Notarisation vs Apostille

Legalisation is the process used to certify the authenticity of a document for international use. When a Notary Public signs and stamps a document, this is only the first step. For the document to be accepted abroad, the recipient country often requires confirmation that the notary’s credentials are valid. This is achieved through legalisation.

What Is an Apostille?

An Apostille is a certificate issued by the UK Foreign, Commonwealth & Development Office (FCDO) that confirms the authenticity of a UK public document. Specifically, it verifies:

• The identity and status of the person who signed the document (e.g. a Notary Public, solicitor, or government official)
• That the signature is genuine
• That any associated seal or stamp is authentic
• That the capacity in which the person signed the document is valid (e.g. they are a registered solicitor or official)
• That the document was issued by a UK authority recognised under the Hague Convention

The Apostille is affixed to the document and confirms its validity for use in countries that are part of the 1961 Hague Convention, which simplifies the legalisation process between member states. Because of this, the Apostille is sometimes referred to as a "Hague Stamp."

Once a notary’s signature and seal have been registered with the FCDO and/or foreign embassies, they can be verified. The Apostille is usually attached to the back of the notarised document and is accepted by countries that recognise this certification.

Apostille vs. Legalisation

Apostille refers specifically to the certificate issued by the FCDO in accordance with the Hague Convention.

Legalisation, more broadly, includes embassy or consular certification where required. Countries not party to the Hague Convention usually require this additional step.

Always verify the specific requirements of the country where the document will be used. Some countries, particularly those in the Commonwealth, may not require an apostille for official UK documents.