Apostille, Certification, Legalisation – What does this all mean?

I often work on the translation of official documents (for nationality applications among others) and the terms above regularly come up in my conversations with customers. As these are all very similar processes, it can be rather confusing to figure out which one is needed for each specific circumstance. So, what exactly is an apostille, a certification or a legalisation – and which one do you need? And where do certified translations fit in?

Apostille

The Apostille is an official government-issued certificate added to documents so they will be recognised when presented in another country. This certificate is affixed to the back of the original document, is embossed with the FCO apostille stamp and attests that the document is indeed authentic. Apostilles are accepted by any country that has signed the Hague Convention, a list of which can be found here. Unfortunately, this does not include Algeria, Canada or Senegal, among others.

Certification

If the country that issued the document has not signed the Hague Convention, then the document will need to be certified. This may vary depending on the country but will typically require a certification from the issuing authorities as well as a certification from the receiving authorities. For example, to certify a Canadian birth certificate for a French nationality application, the birth certificate must first be certified by the Canadian Department of Foreign Affairs and then by a French Consulate in Canada.

Legalisation

Legalisation is the process of certifying a document, whether it is done through an apostille or a different form of certification as described above. Any official document intended for use in a foreign country will need to be legalised.

Certified translation

This is a translation of an official document accompanied by a statement by the translator attesting that the translation is “a true and faithful rendering of the original [language]”. The translator must be a qualified professional registered with professional translation associations and, in some instances, with their Embassy.

So how do I get my document legalised?

The first point of call is the country in which the document was issued. For UK documents, you can order the legalisation online at at https://www.gov.uk/get-document-legalised. For French documents, you should email the Legalisation Office within the Europe and Foreign Affairs Ministry. For other countries, I recommend contacting your local embassy or consulate, which should be able to explain the process to you.

I need a certified translation of a legalised document. Which one should I get first?

Generally, you should first have the original document legalised before getting a certified translation. This allows the translator to mention the legalisation details in their certificate of translation (this is a requirement for French nationality applications).