Apostille vs. Authentication and Embassy Legalization
An apostille is one certificate that all Hague Convention countries accept. Countries outside the Convention need a longer chain: authentication, then legalization by their embassy.
By Global Certified Translations · · 3 min read
If you need to use a US document in another country, that country will usually want proof that the document is genuine. There are two routes, and which one you need depends entirely on the destination country.
The apostille route (Hague Convention countries)
The 1961 Hague Apostille Convention replaced the old chain of certifications with a single certificate, the apostille. When the destination country is a party to the Convention, one apostille from the issuing authority is enough. No embassy is involved.
- State-issued documents (birth, marriage and death certificates, state court records, documents notarized by a state notary) are apostilled by the state's designated authority, usually the Secretary of State.
- Federal documents (for example, FBI background checks and documents signed by federal officials) are apostilled by the US Department of State's Office of Authentications.
The authentication and legalization route (non-Hague countries)
If the destination country is not a party to the Convention, it will not accept an apostille. The US Department of State issues authentication certificates for documents going to those countries, and the document then needs legalization by the destination country's embassy or consulate. A typical chain for a state-issued document looks like this:
- Certification by the state authority (the same office that would issue an apostille, issuing a certificate of authentication instead).
- Authentication by the US Department of State's Office of Authentications.
- Legalization by the destination country's embassy or consulate in the US.
Each embassy sets its own fees, forms and processing times, and some also require a translation into their official language as part of the package. Check the embassy's current instructions before starting, because the order of steps matters.
How to tell which one you need
Check whether the destination country is a party to the Apostille Convention. The authoritative list is the status table published by the Hague Conference on Private International Law (HCCH). Membership changes: China, for example, began accepting apostilles in November 2023. So check the current table rather than relying on an older list.
Two details catch people out:
- A country can be a party to the Convention but object to a specific other member's accession, in which case apostilles may not be accepted between those two countries. The HCCH table notes these objections.
- The receiving office decides what it accepts. Even within a Hague country, confirm the exact requirement (apostille on the original, on a translation, or both) with the office that will receive the document.
Where translation fits in
Both routes authenticate signatures and seals, not content or language. If the destination needs a translation, decide early whether it must be made in the US (and apostilled or legalized along with the document) or by a sworn translator in the destination country. We explain the sequence in translation and apostille: which comes first?
At a glance
| Apostille | Authentication + legalization | |
|---|---|---|
| Destination | Hague Convention countries | Countries outside the Convention |
| Steps after the original document | One certificate | State and/or federal authentication, then embassy legalization |
| Embassy involved | No | Yes |
| Typical time | Days to a few weeks | Weeks, depending on the embassy |
Our apostille service
Global Certified Translations provides apostille services for $195 per document with a 5-business-day turnaround, alongside certified translation and notarization. See our apostille service for details, or contact us about a document going to a non-Hague country.