When an official document needs to be used in another country, several formalities may be required. Among the most common terms are apostille, legalization, and certified translation.

These three concepts are often confused. However, they correspond to different yet complementary procedures.

Understanding their roles helps avoid mistakes and ensures you know which formalities to complete before submitting a document to a government agency, court, notary, or other foreign institution.

To sum up: three different procedures

The distinction can be summarized simply:

Formalities What are they used for?

Certified translation Officially translating a document into another language

Apostille Authenticating certain elements of the document for use abroad

Legalization Authenticating the document according to a procedure established for countries that are not part of the Apostille system

In other words:

Translation concerns the content of the document.

The apostille and legalization concern its authentication.

1. What is a certified translation?

A certified translation is a translation performed by a professional authorized under the rules of the country in question.

It is intended, in particular, for documents that must be officially submitted to a government agency, court, or other authority.

Depending on the country and the procedure, the translator may affix a certification, a signature, a stamp, or other markings to identify the translation and its author.

The documents involved may include:

• birth certificates;
• marriage certificates;
• divorce decrees;
• court judgments;
• criminal records;
• diplomas;
• transcripts;
• notarized documents;
• contracts;
• administrative documents.

However, a certified translation does not automatically make the original document authentic.

This is precisely where, when necessary, the apostille or legalization comes into play.

2. What is an apostille?

An apostille is a formal procedure used to certify the authenticity of certain elements of a public document intended for use in another country.

It is primarily used among countries to which the Hague Convention of October 5, 1961, Abolishing the Requirement of Legalization for Foreign Public Documents applies.

The apostille confirms, in particular, the authenticity of the signature, the capacity in which the signatory of the document acted, and, where applicable, the identity of the seal or stamp affixed to the document.

Example

You have a French document intended for presentation abroad.

The foreign authority may require that the document be apostilled.

The apostille does not translate the document.

Nor does it certify the document’s content.

It authenticates certain elements that allow the foreign authority to recognize the document’s official origin.

3. What is legalization?

Legalization is another procedure for authenticating a public document intended for use abroad.

It may be used, in particular, when the destination country is not covered by the Apostille Convention or when a specific procedure applies.

Legalization may involve several successive authorities.

Depending on the country in question, the document may need to be submitted to a competent authority in the country of origin and then, in certain situations, to the consular or diplomatic authorities of the destination country.

The specific requirements therefore depend heavily on:

• the country of origin;
• the destination country;
• the nature of the document;
• the receiving authority.

It is essential to verify the applicable procedure before taking any steps.

4. Apostille or Legalization: How to Choose?

The choice does not depend on your preference.

It depends primarily on the country in which the document is to be used and the applicable legal system.The following general rule applies:

Countries that are parties to the Apostille Convention

An apostille may be used when the conditions of the Convention are met.

Countries not covered by the Apostille system

A legalization procedure may be required.

Be aware of exceptions

Even when both countries are parties to the Hague Convention, specific rules may apply depending on the type of document or the procedure.

You must therefore always verify the requirements of the receiving authority.

5. Should the document be translated before or after obtaining the apostille?

This is a particularly important question.

There is no one-size-fits-all answer.

The order of the steps may depend on the country, the document, and the authority that will receive the file.

In some situations, the receiving authority may require that the original be apostilled first and then translated.

In other situations, the rules governing certified translations may result in a different sequence of procedures.

It is therefore best not to automatically assume that the translation must be done before or after the apostille.

You must verify the specific requirements of the receiving authority.

6. Example: A Birth Certificate Intended for Use Abroad

Let’s take the example of a French birth certificate intended for a foreign government agency.

Several scenarios are possible.

Scenario A: No Additional Formalities

The foreign authority accepts the French document and a translation that meets its requirements.

In this case, it may be necessary to have only the translation done.

Situation B: Certified Translation + Apostille

The authority requires a certified translation and authentication of the document.

The document may then require both an apostille and a certified translation.

Situation C: Legalization + Translation

If the destination country requires legalization, this step may be necessary in addition to the translation.

These examples illustrate why it is important to verify the requirements before ordering a translation.

7. What about documents intended for Belgium?

The procedures for Belgium must be determined based on the document, its origin, and the authority to which it is intended.

Belgium applies the Apostille Convention and also has specific rules regarding the legalization of foreign documents.

For certain translations intended for Belgian authorities, the rules regarding sworn translators must also be taken into account.

The Belgian Federal Public Service (SPF) for Justice provides official information on the legalization of documents and on the status of sworn translators and sworn translator-interpreters.

It is therefore recommended to verify the requirements of the relevant Belgian authority before beginning the process.

8. What about Luxembourg?

Luxembourg is also a party to the Hague Apostille Convention.

However, as with Belgium, the formalities depend on the nature of the document and the recipient organization.

A document intended for a Luxembourg government agency may therefore require a translation that meets specific conditions.

Before placing an order, it is therefore best to identify:

• the document;
• its language;
• its country of origin;
• the destination country;
• the recipient government agency or organization;
• any apostille or legalization requirements.

9. A Common Mistake to Avoid: Confusing Translation with Authentication

A certified translation does not automatically replace an apostille.

Similarly, an apostille does not replace a translation.

The two processes serve different purposes.

Certified translation:

“The document has been translated in accordance with applicable requirements.” ”

Apostille:

“Certain elements used to authenticate the public document are certified under the Apostille system.”

Legalization:

“The document has undergone the authentication procedure required for its use abroad.”

10. The right approach before any translation

Before ordering a certified translation, ask yourself these questions:

1. Where will the document be used?

France, Belgium, Luxembourg, or another country?

2. Which authority will receive the document?

Government agency, court, university, notary, lawyer, or other organization?

3. What type of document do I need to submit?

Civil registry record, court judgment, diploma, contract, criminal record, etc.

4. Is a certified translation required?

You must check the instructions provided by the receiving organization.

5. Is an apostille or legalization required?

This formality is separate from the translation.

6. In what order should these steps be taken?

Do not automatically assume that the translation must be completed before or after the apostille.

Frequently Asked Questions

Are an apostille and a certified translation the same thing?

No. An apostille is a formality for authenticating a public document. A certified translation pertains to the translation of the document itself.

Is a certified translation sufficient for use abroad?

Not necessarily. An apostille, legalization, or another formality may be required.

Do all documents need to be apostilled?

No. The requirements depend, among other things, on the country, the document, and the receiving authority.

Does the apostille certify the content of the document?

No. It certifies the authenticity of certain formal elements of the public document, not the accuracy of its content.

Does the translation need to be apostilled?

That depends on the rules applicable to the destination country and the receiving authority. The same procedure should not be applied to all cases.

Conclusion

The apostille, legalization, and certified translation serve three different purposes.

A certified translation allows the content of a document to be officially presented in another language.

The apostille and legalization, on the other hand, pertain to the authentication of the document for international use.

In a cross-border case, these formalities may be complementary. However, they are not always all necessary.

The best course of action is therefore to identify the receiving authority and verify its requirements before beginning the process.

Need a certified translation?

Do you need to submit a French, Belgian, or Luxembourgish document abroad?

You can submit the document by specifying:

• the destination country;
• the receiving organization;
• the nature of your request.

This helps determine translation requirements more precisely and identify any additional formalities that may be needed.

Laurent Voiry – Sworn Translator

Legal, Judicial, and Administrative Translations

France – Belgium – Luxembourg – International

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