When requesting a translation into English, you will often be asked whether you would prefer American or British English – an aspect of translation that can, but should not, be neglected in terms of importance. Many people understand the basic spelling differences between these dialects, such as the use of a Z or S in words like organisation/organization. However, it is important to remember that spelling, albeit a significant difference between the dialects, is not the only one. In fact, considering that the US and UK have different legal systems and laws, legal documents in American and British English also present differences in vocabulary, which is particularly noteworthy in order to ensure accuracy in a legal translation.
When choosing a dialect, it is important to consider where the translation will be used. If it is to be delivered to a client in the USA, you will of course opt for American English. However, if the translation is for the UK (or anywhere in Europe for that matter), British English should be used.
Here are some things that must be considered when translating a document into American or British English:
American and British English use different formats when writing the date. While the British format follows the natural progression of day-month-year, the USA uses the month-day-year structure and, interestingly, is quite unique in this position, with many other countries worldwide following the day-month-year structure. This is essential to understand since a mix-up could lead to missed meetings or deadlines.
The USA expresses units of measurement using the imperial system, while the UK uses a mixture of both the metric and imperial system, due to traditionally using the latter system but gradually introducing the former system to meet industry and trade requests. At present, the NHS (National Health Service) in the UK uses the metric system since it forms part of the EU where the metric system is standardised by various treaties and directives. However, the imperial system is officially used for speed limits and commonly used for measuring a person’s height and weight. Therefore, this will also affect the translator’s choices when it comes to units of measurement depending on the end user.
As we mentioned, vocabulary can vary greatly between both dialects, in particular within the legal and business sector. Below, we have provided you with a list of some key terminology differences. While this list is not exhaustive, it provides a glimpse into how important understanding the differences between these two dialects can be.
|Articles of association||Bylaws|
|Competition law||Antitrust law|
|Balance sheet||Statement of financial position|
|Company law||Corporation law|
|Employment law||Labor law|
|Flotation||Initial public offering (IPO)|
|Ordinary shares||Common stock|
|Preference shares||Preferred stock|
|Private limited company (Ltd.)||Limited liability company (LLC)|
It is well known that a history of cultural differences has separated these two dialects and while they are very similar in many aspects, they are not the same nor can they be used interchangeably. The emergence of global media has undoubtedly caused us to become more accustomed to these differences and new terms, but they must not be overlooked, in particular in legal documents where comprehension is key. Before requesting a translation into English, consider your target reader -the end customer- would they understand what you mean by a meeting held on 04-03-2019 or a statement of financial position?
Rupert Haigh (2018). Legal English. Oxon: Routledge, p. 109-118.
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