Fiduciary duty
From Equity
Contract and obligationsLegal professions
What it means
A duty of loyalty owed by someone in a position of trust, such as a trustee, a director or an agent. They must put the other person's interests first and avoid conflicts and secret profits.
Why it travels badly
Civil-law codes spread this across several separate rules, such as duties of loyalty in company law or in the law of agency, and do not have one general concept of a 'fiduciary'.
How other systems say it
Treuepflicht
A duty of loyalty that arises in specific relationships, such as between a director and the company.
devoir de loyauté
A duty found in specific contexts, without a single general fiduciary concept.
Tip for translators and students
Keep 'fiduciary duty' for common-law documents, and translate civil-law duties of loyalty by their own names.
Updated October 2026. Spotted a mistake? Tell us.
TheLawToKnow Tools’s glossary is an educational overview of the main differences between legal systems. It is not legal advice.
