or banking.
UAE	Required	2	Notarised before notary public; MOFA attestation may be required.
United Kingdom	Not typically required	1	Lasting POA registered with OPG; one witness per signature.
United States	Required	varies	Notarization required in most states; some require witnesses too.

Download a free Power of Attorney template →

Property Deed: notarization & witnesses by country

Jurisdiction	Notarization	Witnesses	Key point
Argentina	Notarial deed	0	Escritura publica mandatory; registered in Registro de la Propiedad.
Australia	Required	1	Execution requires witness; notary or JP for foreign execution.
Austria	Notarial deed	0	Notarial authentication and land register entry required.
Belgium	Notarial deed	0	Notarial deed mandatory for property transfers.
Brazil	Notarial deed	2	Escritura publica; 2 witnesses; registration in Cartorio mandatory.
Canada	Required	varies	Notarization or land titles office requirements vary by province.
Chile	Notarial deed	0	Escritura publica; inscription in Conservador de Bienes Raices mandatory.
Colombia	Notarial deed	0	Escritura publica; registration in Oficina de Registro obligatory.
Denmark	Not typically required	0	Written deed + Tinglysning (digital registration) required.
Finland	Not typically required	0	Written deed + MML registration; witnesses often used.
France	Notarial deed	0	Acte authentique mandatory; notary required (Code Civil Art. 1582+).
Germany	Notarial deed	0	Notarial authentication mandatory (BGB §311b).
Ghana	Required	2	Land Act 2020; instrument executed, stamped, registered at Lands Commission.
Hong Kong	Required	1	Executed as deed; registered with Land Registry; notary for foreign parties.
India	Required	2	Compulsory registration under Registration Act 1908; two witnesses.
Ireland	Not typically required	1	Deed executed with witness; registration in Land Registry required.
Italy	Notarial deed	0	Notarial deed and land registry transcription mandatory.
Kenya	Required	2	Land Registration Act; instrument executed, witnessed, and registered.
Malaysia	Required	1	Memorandum of Transfer registered at Land Office; stamp duty applies.
Mexico	Notarial deed	0	Escritura publica; registered in Registro Publico de la Propiedad.
Netherlands	Notarial deed	0	Notarial deed and cadastral registration mandatory.
New Zealand	Not typically required	1	Instruments require witness; registration with LINZ required.
Nigeria	Required	2	Deed registered at Land Registry; governor's consent often required.
Norway	Not typically required	0	Written deed + Kartverket tinglysing (registration) required.
Pakistan	Required	2	Transfer of Property Act; registered with Sub-Registrar; stamp duty.
Philippines	Required	2	Deed of Absolute Sale notarized; registered with Registry of Deeds.
Poland	Notarial deed	0	Notarial deed mandatory; land-mortgage register entry required.
Portugal	Notarial deed	0	Escritura publica mandatory; land registry entry required.
Quebec	Notarial deed	0	Acte notarie required; published at Registre foncier du Quebec.
Singapore	Required	1	Instrument must be signed, witnessed, and registered with SLA.
Spain	Notarial deed	0	Escritura publica mandatory; land registry inscription required.
Sweden	Not typically required	2	Written deed + 2 witnesses + Lantmateriet registration required.
Switzerland	Notarial deed	0	Notarial deed and land-register entry mandatory.
UAE	Required	0	Registered with Dubai Land Department or Abu Dhabi DOT; notarisation required.
United Kingdom	Not typically required	1	Executed as deed; one witness to each signature; HMLR registration.
United States	Required	varies	Notarization required for recording; witness rules vary by state.

Download a free Property Deed template →

Bill of Sale: notarization & witnesses by country

Jurisdiction	Notarization	Witnesses	Key point
Argentina	Not typically required	0	Private document for movables; vehicles require form 08 notarised.
Australia	Not typically required	0	No statutory formalities for most personal property sales.
Austria	Not typically required	0	Written contract sufficient for movables.
Belgium	Not typically required	0	Written contract sufficient for movables.
Brazil	Not typically required	0	Contrato de compra e venda: private document sufficient for movables.
Canada	Not typically required	0	No statutory formalities; writing sufficient for most transactions.
Chile	Not typically required	0	Private document for movables; real property always notarial deed.
Colombia	Not typically required	0	Private document for movables; vehicles require notarial deed.
Denmark	Not typically required	0	Written or oral sufficient.
Finland	Not typically required	0	Written or oral sufficient.
France	Not typically required	0	Written or oral sufficient for movables.
Germany	Not typically required	0	Written contract sufficient; notary only for real property.
Ghana	Optional	0	No statutory formalities; stamp duty may apply above threshold.
Hong Kong	Not typically required	0	No statutory formalities for personal property sales.
India	Optional	0	No mandatory formality; stamp duty may apply depending on state.
Ireland	Not typically required	0	No statutory formalities for ordinary sale of goods.
Italy	Not typically required	0	Written contract sufficient for movables.
Kenya	Optional	0	No statutory formalities; stamp duty may apply.
Malaysia	Not typically required	0	No statutory formalities for general sale of goods.
Mexico	Not typically required	0	Private document sufficient for most movable goods.
Netherlands	Not typically required	0	Written or oral sufficient for movables.
New Zealand	Not typically required	0	No statutory formalities; writing sufficient.
Nigeria	Optional	0	Bill of Sale Act requires stamping; registration advisable.
Norway	Not typically required	0	Written or oral sufficient.
Pakistan	Optional	0	Sale of Goods Act 1930; no mandatory formalities for movable property.
Philippines	Optional	0	Notarization recommended for vehicles; no statutory formality otherwise.
Poland	Not typically required	0	Written contract sufficient for movables.
Portugal	Not typically required	0	Written contract sufficient for movables.
Quebec	Not typically required	0	Private deed sufficient; notarial form optional for movable hypothec.
Singapore	Not typically required	0	No statutory formalities for sale of goods.
Spain	Not typically required	0	Written or oral sufficient for movables.
Sweden	Not typically required	0	Written or oral sufficient.
Switzerland	Not typically required	0	Oral or written; notary only for immovables.
UAE	Optional	0	No statutory formalities for general goods; commercial transactions differ.
United Kingdom	Not typically required	1	Bills of Sale Act 1878 requires attestation by one witness.
United States	Optional	0	Generally no formalities; notarization optional for vehicles/boats.

Download a free Bill of Sale template →

Living Trust: notarization & witnesses by country

Jurisdiction	Notarization	Witnesses	Key point
Argentina	N/A	0	No Anglo-American trust; fideicomiso (Law 24.441) differs structurally.
Australia	Not typically required	1	Trust deed executed as deed; one witness typically required.
Austria	N/A	0	No trust concept; Treuhand or testamentary instruments used.
Belgium	N/A	0	No trust concept; use fiducie or contractual arrangements.
Brazil	N/A	0	No trust in Brazilian civil law; patrimonial fund structures used.
Canada	Optional	varies	Trust deed formalities vary by province; Quebec requires notarial act.
Chile	N/A	0	No trust concept in Chilean civil law; fideicomiso is different.
Colombia	N/A	0	Common-law trust not recognised; fideicomiso via financial entity.
Denmark	N/A	0	No trust concept; fond or testamentary instruments used.
Finland	N/A	0	No trust concept; saatio or testamentary instruments used.
France	N/A	0	No trust concept; fiducie (Law 2007-211) for commercial use only.
Germany	N/A	0	No trust concept; use Treuhand or testamentary instruments.
Ghana	Optional	varies	Trusts Act 1962; trust deed in writing; registration recommended.
Hong Kong	Not typically required	1	Trust deed executed as deed with witness.
India	Optional	0	No separate trust registration required unless immovable property involved.
Ireland	Not typically required	1	Trust deed as deed with witness; no separate registry for trusts.
Italy	N/A	0	No domestic trust; foreign trusts recognized under Hague Convention.
Kenya	Optional	varies	Trustee Act Cap 167; registration not typically required.
Malaysia	Not typically required	0	Trust deed in writing; no public registration; stamp duty applies.
Mexico	Notarial deed	0	Fideicomiso; executed as escritura publica before notario.
Netherlands	N/A	0	No trust concept; Stichting or testamentary arrangements used.
New Zealand	Not typically required	1	Trust deed requires execution as deed with witness typically.
Nigeria	Optional	varies	No specific trust registry; registering the trust deed is advisable.
Norway	N/A	0	No trust concept; stiftelse or testamentary instruments used.
Pakistan	Optional	varies	Trust Act 1882; Waqf under Islamic law for charitable trusts.
Philippines	Optional	varies	Trust not common; deed of trust notarized in practice.
Poland	N/A	0	No trust concept; fundacja or testamentary instruments used.
Portugal	N/A	0	No trust concept; fideicomisso limited; foundations used.
Quebec	Optional	0	Fiducie (CCQ Art. 1260): notarial deed strongly recommended.
Singapore	Not typically required	1	Trust deed executed as deed with witness; no public trust registry.
Spain	N/A	0	No trust concept; fideicomiso limited; foundations used.
Sweden	N/A	0	No trust concept; stiftelse or testamentary instruments used.
Switzerland	N/A	0	No trust concept; foundations or succession law used.
UAE	Required	varies	DIFC/ADGM trust frameworks; registration and notarisation required.
United Kingdom	Not typically required	1	Trust deed executed as deed; one witness per signature typically.
United States	Required	varies	Notarization widely required; witness requirements vary by state.

Download a free Living Trust template →

Prenuptial Agreement: notarization & witnesses by country

Jurisdiction	Notarization	Witnesses	Key point
Argentina	Notarial deed	0	Convenciones matrimoniales: escritura publica before escribano required.
Australia	Not typically required	1	Binding financial agreements require independent legal advice certificates.
Austria	Notarial deed	0	Notarial deed mandatory (ABGB §97).
Belgium	Notarial deed	0	Notarial deed mandatory (Civil Code Art. 1392).
Brazil	Notarial deed	2	Pacto antenupcial: escritura publica required (CC Art. 1653); 2 witnesses.
Canada	Optional	varies	Must be written; independent legal advice recommended; varies by province.
Chile	Notarial deed	0	Capitulaciones matrimoniales must be escritura publica before marriage.
Colombia	Notarial deed	0	Capitulaciones before notario; must precede or accompany marriage.
Denmark	Not typically required	0	Written, signed, approved by Familieretshuset (AEL §28).
Finland	Not typically required	2	Written, signed, 2 witnesses, registered with DVV (AL 42§).
France	Notarial deed	0	Notarial deed mandatory (Code Civil Art. 1394).
Germany	Notarial deed	0	Notarial deed mandatory (BGB §1410).
Ghana	Optional	0	Limited statutory recognition; Matrimonial Causes Act governs.
Hong Kong	Not typically required	0	Valid if in writing; courts have discretion; independent advice advised.
India	Optional	0	Not specifically governed; enforceability uncertain; personal law applies.
Ireland	Not typically required	0	Not formally recognised; independent legal advice strongly advised.
Italy	Notarial deed	2	Notarial deed mandatory; 2 witnesses required (CC Art. 162).
Kenya	Optional	0	Recognised but limited statutory framework; customary marriages vary.
Malaysia	Not typically required	0	Recognised for civil marriages; Islamic law governs Muslim marriages separately.
Mexico	Notarial deed	2	Capitulaciones matrimoniales before notario; filed with civil registry.
Netherlands	Notarial deed	0	Notarial deed mandatory (BW Art. 1:115).
New Zealand	Not typically required	0	Contracting Out Agreement; solicitors certify independent advice.
Nigeria	Optional	0	Recognised under common law; customary law may override in some states.
Norway	Not typically required	0	Written, signed, registered with Bronnoysund (EL §65).
Pakistan	Optional	2	Nikah Nama serves a similar function (Muslim Family Laws Ordinance 1961).
Philippines	Required	0	Ante-nuptial agreement must be written and notarized (Family Code).
Poland	Notarial deed	0	Notarial deed mandatory (KC Art. 47).
Portugal	Notarial deed	0	Escritura publica mandatory (CC Art. 1710).
Quebec	Notarial deed	0	Marriage contract (CCQ Art. 440): notarial deed mandatory.
Singapore	Not typically required	0	Valid if in writing; independent legal advice strongly recommended.
Spain	Notarial deed	0	Escritura publica mandatory (CC Art. 1327).
Sweden	Not typically required	2	Written, signed, 2 witnesses, registered with Skatteverket (AktB 7:3).
Switzerland	Notarial deed	0	Notarial deed mandatory (ZGB Art. 184).
UAE	Required	2	Non-Muslims may use DIFC framework; Muslims under Personal Status Law.
United Kingdom	Not typically required	1	No statutory form; independent legal advice strongly advised.
United States	Optional	varies	Writing required; notarization and witnesses vary by state.

Download a free Prenuptial Agreement template →

Promissory Note: notarization & witnesses by country

Jurisdiction	Notarization	Key point
Argentina	Not typically required	Pagare is executive title by law; no notarisation needed.
Australia	Not typically required	No execution formalities under Cheques Act or common law.
Austria	Not typically required	Written form sufficient.
Belgium	Not typically required	Written form sufficient.
Brazil	Not typically required	Nota promissoria is autonomous credit instrument; no notarisation required.
Canada	Not typically required	No execution formalities required under Bills of Exchange Act.
Chile	Not typically required	Pagare is negotiable instrument; no notarisation required.
Colombia	Not typically required	Pagare self-executing; notarial protest optional for enforcement.
Denmark	Not typically required	Written form sufficient.
Finland	Not typically required	Written form sufficient; VeksL governs.
France	Not typically required	Written form sufficient under Code de Commerce.
Germany	Not typically required	Written form sufficient; no notarization needed.
Ghana	Not typically required	Bills of Exchange Act applicable; no execution formalities required.
Hong Kong	Not typically required	Governed by Bills of Exchange Ordinance; no execution formalities.
India	Not typically required	Governed by Negotiable Instruments Act 1881; stamp duty required.
Ireland	Not typically required	No execution formalities required.
Italy	Not typically required	Written form sufficient.
Kenya	Not typically required	Governed by Bills of Exchange Act; stamp duty applies.
Malaysia	Not typically required	Governed by Bills of Exchange Act 1949; no execution formalities.
Mexico	Not typically required	Pagare is self-executing negotiable instrument; no notary needed.
Netherlands	Not typically required	Written form sufficient.
New Zealand	Not typically required	No execution formalities required.
Nigeria	Not typically required	Governed by Bills of Exchange Act; stampable; no witness required.
Norway	Not typically required	Written form sufficient; Gjeldsbrevloven governs.
Pakistan	Not typically required	Negotiable Instruments Act 1881; stamp duty required.
Philippines	Not typically required	No notarization required; governed by Negotiable Instruments Law.
Poland	Not typically required	Written form sufficient; weksel governed by Bill of Exchange Law.
Portugal	Not typically required	Written form sufficient.
Quebec	Not typically required	Governed by Bills of Exchange Act (federal); no notarisation required.
Singapore	Not typically required	Governed by Bills of Exchange Act; no execution formalities.
Spain	Not typically required	Written form sufficient; pagare governed by Ley Cambiaria.
Sweden	Not typically required	Written form sufficient; SkuldebrevL governs.
Switzerland	Not typically required	Written form sufficient under OR.
UAE	Optional	Commercial paper; notarisation recommended but not mandatory.
United Kingdom	Not typically required	Simple written instrument; no execution formalities required.
United States	Not typically required	No statutory formality; notarization optional for added security.

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Frequently asked questions

Do legal documents need to be notarized?

It depends on the document and the country. Across the 36 jurisdictions in this reference, affidavits almost always require notarization (or swearing before a commissioner for oaths), property deeds and powers of attorney usually do, and promissory notes and bills of sale usually do not. In civil-law countries (Germany, France, Mexico, Brazil and others) many documents instead require a "notarial deed" — an authentic act executed before a civil-law notary — which is a stronger requirement than common-law notarization.

How many witnesses does a will need?

In most common-law jurisdictions a will requires two witnesses who are not beneficiaries. The Philippines requires three for a notarial will (none for a holographic will), Brazil requires up to five for a closed will, and Quebec’s notarial will needs a notary plus one witness. Several civil-law countries allow a holographic (handwritten) will with no witnesses at all.

What is the difference between notarization and a "notarial deed"?

Common-law notarization is an act where a notary public verifies identity and witnesses a signature. A civil-law "notarial deed" (escritura pública, acte authentique, notarielle Urkunde) is a far more involved instrument: the notary drafts and is legally responsible for the document, which then has special evidentiary and enforceability status. Property transfers, prenuptial agreements and many powers of attorney require a notarial deed in civil-law jurisdictions.

Why do execution formalities differ so much between countries?

Common-law systems (US, UK, Australia, India and others) rely on the signed document plus witnesses, reserving notaries for specific acts. Civil-law systems (continental Europe, Latin America, Quebec) place the notary at the centre of important transactions. On top of that, registration regimes (land registries, probate courts, marriage registries) add their own requirements, so the same document can be valid in one country and unenforceable in another.

Are the templates in this comparison free?

Yes. forms-legal.com provides free, jurisdiction-aware templates for these document types, downloadable as PDF or Word with no signup required. Use the comparison below to check the local formality, then download the matching template.

About this comparison

This reference maps the typical notarization and witnessing formalities for 9 document types across 36 jurisdictions, curated from the forms-legal.com 36-jurisdiction legal-document library. "Notarial deed" denotes a civil-law authentic act (escritura pública / acte authentique), which is more demanding than common-law notarization; "N/A" marks document types with no direct equivalent in that legal system (for example the living trust in most civil-law countries). The dataset is published under a CC-BY 4.0 licence — you may reuse it with attribution to forms-legal.com.