An apostille is not a translation, not a certification, and not proof that anything in your document is true.
It authenticates a signature and a seal. That is the whole job, and understanding that saves most of the wasted trips.
The short answer
| What it is | A certificate authenticating the signature and seal on a public document |
| What it proves | That the signature is genuine |
| What it does not prove | That the contents are true |
| Works between | Countries party to the Hague Convention of 1961 |
| If the destination is not a party | Full consular legalisation instead, which is slower |
| Usual first step | Notarisation, for anything not already a public document |
The one question that decides everything
Is the destination country a party to the Hague Convention?
- Yes → one apostille from the issuing country's competent authority. Done
- No → consular legalisation: notarisation, then a national authority, then that country's embassy or consulate. Several steps, several fees, several weeks
Most jurisdictions a corporate services client deals with are parties, including the UK, Ireland, Estonia, Singapore, Hong Kong and the United States. Mainland China joined in 2023, which removed one of the most common and painful legalisation routes.
Check the destination country before starting, not after. The two processes diverge at step one, and doing the apostille route for a non-member country means starting again.
- 1Is the destination country party to the Hague Convention?If yes, an apostille is enough and one authority issues it. If no, you need consular legalisation, which is slower and involves the destination's embassy.
- 2Is the document already a public document?Registry certificates usually are. Board resolutions, powers of attorney and company statements are not, and must be notarised before anything can be apostilled.
- 3When will it actually be used?The apostille does not expire but the receiving party will typically want the underlying document issued within 3 or 6 months. Order both close to the moment of use.
- 4Does it need translating?Translation is a separate step with its own requirements, and the receiving country decides whether the translation itself needs certifying.
Which documents can be apostilled
Not every piece of paper qualifies. The document must be a public document, or be made into one.
Usually apostilled directly, because they are already public documents:
- Certificate of incorporation
- Certificate of good standing or status
- Certified extracts from a company register
- Court documents
Need notarising first, because they are private documents:
- Board resolutions
- Powers of attorney
- Memorandum and articles, if you hold an unofficial copy
- Shareholder registers
- Certified copies of passports for directors
- Signed declarations and undertakings
The order matters and cannot be reversed:
- Notarise, if the document is private
- Apostille the notarised document
- Translate, if required, and check whether the translation itself must be certified
Getting these out of order is the most common reason a document comes back rejected.
What it is usually needed for
The situations that generate the request:
- Opening a bank account abroad, where the bank wants legalised proof the company exists
- Registering a branch or subsidiary in another country
- Registering as a foreign shareholder in a local company
- Tenders and government contracts in another jurisdiction
- Litigation requiring foreign corporate documents
- Property purchase by a company in another country
Banks and foreign registries are the two big ones, and both usually want a document issued recently.
The freshness trap
An apostille does not expire. The document underneath it effectively does.
- A certificate of good standing apostilled last year still carries a valid apostille
- But the receiving party will usually reject it, because they want proof of current standing
- Many registries and banks specify documents issued within 3 or 6 months
Practical rule: order the underlying document and the apostille close together, and close to when you will actually use them. Legalising documents "to have on file" wastes money in most cases.
Translation, and when it comes in
Translation is a separate step from legalisation, and the sequence depends on the destination.
- Some countries want the original apostilled, then translated
- Others want the translation itself certified, and sometimes apostilled too
- Some accept a sworn translator's certificate in place of an apostille on the translation
There is no universal answer. Ask the receiving party for their exact requirement in writing before paying for anything. This single question prevents more rework than any other step in the process.
What it does not do
Worth stating plainly, because clients regularly assume otherwise.
- It does not verify that the company is solvent, trading or well managed
- It does not make a document legally effective in the destination country
- It does not replace a required local filing
- It does not confirm that the person who signed had authority to sign
An apostilled board resolution proves a notary witnessed a signature. Whether the board had the power to pass that resolution is a question of the company's constitution, and no apostille addresses it.
Planning the timeline
For a cross-border structure, legalisation is a step people discover late and then rush.
| Step | Typical drag |
|---|---|
| Obtaining the underlying document | days |
| Notarisation | days, needs an appointment |
| Apostille | days to weeks, depending on the authority and service level |
| Consular legalisation, if not a Convention country | weeks |
| Translation | days |
Budget for the whole chain, not the apostille alone. The apostille is often the fastest step, sitting between two slower ones.
If you are setting up a company that will need documents recognised in another country, it is worth knowing which documents you will be asked for before you incorporate, alongside the other practical requirements of the jurisdiction.
The summary
| Question | Answer |
|---|---|
| What it authenticates | The signature and seal, not the contents |
| When it works | Between Hague Convention countries |
| When it does not | Non-member destinations need consular legalisation |
| Private documents | Notarise first, then apostille |
| Does it expire? | No, but the underlying document effectively does |
| Translation | Separate step, sequence depends on the destination |
| First thing to do | Ask the receiving party for the exact requirement in writing |
Frequently asked questions
What is an apostille?
A certificate that authenticates the signature and seal on a public document so it can be recognised in another Hague Convention country.
Does an apostille prove the document is true?
No. It confirms the signature and seal are genuine. It says nothing about the contents.
Which company documents need one?
Typically the certificate of incorporation, certificate of good standing, register extracts, board resolutions and powers of attorney, depending on what the receiving party asks for.
Do board resolutions need notarising first?
Yes. Private documents must be notarised before they can be apostilled.
What if the destination country is not in the Hague Convention?
You need full consular legalisation instead, which involves the destination country's embassy and takes considerably longer.
Does China accept apostilles?
Mainland China joined the Hague Convention in 2023, so apostilles are now accepted where consular legalisation was previously required.
Does an apostille expire?
No. But receiving parties usually require the underlying document to have been issued recently, often within three or six months.
Do I apostille before or after translation?
It depends on the destination. Ask the receiving party in writing before paying for either.
Can I apostille a photocopy?
Not directly. A copy must first be certified by a notary, and the notary's certification is what gets apostilled.
How long does it take?
The apostille itself is usually days. The full chain including notarisation and translation runs longer, and consular legalisation runs to weeks.
Sources
- HCCH: the Apostille Convention and its contracting parties
- GOV.UK: get a document legalised
- Hong Kong Judiciary: apostille service
Membership of the Apostille Convention changes as states accede, and an accession can be objected to by an existing party, so the list must be checked for the specific country pair rather than assumed. Freshness requirements of 3 or 6 months are imposed by the receiving registry or bank, not by the Convention, and vary between them.