The Relationship of the European Certificate of Succession to National Certificates

In the Rome IV Proposal, the European Commission suggested rules for the creation of a European Certificate of Succession (ECS). On the level of the Member States, there exist national succession certificates with very different legal character and effects. The Rome IV Proposal contains some rather short indications how the cooperation between the ECS and the national certificates shall be organized. This contribution examines the relationship of the European and the national certificates and will try to explain more clearly the model intended by the Rome IV Proposal.