Apostille accepted abroad
Foreign authorities usually want a birth certificate, diploma or other official paper that carries an apostille under the Apostille Convention of 5 October 1961. The route runs from checking the document, through notarisation where required, to the competent apostille authority in the issuing state.
| Aspect | Notarisation | Apostille |
|---|---|---|
| What it confirms | Signature, oath, affidavit or faithful copy | Capacity of the signatory and seal on a public document |
| Legal effect abroad | None by itself across borders | Accepted in the destination state without further certification |
| Who performs it | Notary public, a common-law office | Competent authority designated by the issuing state |
| Fee range | Set by national fee schedules | 0 to 180 USD across contracting states |
| Average fee | Varies by state | 15.43 EUR in a 2016 HCCH compilation of 54 states |
| Free of charge | Generally not | Yes in states such as Italy and Japan |
| Entry into force rule | Not applicable | 60 days after deposit of accession, subject to a six-month objection window |
| Number of states | Applies domestically | 130 contracting states as of September 2026 |
Follow the ordered path: verify the document, obtain notarisation if required, then apply to the competent apostille authority in the issuing state.
The Apostille Convention of 5 October 1961 simplifies how a public document issued in one contracting state is certified for legal purposes in another contracting state. Under the convention, an apostille issued by the competent authority of the issuing state is accepted by the destination state without further legalisation.
A notary public is a public officer who validates signatures, administers oaths and affirmations, takes affidavits and authenticates the execution of certain documents. In common-law systems, notarisation often precedes the apostille when the underlying document is privately signed.
The word apostille comes from French, meaning a marginal or bottom note, derived from the Latin post illa. In practice it appears as a stamped or attached certificate on the document itself or on an allonge.
Notarisation validates a signature or act; an apostille certifies that a public document will be recognised in another contracting state.
The two certifications answer different questions. Notarisation confirms that a signature is genuine, that an oath was administered, or that a copy faithfully reproduces an original. The apostille confirms the capacity of the signatory and, where applicable, the seal on a public document.
An apostille is an international certification comparable to a notarisation; where the convention applies, it removes the need for further certification by the destination state. Notarisation alone does not have that effect across borders.
For each acceding state, the convention enters into force 60 days after the deposit of its accession. Other contracting states may object during the six months after an accession is deposited, and the convention enters into force 60 days after that period.
Apostille fees vary widely: some states charge nothing, others charge up to 150 KYD (180 USD).
An HCCH compilation of apostille fees across 54 states in 2016 calculated an average of 15.43 EUR. Some states, such as Italy and Japan, charge no fee for an apostille, while the Cayman Islands charge 150 KYD (180 USD), one of the highest.
Fees are set by each contracting state individually and are not harmonised by the convention. The destination state does not charge again under the convention, provided the apostille is valid.
A fee schedule should be checked against the current publication of the competent authority, because rates change between editions of national fee tables.
Dates are taken from the convention text, the 2016 HCCH fee compilation and the September 2026 party count.
Six classes of documents most often presented for certification before use abroad.
Figures and definitions are taken from the convention text, HCCH publications and the September 2026 party count.