Americas Canada Falkland Islands The Falkland Islands registry holds copies of all Crown Grants from 1844.
United States Land registration is a matter for individual states in the USA. Thus each state will define the officials, authorities, and their functions and duties with respect to the ownership of land within that state, as is more fully described in the specified main article.
Europe Austria Czech Republic Denmark Finland Finland operates a cadastral system operated by the
National Land Survey of Finland (Finnish: )
France The French system uses a cadastre, maintained by the French public land registry. The plans are boundaries of land parcels but do not provide details of the land owner or precise boundaries.
Germany § 873.1 of the German Civil Code stipulates that the transfer of ownership of a plot of land, the encumbrance of a plot of land with a right and the transfer or encumbrance of such a right requires registration in the Land Register (
Grundbuch). Except for the cases explicitly provided for by law, the respective agreement becomes binding only upon its registration. Land used for purposes in the public interest is exempt from this requirement.
Ireland Land registration is compulsory in the
Republic of Ireland, and two parallel registries are maintained: the Land Registry ( in
Irish) and the Registry of Deeds (). The system in Ireland follows the English system, but with features typical of the Torrens system (for example, anyone can inspect the register).
Robert Torrens himself drafted the Record of Title (Ireland) Act, 1865 in order to record titles conveyed. The Landed Estates Court a register, the "Record of Title". While the record was not open to the public, the index could be inspected by anyone, today the index and folios can be viewed by anyone with an administration charge. Recording of title under the Act was voluntary and this was one of the reasons why the Act proved ineffective. A sale agreement on real estate is legally binding even without registration in the land register, the only requirement being certification of the agreement by a notary. Registration is required, however, in order for the new owner to sell or otherwise transfer the property, or enter a mortgage. Furthermore, only registration makes the transfer opposable to third parties.
Netherlands Poland The land and mortgage register system in Poland is public and accessible online. According to art. 25 of Land and Mortgage Act it provides an official and structured register of rights to real estate, divided into four sections: designation of real estate and related rights (I), information on the owner or perpetual usufructuary (II), limited property rights and claims (III) and mortgages (IV). The principle rules of Polish real estate law is the presumption of conformity of land and mortgage entries with reality – rights disclosed are considered to exist, and those deleted are considered non-existent. Also a public credibility principle protects buyers acting in good faith on the basis of information entered in the land register, even if the register does not reflect the actual legal status. However, this protection does not apply to gratuitous transactions or purchasers acting in bad faith. In addition, certain rights, such as statutory encumbrances or easements established by law, are effective regardless of their entry in the register.
Russia Content in this edit is translated from the existing Russian Wikipedia article at
:ru:Титул Торренса; see its history for attribution. Advantages of the Torrens system were seen in Russia almost immediately after its occurrence, but scrapped the Russian legal system for the overthrow of the Provisional Government and the dispersal of the Constituent Assembly did all ideas Russian imperial jurists consigned to history. Now operating the system of accounting and registration of rights to immovable property in Russia can not be called a complete system or Torrens cadastral system, although some of its elements and principles correspond to the Torrens title. Accounting for land, buildings and natural sites organized in Russia in the database of real estate cadastre of the State on the basis of a federal law in 2007 No. 221-FZ "On State Real Estate Cadastre". The account holder of these facilities is conducted in another database: the Unified State Register of rights to immovable property and transactions with them on the basis of a federal law in 1997 No. 122-FZ "On State Registration of Rights to Real Estate and Transactions Therewith". Both laws established openness cadastre and registry information, and assigned to a single organization responsible for their management – Rosreestr . Entry in the Unified State Register of real property rights is a necessary and sufficient condition for the emergence of property rights to real estate. For information about the property, contained in the cadastre and registry, sufficiently detailed and structured cover most essential information about an object runs open cadastral map. With a fairly simple web forms can be found and read a part of the information on any object property. These laws are not, however, establish an immediate full liability of the state for the correctness of the information contained in databases. In 2015, the State Duma has been registered a bill that covers public access to information about the owners of the property. The bill was supported by the Government. According to some experts, the restriction of information openness reduces the chances of identifying the public cases of illegal enrichment and increases business risks.
Slovakia Spain United Kingdom In the United Kingdom there are several land registers, including
HM Land Registry for England and Wales,
Registers of Scotland, and Land and Property Services in Northern Ireland.
England and Wales A national system of land registration was first attempted in
England and Wales under the
Land Registration Act 1862, a register having operated for the county of
Middlesex (excluding the
City of London) since 1709. This voluntary national system proved ineffective and, following further attempts in 1875 and 1897, the present system was brought into force by the
Land Registration Act 1925. It is operated by
HM Land Registry. Over time various areas of the country were designated areas of compulsory registration by order so in different parts of the country compulsory registration has been around longer than in others. The last order was made in 1990, so now virtually all transactions in land result in compulsory registration. One difference is land changing ownership after death, where land is gifted rather than sold; these became compulsorily registrable only in April 1998. Similarly it became compulsory to register land when a mortgage is created on it in 1998. The
Land Registration Act 2002 leaves the 1925 system substantially in place but enables the future compulsory introduction of
electronic conveyancing using
electronic signatures to transfer and register property. The Land Registry is connected to the European Land Information Service
EULIS. Details of registrations are available to any person upon payment of the prescribed fees. Precautionary measures have been introduced in recent years to verify the identity of persons attempting to change records of title. No details will be on record for any land which has not had a relevant transaction recorded as will often occur if, for example, ownership was last transferred before the introduction of compulsory registration in a particular area. Public access to the title and filed plans in pdf format is available for a fee at Land Registry of England and Wales. Public access to a digital version of the boundaries on aerial photography is available at Land Registry UK - Map Search. A legal boundary deals with the precise separation of ownership of land. It is an invisible line dividing one person's land from another's. It does not have thickness or width and usually, but not always, falls somewhere in or along a physical boundary feature such as a wall, fence or hedge. The exact positions of the legal boundaries are almost never shown on registered title plans and are not shown on Ordnance Survey maps. In a joint statement between Land Registry (England and Wales) and Ordnance Survey they state that:
Scotland Scotland is one of the first countries in the world to have a system of land registration. Land registration commenced in Scotland with the creation of the "Register of
Sasines" by the
Registration Act 1617. For full discussion, see
Land Registration (Scots law) Northern Ireland Land registration in
Northern Ireland is operated by
Land and Property Services, an executive agency within the Department of Finance and Personnel for Northern Ireland. Prior to 1 April 2007 it was dealt with by the
Land Registers Northern Ireland government agency.
Asia Hong Kong The
Hong Kong Land Registry administers the Land Registration Ordinance and provides facilities for search of the Land Register and related records by the public and government departments. It has responsibility for the registration of owners corporations under the Building Management Ordinance.
India Land registration is a matter for individual states in India. Thus each state will define the officials, authorities, and their functions and duties with respect to the ownership of land within that state. Each and every state has different recording and management systems. In recent times, Union Government of India and many state governments have started different programs to modernise the state level land records.
Israel Japan Malaysia New Zealand New Zealand uses the
Torrens title system, which it adopted in 1870, replacing the
deeds registration system. Land registration is governed by the
Land Transfer Act 1952. The Deeds system was introduced in 1841 and the Torrens system in 1870. Both methods ran in parallel until 1924 when registration under the Land Transfer Act (Torrens system) became compulsory and a project to issue titles for all property was instituted. A title could be issued
Limited as to Title or
Limited as to Parcel if there were doubts about the ownership or the survey.
Philippines •
Land Registration Authority ()
Singapore Thailand Oceania Australia ==See also==