Matrimonial regimes are applied either by operation of law or by way of prenuptial agreement in civil-law countries, and depend on the lex domicilii of the spouses at the time of or immediately following the wedding.
Also, in England, the birthplace of common law, pre-nuptial agreements were until recently completely unrecognized, and although the principle of separation of property prevailed, Courts are enabled to make a series of orders upon divorce regulating the distribution of assets.
Civil-law and bijuridical jurisdictions, including Quebec, Louisiana, France, South Africa, Italy, Germany, Switzerland, and many others, have statutory default matrimonial regimes, in addition to or, in some cases, in lieu of regimes that can only be contracted by prenuptial agreements.
A married woman could not own property, sign legal documents or enter into a contract, obtain an education against her husband's wishes, or keep a salary for herself.
This situation persisted until the mid-to-late 19th century, when married women's property acts started to be passed in many English-speaking legal jurisdictions, setting the stage for further reforms.
In Spanish it is known as régimen de participación, in French participation aux acquêts, and in German Zugewinngemeinschaft or Errungenschaftsbeteiligung.