How do you sign a power of attorney in the U.S. for a matter in Poland?

What does a lawyer in Poland need from you?

One document, prepared before it is signed. Polish law reads the scope of a power of attorney strictly. A general power of attorney covers acts of ordinary management; for anything beyond that you need a power of attorney that names the type of act, and some acts require a power of attorney for that specific act (Civil Code, Article 98). A sentence such as "handle my affairs in Poland" therefore does much less than it sounds like: it will not cover accepting an inheritance, selling an apartment, or signing an agreement that divides an estate.

In practice we draft the wording first, send it to you, and only then do you sign. It names the matter, the authority or court, the acts covered, and whether the lawyer may appoint a substitute. Redrafting a power of attorney that arrived with too narrow a scope costs another notary appointment, another apostille, and another translation, which is exactly the delay the document was meant to avoid.

Is a signature before a U.S. notary enough?

For most matters, yes, with two steps added. The notary public certifies that you signed, not what the document says. That certification is an American public document, so before a Polish court or office will work with it, it needs an apostille, and it needs a translation into Polish by a sworn translator entered on the list kept by the Polish Ministry of Justice.

The apostille replaces consular legalization between the United States and Poland. Both countries are parties to the Hague Convention of October 5, 1961, which abolished the requirement of legalization for foreign public documents: it entered into force for the United States on October 15, 1981 and for Poland on August 14, 2005.

What is an apostille and where do you get one?

An apostille is obtained in the United States, not in Poland. For documents issued by a state, including a notarial certification, it is issued by the competent authority of that state, generally the Secretary of State, although a few states designate a different office. Documents issued by federal agencies go to the U.S. Department of State instead. The apostille is attached to the original of the notarized document, which is then translated with the apostille.

When is a certified signature not enough?

When the act itself requires a special form. If validity depends on a particular form, the power of attorney to perform that act has to be given in the same form (Civil Code, Article 99 § 1). The clearest example is real estate: an agreement that transfers or divides it is made as a notarial deed, so the power of attorney has to meet the same standard.

Two things are easy to confuse here. The fallback rule - that it is enough to observe the form required by the law of the country where a document is signed - does not apply to dispositions concerning real estate (Private International Law Act, Article 25). Granting a power of attorney, however, is not itself such a disposition, so a power of attorney signed in the United States may satisfy the form required by the law of the place where it was granted. Because the answer depends on the act and on the office that will receive the document, we check the applicable rules and agree the wording and the form with the Polish notary handling the transaction before you sign. That agreement is a practical check, not a separate source of validity.

Can you sign at a Polish consulate instead?

Yes, and for many documents it is the simplest route. A Polish consul certifies the authenticity of a signature, and the provisions of the Notary Public Law apply to that act accordingly, so it has the same legal force as a certification by a notary in Poland (Consular Law, Articles 28 and 29). A document certified this way needs no apostille and no sworn translation, because it is already a Polish document. Certifying a signature is not the same as drawing up a notarial deed: a consul may draw up a deed only with written authorization from the Minister of Justice, granted at the request of the minister for foreign affairs (Consular Law, Article 28(3)).

The limits are set by the same statute: a consul does not draw up a deed of succession, does not accept an inventory list, does not deal with European certificates of succession, and does not issue electronic copies of notarial deeds (Consular Law, Article 30). Consular appointments also have to be booked, which is why many clients sign before a local notary instead and accept the apostille step.

Which law governs the power of attorney itself?

The law chosen by the principal, which is you (Private International Law Act, Article 23). Where no choice is made, the Act points to a sequence of other laws, starting with the law of the state where the agent has the seat in which they permanently act. In practice we draft powers of attorney for Polish matters under Polish law and say so in the document, so that the authority receiving it does not have to answer that question at all.

What should the document contain?

A power of attorney that works on the first attempt usually contains: your full name as it appears in your passport, together with the passport or identity document number; the name of the lawyer and their bar details; the matter, described so that an office can recognize it, with the property or the deceased person named; the acts covered, listed rather than implied; a statement on whether a substitute may be appointed; and the date and place of signing. If the matter concerns a specific piece of real estate, the land and mortgage register number belongs in the document as well.

Send us a scan the moment it is signed. We check the wording and the apostille before the original travels, because a document that is wrong is easier to correct while it is still in the United States.

This article is general information about Polish law, not legal advice about your situation, and it does not describe the practice of any particular U.S. state. Legal basis: the Civil Code (consolidated text, Journal of Laws 2026 item 795), Articles 98 and 99 § 1; the Private International Law Act (consolidated text, Journal of Laws 2023 item 503), Articles 23 and 25; the Consular Law (consolidated text, Journal of Laws 2026 item 711), Articles 28, 29 and 30; the Hague Convention abolishing the requirement of legalisation for foreign public documents (Journal of Laws 2005 No. 112, item 938). Dates of entry into force and the authorities that issue apostilles in the United States: the Hague Conference status table, checked in September 2026.

Sources

This article is based on the acts listed below. Each link opens the text published by the Polish government, checked on September 20, 2026. Acts in force open as a consolidated text; historical acts are marked as such, with the date they stopped applying.

• Civil Codeconsolidated text, Journal of Laws 2026 item 795
• Private International Law Actconsolidated text, Journal of Laws 2023 item 503
• Consular Lawconsolidated text, Journal of Laws 2026 item 711
• Hague Convention abolishing the requirement of legalisation for foreign public documentsJournal of Laws 2005 No. 112, item 938