5. Does the law provide for the possibility of partial guardianship?
While it is excellent to see that in 20 countries (together with both California and New York state), partial guardianship is available to cover a wide range of different circumstances, there are still nine countries in which only plenary guardianship is possible: Bulgaria, Ireland, Mexico, Montenegro, Romania and the UK.
As the respondent from Ireland unfortunately describes the situation there: ìIreland operates an antiquated system of wardship under the Regulation of Lunacy Act 1871.î And, even in those countries in which partial guardianship is available, whether it is used or not, can be quite a different matter: “…it is rarely used and plenary guardianship is dominant” (Serbia).
Partial guardianship is available to cover a wide range of different circumstances. For example, temporary guardianship, guardianship only of property, etc.
Partial guardianship is possible only in a limited number of different circumstances. For example, there is no possibil- ity of guardianship of property.
Only plenary guardianship is possible.
 Albania (ALB) |
Limited partial guardianship |
 Argentina (ARG) |
Limited partial guardianship |
 Australia (AUS) |
Wide partial guardianship |
 Austria (AUT) |
Wide partial guardianship |
 Belgium – Federal State Walloon (BEL) |
Wide partial guardianship |
 Bosnia and Herzegovina (BIH) |
Wide partial guardianship |
 Bulgaria (BUL) |
Only plenary guardianship |
 Canada (CAN) |
Wide partial guardianship |
 Croatia (CRO) |
Wide partial guardianship |
 Czech Republic (CZE) |
Wide partial guardianship |
 Denmark (DNK) |
Wide partial guardianship |
 Estonia (EST) |
Limited partial guardianship |
 Finland (FIN) |
Wide partial guardianship |
 France (FRA) |
Wide partial guardianship |
 Germany (DEU) |
Wide partial guardianship |
 Hungary (HUN) |
Wide partial guardianship |
 Ireland (IRL) |
Only plenary guardianship |
 Israel (ISR) |
Wide partial guardianship |
 Italy (ITA) |
Wide partial guardianship |
 Kosovo (RKS) |
Limited partial guardianship |
 Macedonia (MKD) |
Limited partial guardianship |
 Mexico (MEX) |
Only plenary guardianship |
 Montenegro (MNE) |
Only plenary guardianship |
 Netherlands (NED) |
Wide partial guardianship |
 Portugal (POR) |
Limited partial guardianship |
 Romania (ROU) |
Only plenary guardianship |
 Serbia (SRB) |
Wide partial guardianship |
 Slovakia (SVK) |
Wide partial guardianship |
 Slovenia (SLO) |
Wide partial guardianship |
 South Africa (RSA) |
Limited partial guardianship |
 Spain (ESP) |
Limited partial guardianship |
 Sweden (SWE) |
Wide partial guardianship |
 Switzerland (SUI) |
Wide partial guardianship |
 Turkey (TUR) |
 |
 United Kingdom (UK) |
Limited partial guardianship |
 United States – California (US CA) |
Wide partial guardianship |
| United States – New York (US NY state) |
Wide partial guardianship |
