deed
noun · Deed
No German instrument answers to it, so the honest rendering keeps Deed and explains, German practice does. Urkunde says only document, Tat says an act of heroism, and the work a deed does in England, binding a promise by form alone, is done in Germany by the notarielle Beurkundung.
Which translation, when
Why
A deed is a class of instrument, signature, witness and delivery in place of the old seal, and the class has consequences, the promise binds without consideration and the limitation clock runs longer. German law has no instrument class, it has a ladder of forms attached transaction by transaction, Schriftform, § 126 BGB, Beglaubigung, § 129 BGB, Beurkundung, § 128 BGB, and the deed’s defining effect, making a gratuitous promise enforceable, is performed on the German side by the notarielle Beurkundung, § 518 Abs. 1 BGB for the gift promise. So the translation splits by object. Where the text refers to an actual English instrument, the word stays Deed, German legal writing keeps it and glosses it. Where the text wants the function under German law, the rendering names the German form. And one habit of English property language needs unlearning, title deeds are paper, German land ownership lives in the Grundbuch, § 873 BGB, registration is constitutive and the file of deeds proves history, not title.
Typical mistakes
- Als Tat ausgeführt is the loose-register howler, Tat is an act, heroic or criminal, and a document executed as a deed has nothing to confess.
- Urkunde under-translates, every document is an Urkunde, the deed’s point is that its form alone changes the legal result, and the generic word deletes exactly that.
- Title deeds tempt towards paper thinking, German ownership of land follows the Grundbuch, § 873 BGB, so a due diligence list built on Eigentumsurkunden is checking the wrong source of truth.
What matters
Cross-border opinions meet the word head-on: the guarantee was executed as a deed. German counsel keeps Deed and appends the gloss, ein formgebundenes englisches Instrument ohne deutsches Gegenstück, and where the parties want the same effect under German law, an enforceable gratuitous promise, the route is the notarielle Beurkundung, § 518 BGB, not a hunt for a German noun.
What the machine misses
Deed scatters by register in machine output, legal contexts get Urkunde, a word for any document, loose prose gets Tat, an act of valour, and neither carries the one thing the English word exists for, that form alone makes the promise bind. The instrument class vanishes in translation, and the German reader sees paper or heroism where the source named a form.
Examples
| executed as a deed | als Deed errichtet |
| title deeds | die Eigentumsurkunden |
| a deed of assignment | eine Abtretungsurkunde |
| deed of gift | notariell beurkundetes Schenkungsversprechen |
More notes on these sections
notarisation notarielle Beurkundung
conveyance Auflassung
execution Unterzeichnung