On 9 December 2025 an global conference entitled "EU Succession Regulation: A Decade in Application" was held at the Justice Institute. The event brought together representatives of discipline and law practice from respective European countries, who undertook to sum up the first decade of application of the EU's inheritance regulation and discuss future challenges.
The conference was opened by Prof. Piotr Rylski, manager of the IWS, who indicated that due to the 10 years since the application of Regulation No 650/2012 in matters of succession there is simply a request for further investigation into its applicable functioning. He besides stressed Poland's large function in drafting and adopting the regulation during the first historical Polish Presidency of the EU Council. At the same time, he pointed out that in the absence of an authoritative study from the European Commission on the functioning of the Regulation, the burden of the analysis falls on national centres specified as the Institute of Justice. The conference, with the participation of prominent representatives of discipline and practice from all over Europe, is besides part of the culmination of the Institute's 35th anniversary.
AND PANEL
The conference was opened by the discussion panel "EU Succession Regulation: achievements and challenges for the future". It was discussed by prof. Andrea Bonomi (University of Lausanne), Dr. Maciej Zachariasiewicz, Prof. ALK (Academy of Leon Kozmiński), Dr. Marcin Margoński (notary in Krapkowice) and justice Agata Srokowska (Rejonal Court in Oława / Ministry of Justice). The panel was moderated by Dr. Bogusław Lackoronski.
The discussion included issues related to the work on the text of the regulation — the arguments and doubts raised at the legislative phase were recalled and verified in the light of practice. Panelists indicated which of the doubts were confirmed and which were corrected by the practice of applying rules and case law.
II PANEL
The panel “Scope and Interplay with another Instruments and global Conventions” analysed the place of regulation in the private global law system. The issue of the boundary between succession and substantive law, the relation between the Hague Convention 1961 on the form of death resolution and the effects of bilateral global agreements was discussed.
The panel was attended by Prof. Anatol Dutta (University of Louis and Maximilian in Munich) and Prof. Louis Perreau-Saussine (Paris Dauphine University – PSL), and the panel was moderated by Prof. Konrad Osajda of the University of Warsaw.
III PANEL
The panel of jurisdiction discussed the general regulation with Article 4 of Regulation No 650/2012, the prorogation mechanisms with Articles 5 to 9 and the instruments for achieving convergence between the competent court and the applicable law. The grounds for subsidiary jurisdiction (Article 10) and the necessitatis forum (Article 11) were besides raised in matters closely linked to 3rd countries.
The panel was attended by Assoc. Prof. Jacopo Re (University of Milan) and Assoc. Prof. Lenka Válkova (University of Milan) and Dr. Piotr Rylski, Prof. IWS (Institute of Justice). The panel was moderated by Dr. Andrzej Olasi, Prof. UJ (Jagielloński University in Krakow).
IV PANEL
“Applicable Law”, attended by Prof. Jens Kleinschmidt (University of Trewira) and Dr. Anna Wysocka-Bar (Jagielloński University in Cracow), moderated by Dr. hab. Mateusz Pilich, Prof. UW (Warsaw University).
This section discusses the practice of applying the principles of choice of law (Article 22), the importance of the rule of universal application (Article 20) and the unity of inheritance, and the selected general issues (referencing, public order), supplementing this with a review of the case law (including Polish law) in conflict-law cases concerning succession.
V PANEL
The panel “Recognition, Enforcement and European Certificate of Succession” was attended by Mag. Alice Persch (notary, Leoben) and Dr. Bartosz Wolodkiewicz (University of Warsaw). The panel was moderated by prof. Karol Weitz (University of Warsaw). The session discussed the cross-border circulation of authoritative decisions and papers and the practice of utilizing ECS. The fixed elements resulting from the plan of the certificate and the areas of uncertainty, in peculiar the hazard of conflicting papers and the requirements of lex rei sitae, were identified. It besides refers to the current case law of the TEU and the ongoing preliminary rulings.
Many speeches highlighted the key function of habitual residence as a basic link between jurisdiction and conflict-of-law. Much attention was besides paid to the scope of the correction clause under Article 21(2) of the Regulation, pointing out the request to increase the predictability of its application, including proposals to clarify assessment tests or consider solutions in the event of multiple habitual residences, while maintaining unity of inheritance and consistency with the law-choice mechanism.
The conference organised by the Institute of Justice gave the chance to address key aspects of the functioning of the EU's inheritance regulation and contributed to an in-depth reflection on the direction of its further development.
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