Apostille or consular legalisation: how not to get it wrong

An apostille and consular legalisation solve the same task — they confirm the authenticity of a document for another country — but they apply in different cases. An apostille works only between countries that have signed the 1961 Hague Convention. If the destination country is among them, an apostille is enough: a single stamp recognised by all parties to the Convention.

When legalisation is needed

If a country has not signed the Convention (for example the UAE or Vietnam; China, by contrast, has been a party to the Convention since 7 November 2023 and accepts apostilles), an apostille will not be accepted there. The document then goes through consular legalisation: certification at the Ministry of Justice, then at the Foreign Ministry, then at the consulate of the country in question. The process is longer and requires a personal visit to the consulate or a power of attorney for a representative.

The mistake we see most often: an apostille is affixed in advance, "just in case", while the destination country requires legalisation — and you have to start over. Check the receiving side's requirements before ordering the translation: they are often stated in the request from the institution asking for the document itself.