Диамитрий
All articles

Sworn, court, notarial translator: the difference by country

April 3, 20263 min read

Confusion over the terms "sworn", "court", "certified", "notarial" translator costs people time and money: they order the wrong kind of certification, and the document is not accepted. Let us go through it by system, so you know exactly what to ask for.

The Russian model: notary plus translator

Russia has no state register of sworn translators. Certification works as a pairing: a qualified translator makes the translation and signs it, and a notary certifies the authenticity of their signature and registers the act. Responsibility for the accuracy of the translation lies with the translator, for the procedure with the notary. To use such a translation abroad, an apostille on the original of the document is usually needed (for Hague Convention countries) or consular legalisation.

The sworn-translator model: Poland, the Czech Republic, Spain, Germany, and others

Here the state keeps an official list of translators who have passed an exam and taken an oath: tłumacz przysięgły in Poland, soudní tlumočník (soudní překladatel) in the Czech Republic, traductor jurado in Spain, öffentlich bestellter und beeidigter Übersetzer in Germany. Such a translator certifies the translation themselves — with a personal seal, signature, and a certifying formula, without a notary. Their translation has the force of an official document throughout the country.

The practical consequence: a translation made by a Russian translator and certified by a Russian notary is often not recognised in these countries for official purposes — a translation by a local sworn translator is needed. And vice versa: a translation made, for example, by a Polish tłumacz przysięgły will most likely have to be re-done in Russia for notarial acts.

How to choose the right one and not pay twice

Ask the receiving authority directly: will a notarised translation from Russia with an apostille on the original do, or is a translation by a sworn translator of their country required. If the latter, certification is done on the spot, and the agency can prepare a correct Russian basis and the apostille. If the former, the whole cycle is done in Russia.

Do not order both options "just in case": that is double the cost, and there is always one specific one that is needed. And store finished translations carefully — an unbound or damaged notarised translation is invalid and has to be ordered again.

ДИАМИТРИЙ

TAKING ORDERS 24/7