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Having a UK Adoption Order recognised in France

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Aero11 January 23, 2021 17:08

Hello, we are trying to have our UK Adoption Order recognised in France. We sent off paperwork to the Tribunal about a year ago and have just had the request declined. The main issue seems to be that in France adoption is nearly always with birth parent consent. Our UK adoption order was not granted with consent from birth parents and this is the main reason our application there has been declined. My other half is French but lives in the UK. Does anyone have any experience with this?

Our next step is to speak to a Solicitor specialising in this area, but would appreciate any help or advice anyone can offer.

Edited 17/02/2021
chestnuttree January 24, 2021 10:04

I am following this with interest, because we are also trying to get our UK adoption recognised in a European country in which adoptions take place with birth parents’ consent. Unfortunately I have no further insights to offer. I hope you get some responses!

Edited 17/02/2021
Safia January 24, 2021 11:29

Can AUK advise on this? It seems something it would be helpful to have legal knowledge on

Edited 17/02/2021
Aero11 January 25, 2021 09:03

Thank you both, I will update when I hear more or on any progress - I have seen an AUK legal helpline which I will try. Just to clarify we applied to the French Tribunal for adoption plénière (Plenary Adoption) and not the simple adoption. Someone has asked if we have any documentation which removed birth parents ' parental responsibility', which is something we will look into (maybe the placement order?) and hopefully submit on appeal. We are now in a position with the Tribunal where a solicitor is required to appeal, so our next steps are clearer.

Edited 17/02/2021
windfalls January 25, 2021 09:30

Hi areo,

Contact you child's placing authority and explain the situation. They should have a copy of the care/placement order on your child's file. Xx

Edited 17/02/2021
buafroo January 25, 2021 10:56

Hi Aero11,

Like windfalls, I thought that's all you needed. If one of you does read french, maybe this report from the European parliament might be helpful, especially section 2.2 and section 4 in its entirety:

We would be very grateful if you could keep us posted on the outcome since we might be faced with the same issue at some point.

Many thanks and best of luck.

Edited 17/02/2021
Aero11 January 25, 2021 13:56

Windfalls and buafroo, thank you both. I will look at that link today.

Looking closer at the documents we submitted to the Tribunal in France, we did submit the Placement Order. So they had sight of that as well.

AUK - have forwarded me a link on how to find a solicitor in from the law society and the Coram Legal Advice service (sadly this service doesn't look suitable for us, it seems to be focussed on children coming to the UK).

International Adoption Centre (IAC) - have forwarded me a list of Immigration Solicitors based in the UK who have experience with Adoption cases, but as an organisation they deal with children coming to the UK.

Our local Authority - suggested we might not need for the UK order to be recognised as the UK and France are signatories to the Hague Convention 1993, but would suggest professional legal advice.

French Embassy - sent a link to the Tribunal and couldn't offer further help or advice.

This is the update from our enquiries today. Not much to work on except to go for Legal Advice. I do wonder whether we are doing the right thing by submitting a case to the Tribunal, but from all the research we can see it seems that the Tribunal need to make a new judgement for our little one to become French as a dual citizen.

Edited 17/02/2021
chestnuttree January 25, 2021 14:28

That report is available in English too. Adoption without consent - EU Parliament, 2015

Unfortunately it includes very little information on France.

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buafroo January 26, 2021 18:54

Thanks for the update, we will also investigate on the topic over the next 2-3 months, I'll share anything I find on your post. Best of luck Aero11.

Edited 17/02/2021
Aero11 July 22, 2021 15:12

We have an update, but in short it looks like France doesn't automatically recognise a UK Granted Adoption Order and it is not obliged to under the Hague Convention rules (the Hague Convention only applies to Inter Country Adoptions, eg. if we were adopting a UK child but we were living in France and applying through the French system, or that is what I understand).

We received a letter (through our MP) from the UK minster in charge of the Hague Convention compliance and he said it does not apply to our circumstances. It is solely up to the French Government if they wish to recognise the UK Adoption Order. We have also seen legal advice from a UK Social Services department which clearly states the same thing. This applies not just to France but other countries too.

So the route open to us now are to seek Legal representation in France to challenge the ruling we have received declining Plenary Adoption to us. We have spoken to a couple of French lawyers in the Nantes area (where the Family Tribunal sit) and it appears to be an uncommon question. But the hope is that we can prove that the UK decision cuts parental responsibilty from birth parents in favour of us, we thought that would be indicated in the paperwork we submitted - but this is the area the lawyers seem to think we can argue from. We haven't been given any firm quotes, but it could be a thousand pounds or more in legal fees we think. I will update when we know more. Sorry it isn't the definitive answer some were looking for.

chestnuttree July 22, 2021 15:38

Thanks for keeping us posted. We are going through a similar process in another EU country at the moment. It is ridiculous, because the process here is more thorough than in my home country! 🙈😡

Fingers crossed for you!

buafroo July 28, 2021 09:47

Hi Aero11,

We cannot thank you enough for this detailed update. This is terrifying, my partner and I are nationals from two different EU countries and the implications of the denial you face are huge for all of us.

We are still waiting for the adoption order to come through but we will be fighting the same battle very soon. Your insight is extremely helpful, we will also keep you posted on how it goes with France for us too and anything relevant we might find along the way.

Wishing you all the best.

Ddhh33 October 18, 2021 23:15

I am a bit confused. We have 3 adopted children. Adopted 10 years ago. We recently moved to France and have enrolled children in Local school and used adoption ‘birth’ certificate for ID etc. We’ve not given anything else - have got child benefit being paid and never had anything asked about placement order ……why would we need to give anything else?

chestnuttree October 19, 2021 12:55

@Ddhh33 For us it is about getting citizenship for our children. In order to do so, we first need to get the adoption recognised by my home country. Have you tried to get French passports for your children?

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Baba22 June 20, 2022 19:54

Hello Aero11

i am exactly in the same situation, I am French my daughter’s father is English, we adopted our daughter here in the uk, and the same thing happened to us when we tried to have her adoption recognised in France, we sent all the paperwork in Lille and about a year later received a reply saying that it was refused.

i would be interested to know if you are happy to share of course, over a year after this post, were you successful? Would you share the name of the solicitor you used in France?

Would you be happy to talk to me over the phone about it ?

LVJK September 1, 2022 21:42

Hello Aero11, Hello Baba22,

We are in the same situation. Both French living in the UK, and we just found out that our sons Adoption Order recognition has been rejected.

Any chance to get in touch with either of you to see if we can learn from each other's experience?

Keen to take a lawyer to help on that, but would be happy to have your advices first.


Baba22 September 2, 2022 19:35

Hello LVJK

i am happy to discuss it with you separately from this forum if you want to.

LVJK September 3, 2022 08:35

Hello Baba22,

Great, thanks.

Moderator here: email address deleted. We don't recommend sharing personal details on the public forums - please use the chat function to connect with other forum users.

Edited 05/09/2022
Ddhh33 September 4, 2022 07:30

Bit late in my reply. My two youngest children (adopted) have now been in France for 3 years . They are now 14 and 16. So far no issues in any areas but they retain British passport and citizenship. We hoped they may be able to apply for dual citizenship after 5 years but am now wondering if that will be when the ‘adoption’ issue will be a problem. However, given by then one of them will be 18 maybe as they are ‘no longer a child’ it may be easier? Perhaps I will have to update in 2024 !!

Baba22 September 4, 2022 09:20


We applied for my daughter before she turned 18 it was refused, she tried to apply for French citizenship again last year age 22 it was refused again for the same reason, her adoption wasn't recognised in France, I am French, her father is English but also has a French passport.

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