What a notarial power of attorney must say, specific versus general, apostille and translation, the risks, how it is treated abroad and how to revoke it.
Many EU residents buy abroad without flying out for the signing. They sign a power of attorney at home, and a lawyer or another trusted person signs the deed for them. It is a normal tool, and also the document with the most potential for harm if it is badly drafted. This guide covers what the document must say, how it travels abroad, how some destination countries are reported to treat it, and how to end it. It is informational, not legal advice; the receiving notary or registry has the last word on form.
What a power of attorney is for
You (the principal) authorise someone (the agent) to act in your name. In a purchase the agent may sign the reservation and sale contract, pay or receive money, obtain a tax number, sign the final deed before a notary and register the title. Buying remotely is the main use; see our guide on buying property abroad remotely. Some buyers also use it for the later management or the sale.
Specific or general
A specific (special) power of attorney names the property, the price or a ceiling, the seller if known and the acts the agent may perform. A general one gives broad authority over your affairs.
For a purchase, a specific power is the safer choice and is the one reported to be most readily accepted by land registries and banks. A general power exposes you to misuse and is often refused for real estate. Several countries require the real-estate power to describe the property, the price and the terms; Bulgaria is reported to be one of them. If you do not yet know the exact property, a narrower mandate that covers a defined search and a price ceiling is better than a blank cheque, and you can sign a second one when the choice is made.
What it should say
Ask the lawyer in the destination country to draft or approve the text, then have it notarised at home. As a minimum:
- Your full name, address, date of birth, passport number and, if the country asks for it, your tax number.
- The agent's full identity and capacity (a lawyer, a relative, a company representative).
- The exact acts allowed: sign the contract, pay the price, receive the keys, sign the deed, register the title, open a bank account, connect utilities. Exclude everything else explicitly, including borrowing, selling and granting a mortgage unless you want that.
- The property identification (address, cadastral or registry number) and the price or a maximum.
- Whether the agent can sub-delegate (usually no) and whether they may act for the seller too (this should be excluded).
- An end date or a clear purpose after which it lapses.
- The language: many registries want it in their language, or a sworn translation attached.
How it travels abroad
In Spain, as reported by law firms, there are three ways to grant it: before a Spanish notary, before a Spanish consul abroad (where no apostille or translation should be needed), or before a notary at home with an apostille and a sworn translation into Spanish. Other countries have similar options, for example Turkey is reported to accept a power of attorney made at its consulate or one made before a local notary with an apostille and a Turkish sworn translation.
For a notary at home the usual chain is: notarial signature, apostille or legalisation, sworn translation. For the details and for countries outside the Hague system, see our article on apostille and legalisation. Inside the EU, Regulation (EU) 2016/1191 exempts only a list of civil-status-type documents; a transactional power of attorney is reported not to be on it, so do not assume it is exempt.
How different countries are reported to treat it
These are summaries from law-firm sources, not official positions; check with the local lawyer.
- Spain: the notary checks the power of attorney and the agent's identity before the deed. A specific power naming the purchase is advised. The land registry may reject a power that does not cover the act.
- Cyprus: a limited power to sign the contract and attend the title transfer is used by overseas buyers; sale contracts are commonly deposited at the District Lands Office, within six months of signing, and a specific power is described as more readily accepted.
- Greece: the transfer needs a notarial deed. A power made abroad is reported to need notarisation, an apostille and a Greek translation before use.
- Bulgaria: the transfer needs a notarial deed. The notary checks the power of attorney, which for real estate must be notarised and detailed; one made abroad needs an apostille and a Bulgarian translation.
- Turkey: the title office (tapu) is reported to want an apostilled power of attorney with a sworn Turkish translation, or one made at a Turkish consulate.
- UAE (Dubai): a power issued abroad is reported to need notarisation, legalisation by the UAE embassy or consulate and attestation by the UAE foreign ministry, to be registered or verified for the Land Department, and to be recent (a two-year age limit was reported, which we could not confirm). Official Dubai rules were updated in 2025; ask the local lawyer for the current ones.
Risks
- Misuse. An agent with broad powers can sign things you did not intend. Keep the text narrow.
- Conflicts of interest. If the agent is the seller's agent or a person paid by the developer, they should not be yours. Use an independent lawyer; see notary or lawyer: who do you need abroad.
- Scope disputes. A registry may refuse an act that the text does not clearly cover, and the delay may cost you the price or the date.
- Payments. Money should go to the seller's account named in the contract or to an escrow account, not to the agent personally.
- Expiry or revocation at the wrong moment. If you cancel mid-transaction, the other side may not know.
- Death or incapacity of the principal usually ends a simple power of attorney in many countries; check how it works in the destination.
Alternatives
- Sign in person at the notary. It costs a flight but removes the issue.
- Sign the deed at the destination country's consulate where this is possible, or use a remote or digital signing procedure where the country allows it. Rules differ and not all registries accept it.
- A company or trust structure for the purchase. It brings tax and reporting consequences and needs separate advice.
How to revoke
Revoke in writing, in the same form as you granted it (usually notarial), and send the revocation to the agent, the lawyer, the notary or registry where it was filed, and the seller or developer if they are involved. Keep the proof of delivery. Ask the local lawyer how a revocation is recorded in the destination: in some systems the power of attorney is registered, in others the third party simply has to be told. Until they know, acts made in good faith by the agent may still bind you.
FAQ
Does the agent have to be a lawyer? No, but we advise a licensed independent lawyer, ideally the one doing the due diligence. Can I use one power of attorney in several countries? Normally not: each needs the right form, language and chain. Does a power of attorney replace the notary at closing? No, the notary or registry still verifies it and the deed is signed in your name. How long is it valid? It depends on its text and on the receiving authority, which may reject an old one. What does it cost? Fees for the notary, apostille and translation vary and we do not quote them; ask for a total in advance.
How we help
We are a trilingual platform that finds properties and coordinates independent local lawyers and tax advisers. We can help you brief the local lawyer so that the text of the power of attorney fits your purchase. This text is informational and is not legal, tax or investment advice; verify current rules with the notary, the registry or a licensed lawyer.