authorization to act as agent or attorney for another. Common-law (common law) and civil-law (civil law) systems differ considerably with respect to powers of attorney, and there is also considerable diversity among the civil-law systems themselves. Many of the general powers of attorney that are important in civil-law countries come under the powers of trust in common-law countries.

In England, for example, one may be given the general power to carry out all of a certain type of act, such as carrying on a business after the owner's death, or one may be given the power to carry out only some very specific act. In France a general authorization must specify the types of transactions the agent may engage in, whereas in Germany a general grant of power carries no such limitation. Requirements for registration and formalization of grants of power of attorney also may vary among countries. In Italy, for example, powers of attorney must be verified by specific formalities, whereas in France they may be authorized by mere verbal agreement.