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Updated : 18/06/2014

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EU – Marriages: recognition/registration in different countries – Your Europe

Marriage (civil marriage: meeting legal requirements, but without any religious affiliation) is a legal status recognised in all EU countries.

Different rules apply to partnerships other than marriage, such as registered partnerships and de facto unions.

National rules and practice for marriage differ from one country to another, mainly as regards:

  • rights and obligations of married couples - for instance concerning their property, role as parents or their marital name.
  • relationship between religious and civil marriage - some countries recognise religious marriage as equivalent to civil marriage, others do not. If you move to another country after having entered into a religious marriage only, it is important to check the consequences for your marital status.
  • requirements for marriage - the most notable difference is the right of same-sex couples to get married. As of today, the following EU countries grant this right: Belgium, Denmark, France, the Netherlands, Portugal, Spain, Sweden and United Kingdom (excluding Scotland and Northern Ireland).

Formalities - before the wedding

If different EU countries are involved - for instance because you marry someone of a different nationality or because you plan to move abroad after getting married - check which country's laws apply to your marriage and to your matrimonial property regime. This will have important consequences for your rights and obligations as spouses.

If you are getting married in a different EU country from the one where you live, check with the authorities in both which formalities are needed for your marriage to have full force and effect in both countries. These may include registration or publication requirements.

Formalities - after the wedding

In theory, your marriage is guaranteed to be recognised in all other EU countries - but this does not fully apply to same-sex marriages.

If you get married in a different EU country than your country of origin it is a good idea to register the marriage at the consular office of your country of origin where you live.

If you move to another EU country for work, your husband or wife can come and live with you there if they are also a citizen of an EU country. Different rules apply for spouses without EU citizenship.

Sample story

Same-sex marriage - when national practices differ

Emma, a Belgian national, married Carine, a French national, in Belgium. When Emma had to move to Germany for work, Carine followed her - but they were not regarded as married by the authorities, since same-sex marriage is not recognised in Germany.

However, because registered partnerships between same-sex couples are allowed in Germany, Emma and Carine can be granted the same rights as couples with registered partnerships under German law.

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