The CIA World Factbook Edition 2025, the latest with this field Government

Legal system In 36 editions of 36.

Legal system was published in 36 editions of the CIA World Factbook, from 1990 to 2025. The 2025 edition carries it in 250 entries, in its Government section. Every entry is shown as that edition published it.

entries in the 2025 edition
250
the first edition with it
1990
the latest edition with it
2025

Published as “Legal system” (1990 to 2025).

the entry has the field in that editionnot in that editionthe open editionEach entry below ends in its editions with Legal system, 1990 to 2025. Point at a year above to follow it down; choose one in a row to read that edition’s text there.

Entries with Legal system in each edition

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World

1 entry

World

  • the legal systems of nearly all countries are modeled on elements of five main types: civil law (including French law, the Napoleonic Code, Roman law, Roman-Dutch law, and Spanish law), common law (including English and US law), customary law, mixed or pluralistic law, and religious law (including Islamic sharia law);
  • an additional type of legal system -- international law -- governs the conduct of independent nations in their relationships with one another

Africa

54 entries

Algeria

  • mixed system of French civil law and Islamic law;
  • judicial review of legislative acts in ad hoc Constitutional Council composed of various public officials including several Supreme Court justices

Angola

civil legal system based on Portuguese civil law; no judicial review of legislation

Benin

civil law system modeled largely on the French system and some customary law

Botswana

mixed legal system of civil law influenced by the Roman-Dutch model, including customary and common law

Burkina Faso

civil law based on the French model and customary law

Burundi

mixed legal system of Belgian civil law and customary law

Cabo Verde

civil law system of Portugal

Cameroon

mixed system of English common law, French civil law, and customary law

Central African Republic

civil law system based on the French model

Chad

mixed system of civil and customary law

Comoros

mixed legal system of Islamic religious law, the French civil code of 1975, and customary law

Congo, Democratic Republic of the now Democratic Republic of the Congo

civil law system primarily based on Belgian law, but also customary and tribal law

Congo, Republic of the now Republic of the Congo

mixed system of French civil law and customary law

Cote d'Ivoire

civil law system based on the French civil code; Constitutional Chamber of the Supreme Court reviews legislation

Djibouti

mixed system based primarily on the French civil code (as it existed in 1997), Islamic religious law (in matters of family law and successions), and customary law

Egypt

mixed system based on Napoleonic civil and penal law, Islamic religious law, and vestiges of colonial-era laws; Supreme Constitutional Court reviews laws

Equatorial Guinea

mixed system of civil and customary law

Eritrea

mixed system of civil, customary, and Islamic religious law

Eswatini

mixed system of civil, common, and customary law

Ethiopia

civil law system

Gabon

mixed system of French civil law and customary law

Gambia, The now The Gambia

mixed system of English common law, Islamic law, and customary law

Ghana

mixed system of English common law and customary law

Guinea

civil law system based on the French model

Guinea-Bissau

  • mixed system of civil law, which incorporated Portuguese law at independence;
  • influenced by Economic Community of West African States (ECOWAS), West African Economic and Monetary Union (UEMOA), African Francophone Public Law, and customary law

Kenya

mixed system of English common law, Islamic law, and customary law; Supreme Court reviews laws

Lesotho

mixed system of English common law and Roman-Dutch law; High Court and Court of Appeal review legislative acts

Liberia

mixed system of common law, based on Anglo-American law and customary law

Libya

Libya's post-revolution system is in flux and driven by state and non-state entities

Madagascar

civil law system based on the old French civil code and customary law in matters of marriage, family, and obligation

Malawi

mixed system of English common law and customary law; Supreme Court of Appeal reviews legislative acts

Mali

civil law system based on the French civil law model and influenced by customary law; Constitutional Court reviews legislative acts

Mauritania

mixed system of Islamic and French civil law

Mauritius

civil system based on French civil law with some elements of English common law

Morocco

mixed system of civil law based on French civil law and Islamic (sharia) law; Constitutional Court reviews legislative acts

Mozambique

mixed system of Portuguese civil law and customary law

Namibia

mixed system of uncodified civil law based on Roman-Dutch law and customary law

Niger

note: following the 26 July 2023 military coup, the National Council for the Safeguard of the Homeland assumed control of all government institutions and rules by decree; formerly, mixed system of civil law, based on French civil law, Islamic law, and customary law

Nigeria

mixed system of English common law, Islamic law (in 12 northern states), and traditional law

Rwanda

mixed system of civil law, based on German and Belgian models, and customary law; Supreme Court reviews legislative acts

Saint Helena, Ascension, and Tristan da Cunha

English common law and local statutes

Sao Tome and Principe

mixed system of civil law based on the Portuguese model and customary law

Senegal

civil law system based on French law; Constitutional Council reviews legislative acts

Seychelles

mixed system of English common law, French civil law, and customary law

Sierra Leone

mixed system of English common law and customary law

Somalia

mixed system of civil law, Islamic (sharia) law, and customary law (referred to as Xeer)

South Africa

mixed system of Roman-Dutch civil law, English common law, and customary law

Sudan

mixed system of Islamic law and English common law

Tanzania

English common law; judicial review of legislative acts limited to matters of interpretation

Togo

customary law system

Tunisia

mixed system of civil law, based on the French civil code and Islamic (sharia) law; Supreme Court reviews some legislative acts in joint session

Uganda

mixed system of English common law and customary law

Zambia

mixed system of English common law and customary law

Zimbabwe

mixed system of English common law, Roman-Dutch civil law, and customary law

Antarctic Region

5 entries

Antarctica

  • Antarctica is administered through annual Antarctic Treaty Consultative Meetings that include member nations, observer groups, and experts;
  • decisions are made by consensus and enforced by each country through its own laws, applying to their citizens and operations in the region south of 60° south latitude, including all ice shelves and islands;
  • in the US, the Antarctic Conservation Act prohibits actions like harming native wildlife, introducing non-native species, polluting, or entering protected areas without authorization;
  • the US National Science Foundation and Department of Justice enforce these rules;
  • US expeditions must also notify the Office of Ocean and Polar Affairs at the US Department of State, which informs other Treaty nations, as required under Public Law 95-541

Bouvet Island

the laws of Norway apply

French Southern and Antarctic Lands

the laws of France apply

Heard Island and McDonald Islands

the laws of Australia apply

South Georgia and South Sandwich Islands now South Georgia and the South Sandwich Islands

the laws of the UK apply

Arctic Region

4 entries

Greenland

Denmark's laws apply in some areas, and Greenland's law for the remainder

Iceland

civil law system influenced by the Danish model

Jan Mayen

the laws of Norway apply

Svalbard

  • laws of Norway that explicitly apply to Svalbard, including the Svalbard Act, the Svalbard Environmental Protection Act, and certain regulations;
  • the Spitsbergen Treaty and the Svalbard Treaty grant certain rights to citizens and corporations of signatory nations

Asia

23 entries

Afghanistan

  • the Taliban is implementing its own interpretation of Islamic law, which is partially based on the Hanifi school of Islamic jurisprudence and have enforced strict punishments;
  • before the Taliban takeover, Afghanistan had a mixed legal system of civil, customary, and Islamic law (2021)

Armenia

civil law system

Azerbaijan

civil law system

Bangladesh

  • common law, incorporating elements of English common law;
  • since independence, statutory law has been the primary form of legislation;
  • Islamic law applies to Muslims in family and inheritance laws, with Hindu personal law applying to Hindus and Buddhists

Bhutan

civil law based on Buddhist religious law

British Indian Ocean Territory

the laws of the UK apply

China

civil law influenced by Soviet and continental European civil law systems; legislature retains power to interpret statutes

note: in 2020, the National People's Congress adopted the PRC Civil Code, which codifies personal relations and property relations

Georgia

civil law system

India

  • common law system based on the English model;
  • separate personal law codes apply to Muslims, Christians, and Hindus;
  • judicial review of legislative acts

Japan

  • civil law system based on German model;
  • also reflects Anglo-American influence and Japanese traditions;
  • Supreme Court reviews legislative acts

Kazakhstan

civil law system influenced by Roman-Germanic law and by the theory and practice of the Russian Federation

Korea, North now North Korea

civil law system based on the Prussian model; influenced by Japanese traditions and Communist legal theory

Korea, South now South Korea

mixed system combining European civil law, Anglo-American law, and Chinese classical thought

Kyrgyzstan

civil law system that includes features of French civil law and Russian Federation laws

Maldives

Islamic (sharia) legal system with English common law influences, primarily in commercial matters

Mongolia

civil law system influenced by Soviet and Romano-Germanic systems; constitution ambiguous on judicial review of legislative acts

Nepal

English common law and Hindu legal concepts

Pakistan

common law system with Islamic law influence

Russia

civil law system; judicial review of legislative acts

Sri Lanka

mixed system of Roman-Dutch civil law, English common law, Jaffna Tamil customary law, and Muslim personal law

Tajikistan

civil law system

Turkmenistan

civil law system with Islamic (sharia) law influences

Uzbekistan

civil law system

note: in 2020, the criminal code, criminal procedure code, and code of administrative responsibility were reformed; a constitutional referendum in 2023 included additional criminal code reforms

Central America and the Caribbean

33 entries

Anguilla

common law based on the English model

Antigua and Barbuda

common law based on the English model

Aruba

civil law system based on the Dutch civil code

Bahamas, The now The Bahamas

common-law system based on the English model

Barbados

English common law; no judicial review of legislative acts

Belize

English common law

British Virgin Islands

English common law

Cayman Islands

English common law and local statutes

Costa Rica

civil law system based on Spanish civil code; Supreme Court reviews legislative acts

Cuba

civil law system based on Spanish civil code

Curacao

based on Dutch civil law

Dominica

common law based on the English model

Dominican Republic

civil law system based on the French civil code; Criminal Procedures Code modified in 2004 to include important elements of an accusatory system

El Salvador

civil law system with minor common law influence; Supreme Court reviews legislative acts

Grenada

common law based on English model

Guatemala

civil law system; judicial review of legislative acts

Haiti

civil law system strongly influenced by Napoleonic Code

Honduras

civil law system

Jamaica

common law system based on the English model

Montserrat

English common law

Navassa Island

the laws of the US apply

Nicaragua

civil law system; Supreme Court may review administrative acts

Panama

civil law system; Supreme Court of Justice reviews legislative acts

Puerto Rico

civil law system based on the Spanish civil code, within the framework of the US federal system

Saint Barthelemy

French civil law

Saint Kitts and Nevis

English common law

Saint Lucia

English common law

Saint Martin

French civil law

Saint Vincent and the Grenadines

English common law

Sint Maarten

based on Dutch civil law system with some English common law influence

Trinidad and Tobago

English common law; Supreme Court reviews legislative acts

Turks and Caicos Islands

mixed system of English common law and civil law

Virgin Islands

US common law

Europe

49 entries

Albania

civil law system except in the northern rural areas where customary law known as the "Code of Leke" is still present

Andorra

mixed legal system of civil and customary law with the influence of canon (religious) law

Austria

civil law system; Constitutional Court reviews legislative acts

Belarus

civil law system

note: nearly all major codes (civil, civil procedure, criminal, criminal procedure, family, and labor) were revised and came into force in 1999 and 2000

Belgium

civil law system based on the French Civil Code; judicial review of legislative acts

Bosnia and Herzegovina

civil law system; Constitutional Court review of legislative acts

Bulgaria

civil law

Croatia

civil law system influenced by legal heritage of Austria-Hungary

Czechia

new civil code enacted in 2014, replacing civil code of 1964 based on former Austro-Hungarian civil codes and socialist theory

Denmark

civil law; judicial review of legislative acts

Estonia

civil law system

European Union

unique supranational system in which EU treaties and EU law have primacy over member-state law

Faroe Islands

the laws of Denmark apply

Finland

civil law system based on the Swedish model

France

civil law; review of administrative but not legislative acts

Germany

civil law system

Gibraltar

the laws of the UK apply

Greece

civil legal system based on Roman law

Guernsey

customary system based on Norman customary law; includes elements of the French civil code and English common law

Holy See (Vatican City)

religious system based on canon (religious) law

Hungary

civil system influenced by the German model

Ireland

common law system based on the English model but substantially modified by customary law; Supreme Court reviews legislative acts

Isle of Man

UK laws apply, as well as Manx statutes

Italy

civil law system; Constitutional Court reviews legislation under certain conditions

Jersey

the laws of the UK apply, as well as local statutes

Kosovo

civil law system

Latvia

civil law system with traces of socialist legal traditions and practices

Liechtenstein

civil law system influenced by Swiss, Austrian, and German law

Lithuania

civil law system; legislative acts can be appealed to the Constitutional Court

Luxembourg

civil law system

Malta

mixed system of English common law and civil law based on the Roman and Napoleonic civil codes; subject to European Union law

Moldova

civil law system with Germanic law influences; Constitutional Court reviews legislative acts

Monaco

civil law system influenced by French legal tradition

Montenegro

civil law

Netherlands

civil law system based on the French system; constitution does not permit judicial review of acts of the States General

North Macedonia

civil law system; judicial review of legislative acts

Norway

mixed system of civil, common, and customary law; Supreme Court can advise on legislative acts

Poland

  • civil law system;
  • judicial review of legislative, administrative, and other governmental acts;
  • constitutional law rulings of the Constitutional Tribunal are final

Portugal

civil law system; Constitutional Court reviews legislative acts

Romania

civil law system

San Marino

civil law system with Italian civil law influences

Serbia

civil law system

Slovakia

civil law system based on Austro-Hungarian codes

Slovenia

civil law system

Spain

civil law system with regional variations

Sweden

civil law system influenced by Roman-Germanic law and customary law

Switzerland

civil law system; judicial review of legislative acts, except federal decrees of a general obligatory character

Ukraine

civil law system; judicial review of legislative acts

United Kingdom

common law system; has nonbinding judicial review of Acts of Parliament under the Human Rights Act of 1998

Middle East

17 entries

Akrotiri

  • laws applicable to the Cypriot population are, as far as possible, the same as the laws of the Republic of Cyprus;
  • note - the Sovereign Base Area Administration has its own court system to deal with civil and criminal matters

Bahrain

mixed legal system of Islamic (sharia) law, English common law, Egyptian civil, criminal, and commercial codes; customary law

Cyprus

mixed system of English common law and civil law, with European law supremacy

Dhekelia

  • laws applicable to the Cypriot population are, as far as possible, the same as the laws of the Republic of Cyprus;
  • note - the Sovereign Base Area Administration has its own court system to deal with civil and criminal matters

Iran

religious system based on secular and Islamic law

Iraq

mixed system of civil and Islamic law

Israel

mixed system of English common law, British Mandate regulations, and Jewish, Christian, and Muslim religious laws

Jordan

mixed system developed from Ottoman Empire codes (based on French law), British common law, and Islamic law

Kuwait

mixed system consisting of English common law, French civil law, and Islamic sharia law

Lebanon

mixed system of civil law based on the French civil code, Ottoman legal tradition, and religious laws covering personal status, marriage, divorce, and other family relations of the Jewish, Islamic, and Christian communities

Oman

mixed system of Anglo-Saxon law and Islamic law

Qatar

mixed system of civil law and Islamic (sharia) law (in family and personal matters)

Saudi Arabia

Islamic (sharia) system with some elements of Egyptian, French, and customary law; commercial disputes handled by special committees

Syria

mixed system of civil and Islamic (sharia) law (for family courts)

Turkey (Turkiye) now Turkiye

civil law system based on various European systems, notably the Swiss civil code

United Arab Emirates

mixed system of Islamic (sharia) law and civil law

Yemen

mixed system of Islamic (sharia) law, Napoleonic law, English common law, and customary law

North America

6 entries

Bermuda

English common law

Canada

common law system except in Quebec, where civil law based on the French civil code prevails

Clipperton Island

the laws of France apply

Mexico

civil law system with US constitutional law influence; judicial review of legislative acts

Saint Pierre and Miquelon

French civil law

United States

  • common law system based on English common law at the federal level;
  • state legal systems based on common law, except Louisiana, where state law is based on Napoleonic civil code;
  • judicial review of legislative acts

Oceania

28 entries

American Samoa

mixed legal system of US common law and customary law

Australia

common law system based on the English model

Cook Islands

common law similar to New Zealand common law

Coral Sea Islands

the common law system of Australia applies

Fiji

common law system based on the English model

French Polynesia

the laws of France apply

Guam

common law modeled on US system; US federal laws apply

Kiribati

English common law supplemented by customary law

Marshall Islands

mixed system of US and English common law, customary law, and local statutes

Micronesia, Federated States of now Federated States of Micronesia

mixed system of common and customary law

Nauru

mixed system of common law based on the English model and customary law

New Caledonia

civil law system based on French civil law

New Zealand

  • common law system,
  • based on English model,
  • with special legislation and land courts for the Maori

Niue

English common law

Norfolk Island

English common law and the laws of Australia

Northern Mariana Islands

the laws of the US apply, except for customs and some aspects of taxation

Palau

mixed system of civil, common, and customary law

Papua New Guinea

mixed system of English common law and customary law

Pitcairn Islands

local island by-laws

Samoa

mixed system of English common law and customary law; judicial review of legislative acts involving fundamental citizen rights

Solomon Islands

mixed system of English common law and customary law

Tokelau

common law system of New Zealand

Tonga

English common law

Tuvalu

mixed system of English common law and local customary law

United States Pacific Island Wildlife Refuges

the laws of the US apply

Vanuatu

mixed system of English common law, French law, and customary law

Wake Island

US common law

Wallis and Futuna

French civil law

South America

13 entries

Argentina

civil law system based on Western European legal systems

note: in 2015, Argentina adopted a new civil code, replacing the old one in force since 1871

Bolivia

civil law system with influences from Roman, Spanish, canon (religious), French, and ethnic groups' pre-colonial law

Brazil

civil law

note: a new civil-law code in 2002 replaced the 1916 code

Chile

civil law system influenced by several Western European civil legal systems; Constitutional Tribunal reviews legislative acts

Colombia

civil law system influenced by the Spanish and French civil codes

Ecuador

civil law based on the Chilean civil code with modifications; traditional law in ethnic communities

Falkland Islands (Islas Malvinas)

English common law and local statutes

Guyana

  • common law system,
  • based on the English model,
  • with some Roman-Dutch civil law influence

Paraguay

civil law system with influences from Argentine, Spanish, Roman, and French civil law models; Supreme Court of Justice reviews legislative acts

Peru

civil law system

Suriname

civil law system influenced by Dutch civil law

Uruguay

civil law system based on the Spanish civil code

Venezuela

civil law system based on the Spanish civil code

Southeast Asia

17 entries

Ashmore and Cartier Islands

the laws of the Commonwealth of Australia and the laws of the Northern Territory of Australia, where applicable, apply

Brunei

mixed legal system based on English common law and Islamic law

note: in 2019, sharia penal codes came into force and apply to Muslims and partly to non-Muslims in parallel with common law codes

Burma now Burma (Myanmar)

mixed legal system of English common law (as introduced in codifications designed for colonial India) and customary law

Cambodia

civil law system (influenced by the UN Transitional Authority in Cambodia), customary law, Communist legal theory, and common law

Christmas Island

system is under the authority of the governor general of Australia and Australian law

Cocos (Keeling) Islands

common law based on the Australian model

Hong Kong

  • mixed system of common law based on the English model and Chinese customary law (in matters of family and land tenure);
  • China's imposition of National Security Law incorporates elements of Chinese civil law

Indonesia

civil law system based on the Roman-Dutch model and influenced by customary law

Laos

civil law system similar in form to the French system

Macau

civil law system based on the Portuguese model

Malaysia

  • mixed system of English common law, Islamic law (sharia), and customary law;
  • the Federal Court can review legislative acts at the request of the supreme head of the federation

Philippines

mixed system of civil, common, Islamic (sharia), and customary law

Singapore

English common law

Taiwan

civil law system

Thailand

civil law system with common law influences

Timor-Leste

civil law system based on the Portuguese model

Vietnam

civil law system with European influences

Cite this page

Central Intelligence Agency. The World Factbook 2025, “Legal system”, all entries. Archived by The Factbook, thefactbook.org/fields/legal-system.

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