Legal professions in Poland, the USA and the UK

Advocate, barrister, solicitor, lawyer, attorney – who are they? And how to translate the names of these professions into Polish? 

The legal systems in the UK/USA and Poland are different, in UK/USA it is a common law system, while in Poland – a civil law, so finding equivalents of names of legal professions may be challenging, but let’s give it a try.

In the UK a lawyer can choose to practice law either as a solicitor or a barrister, but in the USA there is one profession – an attorney at law (attorney), as on the below illustration.

Polish equivalent for solicitor is radca prawny z ograniczonym prawem do występowania przed sądem, barrister is adwokat z ograniczonym prawem do prowadzenia spraw klienta (in the UK) (Leszek Berezowski, Jak czytać, rozumieć i tłumaczyć dokumenty prawnicze i gospodarcze).

The American attorney-at-law or attorney can be translated as pełnomocnik (if represents the clients in court) or prawnik. District attorney is prokurator okręgowy.

What about Poland? There is a system of split professions – adwokat and radca prawny.

Adwokat is a lawyer, whose primary function is to provide legal assistance, prepare legal opinions and drafts of legislative acts, as well as represent clients in court in civil, administrative and criminal trials. Radca prawny used to provide legal assistance mainly in commercial matters, but since 2015 the function became very similar to adwokat – radca prawny can also represent clients in court.

How to translate names of those functions into Polish? Adwokat is usually translated as advocate or attorney. Radca prawny is often translated as solicitor or legal counsel, but the  latter is not accurate as radca can also represent a client before the court, apart from giving legal advice.

As per the resolution of Krajowa Rada Radców Prawnych, radca prawny should be translated as attorney-at-law. However, it is not an accurate equivalent. According to prof. Leszek Berezowski, radca prawny should be translated in a descriptive manner as licenced legal advisor.