Many French lawyers consider practising outside France at some point: a post in Brussels, a secondment to New York, a move to London. The information available is often approximate, because the rules differ radically depending on the destination: what applies within the European Union applies neither in the United States nor, since Brexit, in the United Kingdom. This article sets out the four routes genuinely open to a French lawyer: practising under the home title within the Union, sitting the New York bar after an LL.M., aiming for the SQE in England and Wales, or joining the Paris office of a foreign firm. It ends with how to adapt your CV to each market.
Qualification rules change and their application depends on your personal situation. The points below give the framework; the precise conditions must be checked with the authority that grants the right to practise, whose official pages we cite.
Practising in the European Union under your home title
The principle set by Directive 98/5/EC
Within the European Union, a lawyer does not have to sit a fresh examination to practise in another Member State. Directive 98/5/EC gives every lawyer the right to practise on a permanent basis in another Member State under their home-country professional title. For a lawyer registered with a French bar, this means being able to settle in Belgium, Germany or Spain, for example, while keeping the title of avocat obtained in France. The text appears in the summary of European Union legislation published on EUR-Lex 🔗; its Article 2 🔗 sets out the right to practise under the home title.
This mechanism is distinct from the freedom to provide services (acting occasionally in another State): it governs a lasting establishment.
Registering with the host State’s authority
Practising under the home title is not automatic, however. Article 3 of the Directive 🔗 requires a lawyer who wishes to practise in a State other than the one where they obtained their qualification to register with the competent authority of that State, on presentation of a certificate attesting to their registration in the home State. In practice, you need to obtain a certificate of registration from your French bar, then lodge your application with the local bar or professional body. The host authority may require the certificate to be recent; check the time limit set by the authority you are targeting.
Once registered, you are subject to the host country’s professional and ethical rules, in addition to those of your home bar. You practise under your French title; the alignment with the local title 🔗 is covered below.
What you can do, and what remains restricted
A lawyer practising under their home title may advise on the law of their home State, on European Union law, on international law and, depending on the case, on the law of the host State. Representing and defending clients in court, however, may be restricted by local law, for example by requiring you to act jointly with a lawyer of that country. Practising as an employee is possible only to the extent that the host State allows it for its own lawyers. These are points to verify country by country before signing an employment contract.
Becoming a lawyer of the host State
The Directive also provides a route to full integration. Article 10 🔗 allows a lawyer who has practised effectively and regularly for at least three years in the host State, including in the law of that State, to apply for admission to the local profession without taking the test normally required. The lawyer must be able to prove this activity, for example by documenting the number and nature of the matters handled, and the authority may verify it. Where the activity in local law is more limited, the authority may look at the lawyer’s overall experience, if necessary after an interview. The three-year period also appears in the European Parliament summary sheet 🔗.
This possibility is valuable if you eventually want to plead in court or practise under the local title. It does, however, mean building a record of local-law practice from the first months, which few associates anticipate.
A useful reference: the reverse situation in France
French bars apply the same Directive to European lawyers who settle in France. The Paris bar sets out, on its page for lawyers registered abroad 🔗, the conditions for registration under the home title. Reading that page is a good way to understand how a bar processes this type of application, and therefore what your future host bar will expect of you.
The limits of the European framework
The Directive covers the Member States of the Union; the States of the European Economic Area and Switzerland fall under specific agreements, whose conditions should be checked with the authority concerned. Above all, since Brexit the United Kingdom is no longer part of the Union and the Directive no longer applies there: access to London now follows other rules, described below.
The New York bar and other American examinations
Why New York
Among American States, New York is the destination French lawyers mention most often: it is one of the places where international business law firms have the strongest presence, and the New York bar is a title that many clients and fellow lawyers recognise. But "being admitted in the United States" means nothing: one is admitted in a State. Admission in New York confers no right to practise in the other States, each of which sets its own rules.
Eligibility conditions
The procedure is strictly regulated by the New York State Board of Law Examiners 🔗. The eligibility of a candidate educated outside the United States is assessed under Rule 520.6 of the rules of the New York Court of Appeals. The Board examines the foreign law degree and checks that it is comparable, in length and content, to an American course of study. Where there is a gap, it can be made up by an LL.M. at a US law school approved by the American Bar Association. This is the route that American law schools describe for lawyers trained in a civil-law system, which is the case of French law.
The LL.M. is therefore not just a CV asset: for these candidates, it is the condition of eligibility. The Board describes precise requirements for the content of the programme, notably a minimum volume of in-person credits and compulsory courses, for example in professional responsibility, legal research and writing, and American law. New York University’s law school summarises these requirements on its page on the rules for foreign-trained lawyers 🔗, which mentions a minimum of 24 credits of classroom instruction. Not every LL.M. programme allows you to meet these conditions: check, before applying, that the programme you choose covers the required courses.
The advance evaluation
The candidate must ask the Board for an advance evaluation of eligibility before applying to sit the examination. The Board explains that the review can take several months from receipt of all the documents, that documents must be sent to it directly by the institutions that issue them, and that foreign-language documents must be translated by a certified translator. The filing calendar depends on the session targeted. Given these lead times, the process should be prepared before the LL.M. even begins.
Other American examinations
Each State sets its own admission rules for candidates educated abroad: some open the examination to those who have completed an LL.M., others impose different or more restrictive conditions. If your plan is aimed at California, Texas or another State, do not transpose the New York rules: consult directly the authority in charge of admission in the State concerned.
What the title changes, and what it does not
Being admitted in New York allows you to practise as an attorney of that State, under the State’s rules. For a French lawyer who stays in France, it is mainly useful in firms that handle matters governed by New York law, which is very common in financial contracts and cross-border transactions. It does not replace the French title of avocat, and does not release you from the ethical rules of the bar you belong to: state it on your CV precisely (see the last section).
England and Wales: the SQE
A single examination for foreign lawyers
Since Brexit, the United Kingdom no longer automatically recognises lawyers from the Union. To become a solicitor in England and Wales, the route is the Solicitors Qualifying Examination (SQE), run under the aegis of the Solicitors Regulation Authority (SRA). The former scheme reserved for already-qualified lawyers (the QLTS) has been replaced by the SQE, which is now the route to follow.
The SRA’s page for qualified lawyers 🔗 states that the candidate must hold a professional legal qualification conferring a right to practise, hold a degree or an equivalent-level qualification, pass the first part of the examination (SQE1) and pass the second (SQE2) or apply for an exemption from that second part. The candidate must also meet the SRA’s character and suitability checks. Unlike other candidates, already-qualified lawyers do not have to show the qualifying work experience required of everyone else.
Any exemptions, which relate only to whole assessments, are to be examined case by case on the SRA’s dedicated pages. The Law Society 🔗 also offers a guide for foreign lawyers.
An examination in English, on English law
The SQE is taken in English and covers the law of England and Wales. A French lawyer is therefore not "exempted" from learning local law: preparation, often provided by private organisations, is a real investment of time. This is why the step mostly makes sense if a London employer supports you, or if you plan to settle there for the long term.
London without becoming a solicitor
Becoming a solicitor is not the only way of working in London: some French lawyers act within firms on matters of French law or arbitration. The rules governing foreign lawyers in the United Kingdom are changing: before any decision, ask the SRA and the employer you have in mind directly about the scope of what you could do under your home title.
Joining an international firm from Paris
An accessible way in
For many French lawyers, the most realistic route to an international career is not immediate expatriation but a foreign firm established in Paris. The Paris offices of Anglo-Saxon or European firms recruit associates registered with the Paris bar or another French bar, who handle Franco-foreign matters: financing, mergers and acquisitions, arbitration, competition, international litigation. The French title of avocat is the title of practice there, and English is the working language with teams from other countries.
Why this route opens doors
Working in such an office offers what neither an LL.M. nor a foreign examination guarantees: concrete experience of international matters, colleagues from several jurisdictions and, often, opportunities for secondment to another office in the network. A lawyer who acts in international arbitration, for example, can draw on a profile like the international arbitration lawyer CV example. One who advises on import-export transactions will find reference points in the customs and international trade lawyer CV example.
What these firms read in a CV
Recruiters in these firms first check command of legal English, shown by specific elements (contracts drafted in English, matters run with foreign colleagues), then training (an LL.M. or a semester abroad is read as a sign of familiarity with common-law systems), and finally the nature of the matters handled. The same rules of candour apply as elsewhere: never claim a qualification you do not yet hold. To prepare for the discussion that follows the CV, our advice on the associate interview in a law firm remains valid, including for an interview held in English, and the article on moving from one firm to another explains how to present a change of firm.
Thinking long term
A few years in an international office often serve as a springboard: towards a secondment abroad, towards an LL.M. funded by the firm, towards a career as a partner. On this last point, see becoming a partner in a law firm, which explains what firms examine before offering partnership.
Adapting your CV to the target market
The CV is not the same depending on the route chosen. Some principles apply to all of them.
State exactly where you are qualified. A foreign recruiter looks for simple information: which title, in which jurisdiction, since when. Write Admitted to the Paris Bar, with the year, and distinguish what is acquired from what is in progress. A qualification in progress is written as such: New York Bar Examination, sitting in progress or SQE1 passed, SQE2 pending. Never present an LL.M. as an admission to the bar.
Adapt the format to local custom. In an Anglo-Saxon context, remove the photo, the date of birth and the family situation; practice varies between the shorter American resume and the British CV. Our article on the lawyer CV in English for an international firm details how to translate degrees, titles and matters. For a post in another EU country, find out about local practice: some countries expect a very detailed CV, others a short document.
Describe matters, not subjects. For a foreign recruiter, "business law" says nothing. Write a role, a scale, an outcome, without revealing a client covered by professional secrecy: Advised a listed French industrial group on the cross-border acquisition of a US target.
Highlight the local law you have practised. If you are aiming for integration into the bar of another EU State, effective practice in local law is what the authority will check. From the start, keep a record of the matters handled under the host country’s law, with their nature and date.
Align all your online presence. Dates and titles must match your lawyer LinkedIn profile, which foreign recruiters consult almost systematically.
To build several versions of your CV, one French and one English, you can start from a blank CV: the AvocatCV tool handles the layout for you and produces a PDF that applicant tracking systems (ATS) read correctly, which prevents an approximate layout from eliminating an application before a partner sees it.
Frequently asked questions
Can a French lawyer practise in another EU country without sitting another examination?
Yes, under their home title, by virtue of Directive 98/5/EC: it is enough to register with the competent authority of the host country, on presentation of a certificate of registration in France. The practical arrangements (time limits, documents, fees) and the extent of what you may do, notably before the courts, depend on each State. After three years of effective and regular practice, the Directive provides a route to the local profession.
Do you have to do an LL.M. to sit the New York bar?
The New York State Board of Law Examiners assesses the eligibility of each candidate educated abroad and provides that a gap with the American course of study can be made up by an approved LL.M. The decision is the Board’s, case by case, after an advance evaluation of your file: request it before committing to a programme.
Has Brexit closed access to London?
It has removed the benefit of Directive 98/5/EC in the United Kingdom. To become a solicitor, a French lawyer now goes through the SQE. It is not a closure but a more demanding route, whose possible exemptions should be checked with the SRA.
Is an international firm in Paris enough to build an international profile?
Yes, it is the route many associates choose: it allows you to acquire cross-border practice without leaving your bar. A secondment, an LL.M. or a foreign examination can then complete this career path if your plan requires it.
What should the CV say for an admission examination still in progress?
State the examination and its exact status (sitting in progress, SQE1 passed, pending), never an admission already granted. Specify the jurisdiction, because one is admitted in an American State or in a given jurisdiction, not "abroad".