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Partnerships and cohabitation

Living together creates no rights in most legal systems. What has not been written down does not exist.

Illustration: Partnerships and cohabitation

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Three tiers between marriage and simply living together

A civil or registered partnership is a formal status carrying most of the effects of marriage: maintenance, a property regime, inheritance, and dissolution only through a procedure. A lighter registration confers individual rights — housing, next-of-kin status, some social entitlements — without the full bond. And unregistered cohabitation creates, in most countries, no mutual claims whatsoever.

The most widespread misconception

The belief that after some years of living together a marriage-like status arises automatically is simply wrong in most systems. A minority do attach consequences to cohabitation after a qualifying period, mainly around the home and financial adjustment — but that is the exception. The general rule is blunt: no agreement, no claim, however long the relationship lasted.

What an agreement can and cannot do

A woman with grey hair puts a sealed envelope in an old sideboard while her husband watches

A cohabitation agreement can record who owns what, who pays for what and how things will be divided on separation. It generally cannot create inheritance rights and cannot create pension entitlements. For death you need a will as well — and it has to take account of any forced-heirship rules, which in many countries tie up a large part of the estate regardless of what the will says.

Protection in an emergency

A young couple seal the last moving boxes in an almost empty apartment

Without formal status, a partner may be unable to make decisions or even obtain information if the other is seriously ill. A power of attorney and an advance directive close that gap and are usually inexpensive to put in place. The same is true of the tenancy: whose name is on it determines who can stay in the home after a separation or a death.

Three documents that change everything

An agreement for property during life, a will for death, and a power of attorney for incapacity. Together they cost little and replace almost everything unmarried couples are missing by default.

The law country by country

The legal framework, the procedure, the time limits and the costs differ from one country to another. Each country below has a detailed page: governing texts, key facts, the actual procedure, costs, where to go and the traps to avoid.

Select a country to open its detailed page.

European framework

European Union

The twin of the matrimonial property regulation designates the law governing the property consequences of a registered partnership and organises recognition of decisions.

Europe

Ireland

Civil partnership closed to new couples since 2015, but a statutory redress scheme protects qualifying cohabitants.

Spain

No national law on unmarried couples: each of the seventeen autonomous communities has its own register and its own effects, from almost none to almost marital (Catalonia, the Balearics, Navarre, the Basque Country, Galicia); the survivor's pension and family reunification are open to registered couples, but intestate inheritance is not, except under regional civil law.

United Kingdom

Civil partnerships for all couples since 2019, but cohabitants have almost no automatic rights in England and Wales.

Western Africa

Ghana

No statute covers cohabitation, but the courts can use an equitable approach to jointly acquired property to help partners who contributed.

Nigeria

There is no cohabitation regime, and only statutory marriage gives the full range of spousal rights.

Middle Africa

Cameroon

Cameroon knows no registered partnership: concubinage (cohabitation outside marriage) is widespread but gives no right to maintenance, no share of property and no inheritance; rights come from having a customary marriage recorded in the état civil (civil status registry), from a will and from notarial deeds of purchase. A UK civil partnership has no status in Cameroon, and in the UK unmarried partners have few rights, even though the UK family visa is open to unmarried partners in a lasting relationship.

Eastern Africa

Ethiopia

Ethiopian law has no registered partnership but regulates the 'irregular union' of a man and woman who live together as husband and wife without a valid marriage: property acquired during it becomes common property once it has lasted three years (Revised Family Code, art. 102(1)), and either partner can end it at any time (art. 105).

Kenya

The Marriage Act 2014 ended the presumption of marriage from long cohabitation, though some judgments still recognise such unions.

Rwanda

Rwanda has no registered partnership and gives unmarried cohabitation no legal status: only the civil marriage is recognised (Law No 71/2024, Art. 195(1)), the spouses' property rights begin at the ceremony (Art. 237), and living as husband and wife with someone else while either partner is married is the offence of concubinage (Penal Code, Art. 138).

Tanzania

Tanzania has no registered partnership: a man and woman who have lived together for two years or more with the reputation of husband and wife are presumed married, a presumption courts can rebut but which then leaves the woman and her children with maintenance claims (Law of Marriage Act, s. 160).

Uganda

Cohabitation has no statute, and the long-debated bill that would have addressed it has not been enacted.

Zambia

No cohabitation regime exists; customary marriage is the route to spousal rights, and cohabitants must prove their contribution to property.

Southern Africa

South Africa

Living together can bring particular protections without reproducing all the consequences of marriage. Evidence of the partners’ commitments and contributions matters.

Southern Asia

India

Live-in relationships are legally recognised by the courts, protected under domestic violence law, and now registrable in one state.

Pakistan

No registered partnership and no cohabitation regime: written agreements and wills are the only protection.

Eastern Asia

Hong Kong

Hong Kong still has no partnership scheme, despite the 2023 Court of Final Appeal ruling requiring one for same-sex couples; until then, unmarried partners rely on written agreements and wills.

South-eastern Asia

Indonesia

Indonesia has no registered partnership or civil union: couples are either married under the Marriage Law or not, living together as husband and wife outside marriage is an offence under Article 412 of the Criminal Code (up to six months or a Rp 10 million fine) prosecutable only on a family member's complaint, and a religious marriage that was never recorded can be proved through an isbat nikah ruling.

Malaysia

Malaysian law recognises neither registered partners nor cohabitants, and for Muslims khalwat can be an offence: only contracts and wills protect an unmarried couple.

Philippines

No civil partnership, but the Family Code gives cohabiting couples co-ownership of property acquired together.

Singapore

In Singapore only marriage creates a recognised family tie, and public housing follows it: an unmarried couple protects itself solely through contracts and a will.

Northern America

Canada

Common-law status is recognised across Canada, but what it gives you depends enormously on the province.

United States

No national cohabitation regime: a few states still recognise common-law marriage, and domestic partnership survives locally.

Caribbean

Jamaica

Common-law unions of at least five years carry statutory rights to the family home and to maintenance.

Trinidad and Tobago

A cohabitant may seek property adjustment and maintenance after five years together, or after two with an agreement or a child.

South America

Argentina

The unión convivencial (cohabiting union) of the 2015 Code — two years of living together, optional registration — gives mutual support during the union, protection of the home, a compensation payment and two years' right to live in the home after a death, but neither inheritance nor community of property; written cohabitation agreements (pactos de convivencia) organise the rest. A UK civil partnership is not recognised as such, and an Argentine union has no legal status in the UK or Ireland.

Oceania

Australia

De facto couples are treated almost exactly like married couples for property and maintenance after two years.

New Zealand

De facto relationships of three years attract equal sharing of relationship property — the most far-reaching regime in the common law world.

This topic is also covered for French-speaking countries · German-speaking countries · Poland and the Polish diaspora · Türkiye and the Turkish diaspora · Spanish-speaking countries · Italy and Italian-speaking Switzerland · Portuguese-speaking countries · the Netherlands, Flanders and Suriname.

Sources

  1. Property consequences of registered partnerships — European Commission, European e-Justice Portal, 2023: European rules designating the law applicable to the property of registered partners and facilitating recognition of decisions, in 18 countries

Official or institutional documents this page relies on, consulted on 12 October 2026. Links open in a new tab.

Content updated in . The instruments cited can change: if in doubt, confirm with the official source given.

Text written with the help of AI, under the editorial responsibility of CAPIT; human reviews are occasional (method and sources: About). This content does not replace medical or legal advice. Spotted an error? Write to us.

News

Luxembourg: a single tax class would end joint taxation for future married or PACS couples from 2028

— Bill No. 8676, tabled in the Chamber of Deputies on 6 January 2026, provides for a single tax class from the 2028 tax year. People who marry or register a partnership (PACS) on or after 1 January 2028 would be taxed individually; couples already married or in a PACS could keep joint taxation for 25 years, until 2052. The text has not been passed: it is still in committee.

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