Published in Certified translations, Legal translations on 05/07/2024

In an international context, English is used as a lingua franca, i.e. the language of communication. Like German, French, and Dutch, English also has various standard variants that are spoken and written in different countries. The differences between the individual language variants cause hardly any problems in everyday life. Whether, for example, you say bill or note to a banknote or garbage or rubbish to refuse, it doesn’t affect the understanding in most of situations. It is crucial, however, to keep the language differences in mind when it comes to legal terminology in law texts.

Legal language in English - the differences

The legal language refers to the legal system of the respective country. When a legal text is translated into English, knowing which audience is targeted is therefore important. The difference between UK and US English can be important, even with a seemingly simple term such as “lawyer”. In the British legal system, a distinction is made between different lawyers depending on the type of court. A solicitor is a lawyer licensed to practise in lower courts whereas a barrister is responsible for higher courts. If the word barrister or solicitor is used in an English translation, it is possible that this term may not be understood (correctly) in the USA. A general translation would be lawyer, however, the term attorney is used specifically in the USA. A translation agency that specialises in legal texts is aware of these important cultural differences and, therefore, works with different professional translators depending on the language variant.

Linguistic conventions vary depending on the country

Apart from purely linguistic differences, other conventions of the respective legal systems must also be taken into account in legal translations. For example, while the paragraph symbol (§) is often used in Austrian legal texts, it is uncommon in the United Kingdom. In the USA, this symbol is used in particular in the Code of Federal Regulations. A more general term, such as section, is therefore preferable in order to avoid misunderstandings. Other general linguistic conventions are also important in legal texts. In the USA, for example, the month is given first in the date, followed by the day and then the year; this format therefore differs from the German-language format (day.month.year). Special care is, therefore, always required for legal translations. For this reason, a professional translation agency always works with experienced translators who specialise in different subject and language fields.