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How does acquisitive prescription in civil-law countries resemble adverse possession?

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Oil portrait of Hugo de Groot, also known as Hugo Grotius, by the workshop of Michiel Janszoon van Mierevelt, showing him with a ruffled white collar and dark clothing. — Property law Portrait of Hugo de Groot (Hugo Grotius), oil on panel by the workshop of Michiel Janszoon van Mierevelt, 1631; in the Rijksmuseum, Amsterdam.

In the context of property law, acquisitive prescription in civil-law countries and adverse possession in Anglo-American jurisdictions are functionally similar concepts that allow a person to acquire legal title to property through the passage of time and continuous possession.12

Both systems operate on the principle that if a person possesses property as if they were the owner for a legally defined period, the rights of the original owner may be extinguished, resulting in the possessor acquiring a new, original title. While the terminology and specific requirements—such as the duration of possession or the necessity of good faith—may differ between legal traditions, the practical outcome is the same: the possessor becomes the true owner because the previous owner’s claim is time-barred.3124

Essentially, both concepts serve as mechanisms to resolve ownership disputes by prioritizing long-continued use and possession over stale claims, thereby providing stability and certainty in property rights.42