Probate Fees, by Country
Poland's 100 zl flat fee is the cheapest here, though currencies aren't converted, so treat that as directional. Among flat-fee countries, New Zealand (NZ$275) and the US (California, $355) are the cheapest and the UK (GBP 526) the priciest. The bigger gap is structural: Germany, Canada (Ontario) and Australia (NSW) don't charge a flat fee at all — their cost scales with the estate's value, priced here at a representative 400,000 in each one's own currency, which is why Ontario's Estate Administration Tax (CA$5,250) and Germany's Erbschein fee (EUR 1,570) look so much larger.
Last updated 2 November 2026.
Applying for probate — legal authority to administer a deceased person's estate — is a single, well-defined process that exists almost everywhere there's inheritance law, run by a court or official registry, almost always with a government-published fee.
That fee splits cleanly into two groups worldwide: some countries charge the same amount no matter the estate's size; others scale the fee with the estate's value. This table prices both kinds honestly — flat fees as published, value-scaled fees at one consistent representative estate value (400,000 in each country's own currency) so the comparison means something. See methodology for the exact arithmetic behind each value-scaled row.
| Source | ||
|---|---|---|
🇨🇦 CanadaOntario, Estate Administration Tax, for an estate valued at CA$400,000: the first $50,000 is exempt; the remaining $350,000 is taxed at $15 per $1,000 = $5,250. Ontario has no separate flat 'probate fee' — this tax, paid to apply for the Certificate of Appointment of Estate Trustee, is the whole cost. Rate unchanged since 1 January 2020. Other provinces set their own, different rates and names and aren't priced here. | CA$5,250 | [1] |
🇩🇪 GermanyErbschein (certificate of inheritance), applied for at the local court (Amtsgericht), for a net estate of EUR 400,000: two separate 1.0 fees under GNotKG Tabelle B at the 'bis 410.000 €' band (EUR 785 each) — one for the Erbschein application itself (Kostenverzeichnis Nr. 12210), one for the sworn affidavit the court requires (Nr. 23300, charged separately per the note to Nr. 12210). Total: 2 x EUR 785 = EUR 1,570. | €1,570 | [2] |
🇦🇺 AustraliaNew South Wales, Supreme Court, uncontested Summons for Probate/Administration, sworn gross estate value of A$400,000 (band: $250,000 or more but less than $500,000 — assessed on gross value, debts not deducted). Fee effective 1 July 2026. Each Australian state/territory sets its own scale; NSW is used here as the national benchmark. | A$1,303 | [3] |
🇬🇧 United KingdomEngland & Wales, Grant of Probate/Letters of Administration application fee for an estate over £5,000: a single flat fee regardless of estate size. No fee at all if the estate is £5,000 or less. Extra sealed copies (£2 each with the application, £16 each afterwards) are genuinely optional and excluded here. | £526 | [5] |
🇺🇸 United StatesCalifornia, first petition for letters of administration or letters testamentary, Government Code §70650(a): a flat $355 regardless of estate value. The US has no national probate fee — set county by county within each state; California is used here the same way this site's notary-fees hub uses it for notary caps. Some secondary sources quote $435, but that figure doesn't appear in the statute's own text (confirmed by reading it directly) — it most likely reflects a county-level add-on, not the state-wide fee. | $355 | [4] |
🇮🇪 IrelandProbate Office / District Probate Registry fee, solicitor-applicant schedule (the standard route — most Irish grants are solicitor-led), net estate value of EUR 400,000 (band: 'does not exceed €500,000'). A personal applicant (no solicitor) pays a different, higher schedule — EUR 700 at the same estate value — because the Courts Service charges personal applicants more per band; the solicitor schedule is used as this row's headline figure. | €350 | [6] |
🇳🇿 New ZealandHigh Court application for probate or letters of administration: a flat NZ$275 regardless of estate value, prescribed by regulation under the High Court Fees Regulations 2013. Probate isn't always required — smaller estates can often be dealt with without it, depending on asset type and the institution holding them. | NZ$275 | [7] |
🇵🇱 PolandStwierdzenie nabycia spadku (court certificate confirming acquisition of inheritance), filed with the district court (sąd rejonowy): a flat 100 zł application fee under Art. 49(1)(1) of the law on court costs in civil cases, regardless of estate value. Poland also lets heirs use a notarial route instead, with a different, notary-tariff-based fee — excluded here since this row prices the court route specifically. | 100 zł | [8] |
Flat vs. value-scaled, and why that split matters more here than on this site's other hubs. Unlike notary signature-certification fees or most work-visa fees, probate fees split cleanly into two groups worldwide. The UK, the US (California), New Zealand and Poland charge the same fee no matter the estate's size. Germany, Canada (Ontario), Australia (NSW) and Ireland scale the fee with the estate's value — sometimes gross value (Australia), sometimes net of debts (Germany, Canada, Ireland). Blending these into one number, or picking a different estate value per country, would make the table meaningless, so every value-scaled row here prices the identical representative estate: 400,000 in that country's own currency.
Why 400,000, and what the arithmetic looks like. It's a plausible mid-to-upper estate value in each of these currencies, round enough to show the working. Germany: two 1.0 fees under GNotKG Tabelle B at the EUR 410,000 band (EUR 785 each) = EUR 1,570. Canada (Ontario): (CA$400,000 - $50,000 exempt) x $15/$1,000 = $5,250. Australia (NSW): falls in the $250,000-$500,000 band = $1,303. Ireland (solicitor schedule): falls in the 'does not exceed €500,000' band = EUR 350. A different estate value changes every one of these rows — check your own jurisdiction's table before relying on this for a real estate.
Gross vs. net, and who the fee is paid by. Australia's NSW fee is assessed on the estate's sworn gross value (debts not deducted); Germany, Ontario and Ireland assess on the net value (assets minus debts). This table doesn't normalise that difference away — it's a real, government-set distinction.
What's excluded. Optional add-ons genuinely separate from the probate fee itself — extra sealed copies (UK), online notice-publication fees (Australia NSW: A$59), executor's or solicitor's professional fees, and any inheritance or estate tax (a different kind of government charge entirely, not priced here).
The United States has no national fee. Probate fees are set county by county within each state's own court system. California is used here for the same reason this site's notary-fees hub uses it for notary caps: one of relatively few states with a clean statutory figure. A different state, or a different California county's local add-on fees, would show a different number.
Why some researched countries aren't here. Austria has two distinct fees assessed on different bases (court fee vs. notary-commissioner fee) with secondary sources disagreeing on both the current rate and the minimum charge — too unsettled to price with confidence. The Czech Republic's notary-as-court-commissioner fee is a degressive percentage scale amended several times with no clean current consolidated figure found. Singapore's, Hong Kong's and South Africa's official fee schedules blocked every fetch attempt. Japan and Spain don't have a single comparable 'apply for a grant' event the way common-law and German-style civil-law systems do — both route most estate administration through notaries or registries instead of a single court application.
Why do some countries charge a flat probate fee and others scale it with the estate's value?
It depends on how each country's court-fee statute is written. The UK, the US (California), New Zealand and Poland all charge the same amount no matter how large the estate is. Germany, Canada (Ontario), Australia (NSW) and Ireland set the fee as a formula or banded scale tied to the estate's value — sometimes its gross value, sometimes its value net of debts. Both are official, just structured differently.
What does the 400,000 estate figure mean, and why isn't it converted to one currency?
For the value-scaled countries, the fee shown is what that country's own schedule charges on an estate worth 400,000 in that country's own currency — EUR 400,000 for Germany and Ireland, CA$400,000 for Canada, A$400,000 for Australia. It's a single representative value chosen for comparability, not each country's typical estate. Currencies aren't converted anywhere on this table, so a face-value comparison is directional, not a precise ranking once exchange rates are applied.
Why is the United States just California?
The US has no national probate fee — it's set county by county inside each state's own court system, and many states' fees differ from California's. California is used here the same way this site's notary-fees hub uses it for notary fee caps: one of the few jurisdictions with a clean, citable statutory figure (Government Code §70650, $355).
Why aren't more countries in this table?
Several were researched and left out rather than guessed: Austria and the Czech Republic have complex, cross-referenced percentage-scale fees that couldn't be confidently reduced to one verified figure this round; Singapore's, Hong Kong's and South Africa's official fee-schedule pages blocked every fetch attempt; and Japan and Spain don't actually have a single comparable 'apply for a grant' event the way common-law and German-style civil-law systems do. See the methodology section for the full reasoning.
- 1Estate Administration Tax
Government of Ontario (ontario.ca)
$15 per $1,000 above the first $50,000 (exempt), rate in effect since 1 January 2020. Fetched directly by the researching agent 2 November 2026.
- 2Gerichts- und Notarkostengesetz (GNotKG), Kostenverzeichnis Nr. 12210 and Nr. 23300 (Anlage 1), and Tabelle B (Anlage 2 zu § 34 Abs. 3)
Bundesministerium der Justiz (gesetze-im-internet.de)
KV 12210 (Erbschein application, 1.0 fee under Tabelle B, affidavit fee charged separately per its own note) and KV 23300 (affidavit, 1.0 fee). Anlage 2 (Tabelle B, https://www.gesetze-im-internet.de/gnotkg/anlage_2.html) confirms EUR 785 at the Geschaeftswert band 'bis 410.000 EUR'. Both pages independently fetched and read directly against the primary source 2 November 2026.
- 3Supreme Court of New South Wales Fees, effective 1 July 2026
Supreme Court of New South Wales
Probate (uncontested) fee table by sworn gross estate value band: nil under $100,000; $960 ($100k-$250k); $1,303 ($250k-$500k); $1,999 ($500k-$1M); $2,663 ($1M-$2M); $4,439 ($2M-$5M); $7,399 ($5M+). Official PDF, independently re-downloaded and re-extracted directly 2 November 2026, confirming the table exactly.
- 4California Government Code §70650
California Legislature, via california.public.law
Subsection (a): $355 for the first petition for letters of administration or letters testamentary. leginfo.legislature.ca.gov, the official source, returned an access challenge on every attempt; california.public.law, a legal-publishing mirror, used instead. Full statute text independently re-read directly 2 November 2026, confirming $355 (not the $435 some secondary sources quote).
- 5Fees for applying for probate
GOV.UK / HM Courts & Tribunals Service
£526 flat application fee for estates over £5,000; no fee at £5,000 or under; £2/£16 sealed-copy fees. Fetched directly by the researching agent 2 November 2026.
- 6Probate fees
Courts Service of Ireland (courts.ie)
Fee tables for both solicitor and personal (lay) applicants, by net estate value band. Fetched directly by the researching agent 2 November 2026.
- 7Probate information and guidance
Ministry of Justice, New Zealand
NZ$275 flat fee for probate or letters of administration, prescribed by regulation. Fetched directly by the researching agent 2 November 2026.
- 8Ustawa o kosztach sądowych w sprawach cywilnych, Art. 49(1)(1) (consolidated text, Dz.U. 2023 poz. 1144)
Kancelaria Sejmu (api.sejm.gov.pl)
Flat 100 zł fee for an application to confirm acquisition of inheritance. Fetched directly by the researching agent 2 November 2026 (the same official Sejm chancellery domain used for Poland's rows on the notary-fees hub).