French non-judicial divorce (divorce par consentement mutuel) — recognized in New Jersey?

Custody Divorce and Family

Location: New Jersey

I am a U.S. citizen living in New Jersey. My husband is a French citizen living in France.

We were married in New York and have no children, no jointly owned real estate, and no significant marital assets.

We are currently in the final stages of a French “divorce par consentement mutuel” (mutual consent divorce). This is a non-judicial French divorce where each spouse has their own attorney, both parties sign a settlement agreement, and the agreement is then registered by a French notary. There is no judge involved.

My French attorneys have advised that they cannot guarantee recognition of this type of divorce in the United States because recognition depends on state law.

I have spoken with a U.S. paralegal and a U.S. attorney, both of whom indicated that if necessary I could still pursue proceedings in New Jersey after the French divorce is completed.

My question is:

Has anyone dealt with recognition in New Jersey of a French divorce par consentement mutuel specifically? If New Jersey does not automatically recognize this type of divorce, would the usual next step be a recognition proceeding, declaratory judgment, or a new divorce action?

I understand this is not legal advice and I am also consulting attorneys. I’m simply trying to understand how New Jersey generally handles this situation.

Posted Jun 4, 2026, 12:56 AM UTC

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