Apostille vs Notarisation vs Legalisation — Understanding the Basics
When an official document needs to be used overseas, you may be asked for an apostille, notarisation, legalisation or a combination of these steps. Although the terms are sometimes used interchangeably, they describe different checks.
In the UK, an apostille is issued through the Foreign, Commonwealth & Development Office Legalisation Office. It confirms that a recognised signature, stamp or seal on a UK public document is authentic. Notarisation is performed by a notary public and may involve confirming identity, witnessing a signature or certifying a document or copy. Legalisation is the wider process of preparing a document for official use in another country.
The correct route depends on the document, the country where it was issued and the requirements of the organisation receiving it. You should confirm those requirements before paying for notarisation, an apostille or embassy legalisation.
Apostille, Notarisation and Legalisation: The Short Answer
An apostille is an official certificate used to authenticate a recognised signature, stamp or seal on a UK public document for overseas use.
Notarisation is a separate process carried out by a notary public. It may be required to verify identity, witness a signature, certify a copy or create a notarial certificate that can then be apostilled.
Legalisation is the wider authentication process. For some destinations, obtaining an apostille completes the process. Other destinations or receiving authorities may require additional certification from an embassy or consulate.
Not every document must be notarised before it receives an apostille. Original public documents such as certain birth, marriage, death, court or government documents may be eligible for direct legalisation. Other documents may first need to be certified by a UK notary or solicitor.
Apostille vs Notarisation vs Legalisation
| Process | Who carries it out? | What does it confirm? | When might it be needed? |
|---|---|---|---|
| Apostille | The UK FCDO Legalisation Office | That a recognised signature, stamp or seal on the document is authentic | When a UK document will be used overseas and the recipient asks for an apostille or legalised document |
| Notarisation | A notary public | Identity, signatures, witnessed actions, certified copies or other facts stated in a notarial certificate | When the document itself is not directly eligible for an apostille or the receiving authority specifically requests notarisation |
| Legalisation | The FCDO and, where required, an embassy or consulate | The authenticity of the relevant official signature or seal through the required chain of authentication | When a foreign authority needs formal authentication before accepting the document |
An apostille and notarisation are therefore not competing alternatives. A document may need only one of them, or notarisation may be the first step before an apostille is issued.
What Does Apostille Mean in the UK?
An apostille is an official certificate attached to, or associated with, a public document so it can be presented in another country. In the UK, apostilles are issued by the FCDO Legalisation Office.
The Legalisation Office checks whether the signature, stamp or seal on the document matches its records. If the check is successful, it legalises the document by issuing an apostille.
An apostille authenticates the origin of the document. It does not automatically confirm that every statement in the document is true, nor does it guarantee that every organisation will accept the document. The final decision remains with the authority, court, university, employer, registry or other organisation receiving it.
The Hague Apostille Convention
The Hague Apostille Convention simplified the use of public documents between participating countries by replacing the traditional chain of diplomatic or consular legalisation with a single apostille certificate.
However, you should not rely only on a general list of Convention countries. Confirm the exact requirement with the recipient because individual document rules, bilateral objections and additional procedures can affect what is needed.
What Is Notarisation?
Notarisation is carried out by a notary public. Depending on the document and intended use, the notary may:
- confirm the identity and capacity of a person signing a document;
- witness a signature;
- certify that a copy corresponds with the original;
- verify the execution of a power of attorney, declaration or company document; or
- issue a notarial certificate describing the checks completed.
The notarised document or notarial certificate may then be submitted to the FCDO for an apostille if the receiving authority requires further authentication.
Notarisation Is Not the Same as an Apostille
A notary performs the underlying notarial act. The FCDO then authenticates the recognised signature and seal of the notary by issuing an apostille.
Some documents can be apostilled without a notary. Others need notarisation because there is no directly recognisable public signature or because the foreign recipient has specifically requested a notarial act.
Does a Document Have to Be Notarised to Be Apostilled?
No. A document does not always have to be notarised before it can receive an apostille.
Certain original UK public documents may be submitted directly to the Legalisation Office. Examples can include:
- birth, marriage and death certificates issued by a public registry;
- court documents carrying the required court seal;
- documents issued and signed by a government department; and
- certain Companies House documents.
Other documents may need to be certified by a UK notary or solicitor before the FCDO can legalise them. These can include:
- certified passport or driving licence copies;
- powers of attorney;
- private contracts;
- qualification certificates; and
- documents that do not already carry a recognised public signature, stamp or seal.
The requirements also depend on whether the recipient wants the original document, a certified copy, a solicitor-certified document or a notarised document. Ask the receiving organisation for written instructions before starting the process.
How the UK Legalisation Process Works
The process is not identical for every document. A practical sequence is:
1. Ask the receiving authority what it requires
Confirm the country of use, the document format and whether the recipient requires:
- the original or a certified copy;
- notarisation or solicitor certification;
- a paper apostille or e-Apostille;
- a certified translation;
- translation of the apostille itself; or
- additional embassy or consular legalisation.
2. Check where the document was issued
The UK Legalisation Office legalises eligible UK documents. A document issued in another country normally needs to be legalised through the competent authority in the country where it originated.
3. Determine whether notarisation is required
Some public documents can be submitted directly. Other documents must first be signed or certified by a UK notary, solicitor or another recognised public official.
4. Apply for the apostille
Applications for paper apostilles and e-Apostilles are made online. Paper documents are submitted using the instructions provided after the application. Eligible electronically signed PDF documents can be uploaded for an e-Apostille.
5. Complete any additional destination-country steps
For some countries or specific document types, the apostille may complete the authentication process. In other cases, the document may also need to be submitted to an embassy or consulate.
6. Arrange the translation in the required order
Some recipients want the original document apostilled before it is translated. Others may require the translation to be certified or notarised and then legalised. Confirm the required sequence before ordering the translation.
Which Documents Can Be Apostilled?
A wide range of UK documents may be eligible for an apostille, although the preparation required varies by document.
Birth, Marriage and Death Certificates
An original certificate or official certified copy issued by the appropriate public registry may be eligible for a paper apostille without prior notarisation.
Court Documents
A court document may be eligible if it carries the required official court seal or other recognised authentication.
Passports and Driving Licences
The original identity document is not normally submitted for an apostille in the same way as a public certificate. A certified copy may first need to be prepared and signed by an eligible notary or solicitor.
Degree Certificates and Academic Qualifications
The receiving institution may require the original qualification, a certified copy or a notarised copy. Confirm whether the qualification must first be certified before applying for the apostille.
Powers of Attorney, Affidavits and Private Contracts
These documents commonly involve a signature, witnessed act or notarial certificate. Notarisation may therefore be required before the notary’s signature and seal can be apostilled.
Company Documents
Certain documents issued by Companies House may be eligible, while private company resolutions, authorisations or commercial documents may need additional certification.
Because eligibility depends on the document’s signature, seal, issuing body and intended use, check the requirements before sending an original document.
When Do You Need an Apostille, Notarisation, or Legalisation?
Understanding when to use each service can save time and ensure your documents are accepted abroad:
- Apostille: Required for documents intended for use in Hague Convention countries.
- Notarisation: Necessary for documents that need to be verified for legal purposes, such as contracts or affidavits.
- Legalisation: Needed for documents intended for countries outside the Hague Convention.
Paper Apostille vs e-Apostille
The UK offers both paper-based apostilles and electronic apostilles.
Paper Apostille
A paper apostille is attached to or issued with the physical document. This option may be required when the receiving authority wants an original document or when the document is not eligible for electronic legalisation.
e-Apostille
An e-Apostille is issued electronically for an eligible PDF that has been electronically signed by a UK notary or solicitor. Once issued, it can be downloaded and shared digitally.
An e-Apostille is not available for every document. Current exclusions include General Register Office certificates such as birth, death, marriage, civil partnership and adoption certificates, as well as several police, disclosure and fingerprint certificates.
Always ask the recipient whether it accepts an e-Apostille before choosing the electronic option.
Translation, Notarisation and Apostille: Which Comes First?
There is no single correct order for every application. The appropriate sequence depends on the document and the authority receiving it.
Common routes include:
- Original UK document → apostille → certified translation: This may be appropriate when the recipient wants the apostilled original and a translation of the completed document.
- Certified copy or notarised document → apostille → translation: This may apply when a notary must first certify a copy, witness a signature or issue a notarial certificate.
- Document → certified translation → notarisation or legalisation: Some authorities ask for the translator’s certification or signature to be notarised or authenticated.
Ask whether the apostille certificate itself must be translated. Some organisations require a translation of the complete document package, while others want the apostille left in its issued form.
Before ordering, provide the translation service with:
- the complete document;
- the destination country;
- the name of the receiving authority;
- any written instructions from that authority; and
- the required submission deadline.
This helps prevent the translation, notarisation and apostille steps from being completed in the wrong order.
UK Apostille Costs and Processing Times
The following FCDO fees and estimated processing times were published by GOV.UK at the time this guide was updated:
| Service | Government fee per document | Published processing time |
|---|---|---|
| Standard paper apostille | £45 | Usually up to 25 working days, plus return delivery |
| e-Apostille | £35 | Up to two working days |
| Next-Day paper service for registered businesses | £40 | Next working day |
| Restricted Urgent service for registered businesses | £100 | Same day following prior approval |
Postage or courier charges are additional for paper documents.
Notary, solicitor, translation, agency, embassy and consular fees are separate from the FCDO apostille fee. The total price therefore depends on:
- whether the document needs notarisation;
- how many documents require separate apostilles;
- whether certified translation is required;
- the destination country;
- embassy or consular charges;
- return postage or international courier costs; and
- the required turnaround.
Fees and processing times can change. Check the current GOV.UK information before applying or requesting a final quote.
Practical Document Checklist
Before arranging an apostille, notarisation, legalisation or certified translation, confirm the following:
- Which country will receive the document?
- Which organisation or authority will receive it?
- Was the document issued in the UK?
- Does the recipient want the original or a certified copy?
- Does it specifically require a notary rather than a solicitor?
- Is a paper apostille required, or will an e-Apostille be accepted?
- Does the document need embassy or consular legalisation?
- Is a certified translation required?
- Must the apostille also be translated?
- Does the translation need to be completed before or after legalisation?
- Does each document require its own apostille?
- What is the final submission deadline?
Where possible, obtain the answers in writing from the authority requesting the document. This is safer than relying on general guidance because requirements vary between countries, organisations and document types.
Apostille, Notarisation or Legalisation: Which Do You Need?
An apostille authenticates a recognised signature, stamp or seal on a UK public document. Notarisation is a separate professional act that may involve checking identity, witnessing signatures or certifying a document. Legalisation is the wider process of preparing a document for official use abroad.
You may need:
- an apostille without notarisation;
- notarisation followed by an apostille;
- an apostille followed by embassy or consular processing;
- a certified translation; or
- a combination of these steps.
The receiving authority should determine the route. Confirm its requirements, check whether the document is eligible for a paper or electronic apostille and arrange any translation in the correct order.
Questions Clients Often Ask
What does apostille mean in the UK?
In the UK, an apostille is an official certificate issued by the FCDO Legalisation Office. It confirms that a recognised signature, stamp or seal on a UK public document is authentic so the document can be presented overseas.
What is the difference between an apostille and notarisation?
Notarisation is performed by a notary public and may involve confirming identity, witnessing a signature or certifying a document. An apostille is issued by the FCDO to authenticate a recognised public signature, stamp or seal. A notarised document may subsequently need an apostille.
Does a document have to be notarised to be apostilled?
Not always. Certain original public documents, including eligible registry, court and government documents, may be apostilled directly. Other documents, such as certified passport copies, contracts, powers of attorney and some qualifications, may first need certification by a notary or solicitor.
Is an apostille the same as legalisation?
An apostille is one form of legalisation. For many international document routes, the apostille completes the authentication process. Other countries or authorities may require additional embassy or consular legalisation.
Can the UK apostille a document issued in another country?
The UK Legalisation Office legalises eligible UK documents. A document issued overseas generally needs to be legalised by the competent authority in the country where it was issued.
How much does an apostille cost in the UK?
At the time this guide was updated, the FCDO charged £45 for a standard paper apostille and £35 for an e-Apostille. Postage, courier, notarisation, translation and service-provider charges are additional. Check GOV.UK before applying because fees can change.
How long does a UK apostille take?
Current published processing times are usually up to 25 working days for the standard paper service and up to two working days for an e-Apostille. Delivery time and any signature-verification checks can extend the overall turnaround.
Can an apostille be checked online?
A paper or electronic UK apostille can be checked through the GOV.UK verification service using the issue date and apostille number shown on the certificate.
Does an apostille translate a document?
No. An apostille authenticates the relevant signature, stamp or seal; it does not translate the document. The receiving authority may separately require a certified translation.
Should the document be translated before or after the apostille?
The correct order depends on the receiving authority. Some organisations want the original document apostilled before translation. Others require a translated or notarised document to be legalised. Confirm the sequence before ordering either service.
Need a Certified Translation for Overseas Use?
The correct translation format may depend on whether your document will be notarised, apostilled or submitted for further legalisation.
Send us a clear copy of your document together with the destination country, receiving authority, deadline and any written instructions you have received. Our team can review the translation requirements and prepare an appropriate certified translation for the next stage of your application.
Send your documents securely to request a quote.