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Understanding the terminology

Notarisation and apostille do different jobs.

An apostille does not replace every other document check. In many cases, the paper or electronic document must first be prepared or certified by the appropriate professional.

Reviewed 2026-10-22

Notarisation: the professional act

A notary considers the act required: this may involve witnessing a signature, certifying a copy or preparing a notarial certificate. The work and checks depend on the document and the overseas purpose. A certified copy and a witnessed signature are not the same thing.

Apostille: authentication of origin

The apostille authenticates the relevant official signature, capacity and seal or stamp under the Convention. It does not confirm that every statement in the underlying document is true or that the recipient must accept it for a particular transaction.

Translation: the language requirement

A translation addresses language. Ask the receiving authority who can translate, whether a certified or sworn translation is needed and which parts of the finished document must be translated. Do not assume translation is included in a legalisation service.

Decide the sequence before signing

First obtain the recipient’s instructions, then agree the required certification and legalisation route. If the recipient asks for a notarial act, a different form of certification may not be an adequate substitute.

Common questions

Does every document need notarisation first?

No. Some official documents have a different preparation route. Check the specific document and recipient requirements.

Does an apostille certify the contents?

The Convention concerns authentication of the document’s origin, not approval of its substantive contents.

Sources & review

Reviewed 2026-10-22. Requirements can change. Check current official guidance and the receiving authority’s instructions before proceeding.

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