If you need to use a UK document abroad, you may be told that it needs an apostille, legalisation, embassy attestation, authentication or notarisation. These terms are often used together, but they do not always mean the same thing.
The simplest way to understand it is this: an apostille is one type of document legalisation. Legalisation is the wider process of preparing a document so it can be accepted in another country.
For many countries, an apostille from the UK Foreign, Commonwealth and Development Office, known as the FCDO, is enough. For other countries, the document may need further legalisation through an embassy or consulate after the apostille.
This guide explains the difference between apostille and legalisation, when each is needed, and how to avoid choosing the wrong process.
What is document legalisation?
Document legalisation is the process of confirming that a UK document, signature, seal or stamp is genuine so it can be accepted overseas.
The UK government explains that certain official UK documents can be legalised by submitting them to the Legalisation Office. This may be needed if an official in another country asks you to provide a UK document and says it must be legalised. GOV.UK also explains that the Legalisation Office checks the document, including whether the signature, stamp or seal is genuine, and legalises it by attaching an apostille.
Legalisation does not confirm that the information inside the document is correct. It confirms the recognised signature, seal or stamp on the document.
For example, if you legalise a UK birth certificate, the apostille confirms the official signature or seal on the certificate. It does not confirm the personal details inside the certificate.
What is an apostille?
An apostille is an official certificate attached to a document so it can be recognised in another country.
In the UK, apostilles are issued by the FCDO Legalisation Office. The apostille confirms that the signature, seal or stamp on the document is genuine.
Apostilles are used between countries that are part of the Hague Apostille Convention. If the destination country accepts apostilles, the FCDO apostille is usually the only legalisation step required.
UK documents that commonly need an apostille include:
- birth certificates
- marriage certificates
- death certificates
- degree certificates
- DBS certificates
- ACRO police certificates
- powers of attorney
- company documents
- HMRC letters
- court documents
- adoption certificates
- passport copies
- statutory declarations
Some documents can be apostilled directly. Others need to be certified by a solicitor or notary before the apostille can be issued.
Is apostille the same as legalisation?
Not exactly.
An apostille is a form of legalisation, but not all legalisation stops at the apostille stage.
For Hague Convention countries, the apostille is usually enough. For non-Hague countries, legalisation may involve more steps, such as embassy attestation or consular legalisation.
In practice:
- apostille means the FCDO has attached an official apostille certificate
- legalisation means the wider process of making a document acceptable abroad
- embassy attestation means the document has been further legalised by the destination country’s embassy or consulate
- notarisation means a notary public has certified a document or signature before legalisation
This is why people often use the terms interchangeably, even though they are not identical.
When is an apostille enough?
An apostille is usually enough when the document is going to a country that accepts apostilles under the Hague Apostille Convention.
This often applies to countries in Europe and many other participating countries worldwide.
Common examples include:
- Spain
- Italy
- France
- Germany
- Greece
- Portugal
- Netherlands
- Poland
- Australia
- New Zealand
- United States
- South Africa
- India
If the receiving authority asks for an apostille, you normally do not need embassy legalisation as well. However, you should always check the exact requirements with the authority requesting the document.
When do you need further legalisation?
You may need further legalisation if the destination country does not accept apostille alone.
In this case, the document may need to go through several stages:
- solicitor or notary certification, if required
- FCDO apostille
- embassy or consular legalisation
- ministry of foreign affairs stamping in the destination country, if required
- certified translation, depending on local rules
This is often called embassy attestation, consular legalisation or full document legalisation.
Countries that commonly require additional embassy or consular steps may include:
- United Arab Emirates
- Qatar
- Kuwait
- Egypt
- Vietnam
- Thailand
- Saudi Arabia
- some other non-Hague countries
The exact process changes depending on the document type and country. A personal document, such as a birth certificate, may follow a different route from a company document or power of attorney.
What is embassy attestation?
Embassy attestation is an extra legalisation step completed by the embassy or consulate of the country where the document will be used.
For example, if a UK document is being used in a country that does not accept apostille alone, the relevant embassy may need to check the FCDO apostille and add its own stamp or certificate.
Embassy attestation is common for:
- employment documents
- degree certificates
- marriage certificates
- birth certificates
- powers of attorney
- company documents
- commercial invoices
- certificates of incorporation
- police certificates
Embassy requirements can vary. Some embassies require translations, application forms, passport copies or supporting documents before they will attest the document.
What is notarisation?
Notarisation is different from apostille and legalisation.
A notary public certifies a document, signature or copy. This may be needed before the document can be apostilled.
Notarisation is often required for:
- powers of attorney
- affidavits
- statutory declarations
- passport copies
- company documents
- overseas property documents
- documents signed by private individuals
- documents without a public official’s signature
Not all documents need notarisation. Some official UK documents, such as birth, marriage and death certificates, can often be apostilled directly if they are original official certificates.
Other documents may only need solicitor certification rather than notary certification. The correct choice depends on the document and the receiving country.
What is solicitor certification?
Solicitor certification is when a UK solicitor confirms that a copy is a true copy of the original, or certifies a document in a way that allows the FCDO to legalise it.
This is commonly needed for:
- passport copies
- driving licence copies
- proof of address
- bank statements
- utility bills
- DBS certificates
- digital documents
- academic documents
- private letters
- company documents
The FCDO may attach the apostille to the solicitor’s signature rather than directly to the original document.
If the certification wording is incorrect, the document may be rejected or the receiving authority may refuse to accept it.
Examples of apostille vs legalisation
Here are some common examples.
UK birth certificate for Spain
Spain accepts apostilles, so a UK birth certificate will usually only need an FCDO apostille.
UK degree certificate for UAE
The UAE commonly requires more than a simple apostille. A UK degree certificate may need solicitor or notary certification, FCDO apostille and UAE embassy attestation.
UK marriage certificate for Italy
Italy usually accepts apostilles, so a UK marriage certificate may only need an FCDO apostille. A certified translation may also be required depending on the authority.
UK power of attorney for Qatar
A power of attorney for Qatar may need notarisation, FCDO apostille and Qatar embassy legalisation.
UK company document for overseas business
Company documents often need certification before apostille. If the destination country does not accept apostille alone, embassy attestation may also be required.
How to know which process your document needs
The correct process depends on four key things:
- the type of document
- the country where it will be used
- whether the document is original, copy or digital
- what the receiving authority has requested
Before arranging an apostille or legalisation, check the wording from the overseas authority. Look for phrases such as:
- apostille required
- legalised document
- notarised and apostilled
- embassy attestation
- consular legalisation
- certified true copy
- sworn translation
- Ministry of Foreign Affairs stamp
If the instructions are unclear, it is better to check before submitting the document. Legalising the wrong version can cause delays and extra costs.
Common mistakes to avoid
Common mistakes include:
- assuming apostille and legalisation always mean the same thing
- getting an apostille when embassy attestation is also required
- using a solicitor when a notary is required
- notarising a document that only needed solicitor certification
- submitting a photocopy that has not been certified
- legalising an outdated document
- translating the document in the wrong order
- ignoring country-specific requirements
- assuming one process works for every country
- waiting until the last minute before a visa, wedding or relocation deadline
A document may be genuine but still rejected abroad if it has not followed the correct legalisation route.
Do translations need apostille or legalisation?
Sometimes, yes.
If a UK document is being used in a non-English-speaking country, a certified translation may be required. The order depends on the destination country.
Some authorities want:
- the original UK document apostilled first, then translated
- the translation certified and apostilled
- both the original and translation apostilled
- translation completed by a sworn translator in the destination country
- embassy attestation after translation
Before translating a document, check whether the authority wants the apostille on the original, the translation or both.
How we can help
We can help you confirm whether your UK document needs an apostille, full legalisation, embassy attestation, notarisation, solicitor certification or certified translation.
Our service can include checking the document, confirming the destination country’s requirements, arranging solicitor or notary certification, submitting the document for FCDO apostille, arranging embassy attestation where needed and advising on translation requirements.
If you are unsure which process applies, send us a scan of the document and tell us the country where it will be used. We can confirm the correct route before you send the original.