An Israeli will alongside a foreign will – governing law, form, and when one will revokes the other.

Wills & Succession · October 22, 2026 · 7 min read

The short answer

An Israeli court has jurisdiction over the succession of a person whose domicile at death was in Israel, or who left assets in Israel (section 136 of the Succession Law, 5725-1965). The succession is governed by the law of the deceased’s domicile at death – the place of their centre of life (sections 135 and 137), subject to sections 138 to 140. A will is valid in form if it is valid under any one of several laws – Israeli law, the law of the place where it was made, the law of the testator’s domicile or habitual residence, or the law of their nationality (section 140); Israel is a party to the 1961 Hague Convention on the form of wills. Under section 36(b), a later will revokes an earlier one to the extent their provisions conflict, while an express revocation of “all prior wills” revokes them all. Since 1 July 2023, where the original will is outside Israel and cannot be produced, a probate order granted abroad may be filed in its place, proved as a foreign document (section 68(b)).

1. Jurisdiction and the law governing the succession

Under section 136 of the Succession Law, an Israeli court has jurisdiction over the succession of any person whose domicile at death was in Israel, or who left assets in Israel. Under section 137, the succession is governed by the law of the deceased’s domicile at death, except as provided in sections 138 to 140. “Domicile” means, under section 135, the place where a person’s centre of life is. The Law contains no provision allowing a testator to choose the law that will govern their succession. These terms are characterised according to their meaning in Israeli law (section 141).

Under section 142, where the applicable foreign law refers to the law of another state, the reference is not followed and the internal law of that foreign state applies; but where it refers back to Israeli law, the reference is followed and Israeli internal law applies.

2. Assets that pass under the law of their location

Under section 138 of the Succession Law, assets that pass by succession only under the law of the place where they are located are governed by that law. The wording is general and is not limited to a particular type of asset.

3. Capacity to make a will

Under section 139 of the Succession Law, capacity to make a will is governed by the law of the testator’s domicile at the time the will is made.

4. Form of the will

Under section 140(a) of the Succession Law, a will is valid in form if it is valid under any one of the following:

• Israeli law;
• the law of the place where the will was made;
• the law of the testator’s domicile or habitual residence, when the will was made or at death;
• the law of the testator’s nationality, when the will was made or at death;
• insofar as the will concerns immovable property – also the law of the place where it is located.

Under section 140(b), the qualifications required of the testator or of the witnesses are treated as a matter of form. Israel acceded to the Hague Convention of 5 October 1961 on the Conflicts of Laws Relating to the Form of Testamentary Dispositions on 11 November 1977; it has been in force for Israel since 10 January 1978. Israel is not a party to the 1973 Washington Convention on the international will.

5. When one will revokes the other

Under section 36(a) of the Succession Law, a testator may revoke their will by express revocation made in one of the forms for making a will, or by destroying the will. Under section 36(b), a new will, even without an express revocation, revokes the earlier one to the extent their provisions conflict, unless the new will merely adds to the earlier one. The Law draws no distinction for this purpose between a will made in Israel and one made abroad.

These are the rules of Israeli law. Where a foreign law governs the succession under section 137, that law’s revocation rules may apply. In practice such wills are commonly limited to the assets in each country.

6. After death: probate of the will in Israel

Under section 68(b) of the Succession Law, a will – other than an oral will – is proved by producing the original. Since 1 July 2023 (Succession Law Amendment No. 18), where the original is outside Israel and cannot be produced, and a probate order has been granted by a court or competent authority abroad, the original need not be produced, provided the foreign probate order is proved as a foreign document under section 30 of the Evidence Ordinance [New Version], 5731-1971. The same amendment ended the automatic transfer to the court of applications concerning a succession to which Chapter 7 of the Law (private international law) applies, so the Registrar for Inheritance Matters may decide them unless another ground for transfer applies.

Under regulation 54A of the Succession Regulations, 5758-1998, a document in a foreign language other than English must be accompanied by a notarised translation into Hebrew or Arabic; the Registrar or the court may require a translation of an English document too. For the procedure when the heirs live abroad – see the article on heirs living abroad.

Frequently asked questions

Is a will made abroad under local law valid in Israel?

As to form – yes, if it is valid under the law of the place where it was made, or under any of the other laws listed in section 140 of the Succession Law. Other questions, such as the law governing the succession, are decided under sections 137 to 139.

Does a new will made abroad revoke an earlier Israeli will?

Under section 36 of the Succession Law – if it expressly revokes all prior wills, or to the extent its provisions conflict with the Israeli will. A will that merely adds to the earlier one does not revoke it. These are the rules of Israeli law, which apply where the deceased’s domicile at death was in Israel.

Must an Israeli will be written in Hebrew?

Sections 19 and 20 of the Succession Law do not prescribe the language of a will. A will before an authority written in a language the testator does not understand must be read in translation (section 22(c)), and a document filed with the Registrar in a foreign language other than English needs a notarised translation (regulation 54A of the Succession Regulations).

What if the original will is held by a court abroad?

If it was probated abroad and the original cannot be produced, the foreign probate order may be filed in Israel instead of the original, proved as a foreign document under section 30 of the Evidence Ordinance (section 68(b) of the Succession Law, since 1 July 2023).

The above is general information on Israeli law only, current as of the date of publication, and does not constitute legal advice or a substitute for advice on your specific circumstances. Fee amounts are those published in Reshumot at the date of publication and are updated from time to time. Consult a lawyer before acting.

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