Signing What You Can't Read: Foreign-Language Contracts, Sworn Translators and Bilingual Deeds

Published on: June 20, 2026

There's a particular moment in buying property abroad that no brochure prepares you for. You're sitting in a notary's office in Spain, Italy or Turkey, a document is in front of you in a language you half-understand at best, everyone is waiting, the pen is in your hand, and you're being asked to commit a large sum of money to terms you are taking, essentially, on faith. The agent gives you a cheerful one-line summary. You sign.

It's an entirely reasonable thing to be uneasy about, because the document in front of you, not its verbal summary, is what binds you, and it's usually the foreign-language version that the law treats as definitive. This guide is about closing that gap: understanding which version actually controls, what a sworn translator is and why it matters, how bilingual contracts can quietly mislead you, and how to walk into that signing already knowing what you're agreeing to.

The version you can't read is usually the one that binds you

Start with the uncomfortable foundation. When a property contract or deed exists in two languages, say, the local language and an English "courtesy" translation, the contract almost always specifies that the local-language version prevails in any dispute. The English text is provided for your comfort, not as the legally operative document. Sometimes it's even labelled "for information only."

This matters enormously, because translations are imperfect, and the differences hide in exactly the places that cost money: a boundary description, a payment schedule, a penalty clause, what's included in the sale, who pays which tax, what conditions release you from the deal. A summary that says "standard terms" can sit on top of a clause that is anything but standard for you.

The rule to internalise: you have not understood a contract until you have understood the version that legally binds you, in language you can actually read, checked by someone competent and on your side.

The notary's role, and its limits

In most civil-law countries (Spain, France, Italy, Portugal, Germany, much of Latin America), a notary is central to the sale, and notaries take the question of comprehension seriously. In Germany, for instance, the notary reads the purchase deed aloud before signing. In Spain, where a buyer does not understand Spanish, the notary will generally require an official interpreter to be present at signing, or a sworn translation of the deed, and will note this in the document, precisely so that no one can later claim they didn't understand what they signed.

But understand the limit of this protection. The notary is neutral. Their job is to ensure the deed is validly executed and that the parties formally understand its nature, not to negotiate better terms for you, flag that the price is high, or act as your advocate. The notary confirming you understood the document is not the same as someone on your side confirming the document is good for you. You need both: the notary for validity, your own lawyer and translator for protection.

A practical consequence: if you're relying on the notary's interpreter as your only line of comprehension, you're trusting a neutral party to be your safeguard. Far better to arrive having already read and understood a proper translation, with your own lawyer's view on it, so that the signing is a confirmation of what you know, not the first time you learn what's in the document.

What a sworn (certified) translator actually is

Not all translation is equal, and the distinction is legal, not just about quality.

A sworn translator (also called certified, official or, in some systems, "court" translator) is someone formally authorised by a state body to produce translations that carry legal validity. Their translation is stamped, signed and certified to be a faithful rendering of the original, and it's accepted by notaries, courts and registries as an official document. A friend who speaks the language, a bilingual agent, or an online translation tool can give you the gist, but their version has no legal standing and no accountability behind it if it's wrong.

For property purposes this matters in two ways. First, many jurisdictions require a sworn translation (or an official interpreter) when a foreign buyer signs a deed they can't read in the original. Second, and more importantly for your protection, a sworn translation gives you a reliable, accountable text to actually understand and to have your lawyer review, rather than a casual paraphrase you can't trust.

When you commission a translation of a contract or deed, ask specifically for a sworn/certified translation by an officially recognised translator for that country's language, and get it early enough to read and query it before signing, not on the day.

Bilingual deeds and dual-column contracts: useful, with a trap

Some markets routinely produce bilingual deeds, the local language and English side by side, often in two columns. This is genuinely helpful: you can read along and see, clause by clause, what you're agreeing to. Several international-facing markets and developers offer them as standard.

The trap is the small print about which column governs. As noted above, the contract will usually state that the local-language column prevails in any conflict, with the English provided for convenience. So a bilingual deed is a reading aid, not a guarantee that the English you read is the law you're bound by. Two safeguards make bilingual deeds safe rather than reassuring-but-hollow:

First, have a bilingual lawyer who works for you confirm that the two columns actually say the same thing, that the operative local-language text matches the English you've relied on. Discrepancies between the two columns are exactly where problems hide.

Second, don't let the existence of an English column lull you into skipping independent review. "There's an English version, so I'm fine" is how people end up bound by a local-language clause the English version softened or omitted.

Power of attorney: signing without being there

Cross-border buyers often can't be physically present for every step, and the standard solution is a power of attorney (POA), a notarised document authorising someone (often your lawyer) to sign on your behalf. Used well, it's convenient and safe. Used carelessly, it's a way to lose control of your own purchase.

Two principles keep a POA safe. Make it specific and limited: it should authorise particular acts on a particular property (sign this deed, pay these funds, register this title), not grant open-ended authority to do anything in your name. And give it to someone genuinely independent and accountable, your own lawyer under a clear engagement, not to the seller's representative, the developer's lawyer, or an agent whose interests differ from yours. A POA is a transfer of your signing power; only hand it to someone whose only job is to protect you.

Because a POA itself is a legal document you'll often sign abroad or have apostilled for use in another country, the same rule applies to it as to everything else: understand it, in a language you can read, before you sign it.

A signing checklist for the language barrier

Before you put your name to any binding document in a language you don't fully command:

• Get a sworn/certified translation of the preliminary contract and the final deed, early enough to read and question them.
• Have an independent, bilingual lawyer who represents only you review the operative (local-language) version and explain anything unusual.
• Confirm which language version legally prevails, assume it's the local one, and make sure you've understood that text, not just the English.
• If signing in person without a translation in advance, ensure a genuinely independent interpreter is present (not the selling agent doing double duty as your translator).
• For a bilingual deed, have your lawyer verify both columns match before you rely on the English.
• For a power of attorney, keep it specific, limited and in the hands of your own independent representative, and read it yourself first.

Do these, and the signing stops being a leap of faith. You'll be confirming an agreement you already understand, which is the only way anyone should ever sign for a home.

Frequently asked questions

If I sign a property contract in a foreign language, which version is legally binding?
Almost always the local-language version. Where a contract or deed is bilingual, it typically states that the original (local) language prevails in any dispute and that the translation is provided for convenience. That's why you need to understand, via a sworn translation and your own lawyer, the version that actually binds you, not just the courtesy English text.

What is a sworn translator and do I need one?
A sworn (or certified/official) translator is authorised by a state body to produce legally valid, stamped translations accepted by notaries, courts and registries. Many countries require a sworn translation or an official interpreter when a foreign buyer signs a deed in a language they don't read, and even where it isn't mandatory, it gives you a reliable, accountable text to review with your lawyer.

Can the selling agent translate the contract for me?
They can give you the gist, but you shouldn't rely on it. The agent is paid by the seller and on completion, an informal translation has no legal standing, and the differences that matter are easy to lose in a casual summary. Use an independent sworn translator and your own lawyer for anything that binds you.

Is a bilingual deed enough protection?
It's a helpful reading aid but not a guarantee. The local-language column usually governs, so you still need a bilingual lawyer working for you to confirm the two versions genuinely match before you rely on the English one.

A note from JanusHermes

JanusHermes covers cross-border property across 50+ countries with one rule: no hype, no half-truths. The terminology in your contract, escritura, compromis, rogito, tapu, is decoded in our international glossary.

Disclaimer. This article is provided for general information only and does not constitute legal advice, nor does it create any professional or advisory relationship. Rules on contracts, sworn translation, and notarisation vary by country and change over time. Always verify the specifics with your own independent lawyer and a sworn or certified translator before signing anything. JanusHermes is a property information and listing platform and accepts no liability for any action taken in reliance on this content.