If you need to use a UK document abroad, you may be told to get it apostilled. This can be confusing because people often use terms such as apostille, legalisation, notarisation, solicitor certification and embassy attestation as if they mean the same thing.
They do not.
In the UK, an apostille is issued by the Legalisation Office, which is part of the Foreign, Commonwealth and Development Office, usually called the FCDO. A solicitor, notary, translator or private apostille service cannot issue the official UK apostille themselves.
A professional service can help prepare and submit your document, but the apostille itself comes from the UK Legalisation Office. GOV.UK explains that certain official UK documents can be legalised by submitting them to the Legalisation Office, which checks whether the signature, stamp or seal is genuine and attaches an apostille.
This guide explains who can apostille a UK document, when a solicitor or notary is needed, and how to avoid choosing the wrong route.
Who can issue an apostille in the UK?
The official UK apostille is issued by the FCDO Legalisation Office.
This means the FCDO is the authority that checks the relevant signature, stamp or seal on a UK document and attaches the apostille certificate.
A private company, solicitor or notary can help with the process, but they do not issue the apostille themselves.
The apostille confirms the authenticity of the signature, seal or stamp. It does not confirm that the information inside the document is true, up to date or accepted by the overseas authority.
What does the FCDO Legalisation Office do?
The FCDO Legalisation Office checks whether a recognised UK signature, stamp or seal is genuine.
If the document is accepted, the Legalisation Office attaches an apostille. This allows the document to be used in countries that accept apostilles under the Hague Apostille Convention.
The FCDO may check:
- public official signatures
- registrar signatures
- court seals
- solicitor signatures
- notary signatures and seals
- Companies House certification
- university or professional signatures, where recognised
- government department signatures
- other recognised UK official signatures or seals
If the FCDO cannot verify the signature, stamp or seal, the document may be rejected or delayed.
What can a solicitor do?
A solicitor can certify certain documents before apostille.
This is often needed when the document is a copy, private document, printout or document that does not contain a directly verifiable official signature.
A solicitor may certify:
- passport copies
- driving licence copies
- proof of address documents
- bank statements
- utility bills
- degree certificate copies
- DBS certificates
- employment letters
- private letters
- statutory declarations
- some company documents
- digital or printed documents
The apostille is then usually attached to the solicitor’s signature, not to the underlying document itself.
For example, if you need an apostilled copy of your passport, the solicitor certifies the copy first. The FCDO then legalises the solicitor’s signature.
What can a notary do?
A notary public can certify, witness or authenticate documents for international use.
A notary is often used for documents that need stronger formal certification, especially for countries with stricter legal systems or where the receiving authority specifically asks for notarisation.
A notary may be needed for:
- powers of attorney
- affidavits
- sworn statements
- overseas property documents
- company authorisations
- board resolutions
- passport copies
- certified copies of important documents
- documents for embassy attestation
- documents for civil law countries
GOV.UK guidance for British people abroad says that, if you need a certified copy of a UK document so it can be legalised, you need to use a UK-based notary.
Solicitor vs notary before apostille
The right choice depends on the document and the receiving authority.
Solicitor certification may be enough for many apostille-only documents, such as passport copies, proof of address documents, DBS certificates or academic copies.
Notary certification may be safer or required for powers of attorney, company documents, sworn statements, property documents, embassy attestation or documents going to countries with stricter legal requirements.
Before certifying the document, check whether the overseas authority asks for:
- certified copy
- solicitor-certified copy
- notarised copy
- notarial certificate
- apostilled document
- legalised document
- embassy-attested document
These terms can lead to different document routes.
What can an apostille service do?
An apostille service can help prepare and manage the legalisation process.
A professional apostille service may:
- check whether your document is suitable
- advise whether solicitor or notary certification is needed
- help avoid FCDO rejection
- submit the document for apostille
- arrange e-Apostille or paper apostille where suitable
- arrange embassy attestation if required
- help with certified translation
- return documents securely
- explain the correct order of steps
However, an apostille service does not issue the apostille itself. The official apostille is issued by the FCDO Legalisation Office.
This distinction matters because any provider claiming to “issue” UK apostilles privately should be treated with caution.
Documents that can often be apostilled directly
Some official UK documents can often be submitted directly for apostille, provided they are original official documents and contain a verifiable signature, stamp or seal.
These may include:
- birth certificates
- marriage certificates
- death certificates
- civil partnership certificates
- adoption certificates
- court documents
- Companies House certified documents
- some HMRC letters
- some government-issued certificates
- certificates of no impediment
- official registry documents
Even with official documents, the condition and format matter. Damaged, laminated, incomplete or unclear documents can cause delays or rejection.
Documents that usually need certification first
Many documents cannot be apostilled directly because they are copies, private documents or documents without a verifiable official signature.
These may include:
- passport copies
- driving licence copies
- proof of address
- bank statements
- utility bills
- degree certificate copies
- academic transcripts
- DBS certificates
- ACRO certificates in some cases
- employment letters
- medical letters
- private agreements
- powers of attorney
- company documents
- downloaded PDFs
- online statements
These documents may need solicitor or notary certification before apostille.
Why an ordinary photocopy is not enough
An ordinary photocopy is usually not suitable for apostille by itself.
The FCDO needs a recognised signature, stamp or seal to verify. A simple photocopy often has nothing for the Legalisation Office to authenticate.
This is why a copy may first need to be certified by a solicitor or notary. The apostille can then be attached to that certification.
For example, a photocopy of a degree certificate, passport or proof of address document may be rejected if it has not been certified correctly.
Paper apostille vs e-Apostille
The UK offers paper apostilles and e-Apostilles.
A paper apostille is attached to a physical document. It is often safer for original certificates, documents that must be posted, and documents that may need embassy legalisation.
An e-Apostille is issued electronically for suitable digital documents. GOV.UK says e-Apostille documents can be downloaded and shared digitally after legalisation.
An e-Apostille may be suitable if the document is digitally signed, digitally certified and accepted by the receiving authority. It may not be suitable if the recipient requires original paper documents.
When embassy legalisation is also needed
An apostille is often enough for countries that accept apostilles under the Hague Apostille Convention.
For some countries, apostille is only one step. The document may also need embassy or consular legalisation after the FCDO apostille.
This may apply to documents going to certain non-Hague countries or where the foreign authority specifically requests embassy attestation.
The process may be:
- solicitor or notary certification, if needed
- FCDO apostille
- embassy or consular legalisation
- certified translation, if required
- local ministry stamping abroad, if required
Common mistakes to avoid
Common mistakes include:
- assuming a solicitor can issue an apostille
- assuming a notary can issue an apostille
- sending an ordinary photocopy to the FCDO
- using solicitor certification when notarisation is required
- notarising a document when solicitor certification would have been enough
- choosing e-Apostille when a paper apostille is required
- forgetting embassy legalisation for non-Hague countries
- submitting a damaged or unclear document
- using the wrong certification wording
- translating the document before checking the correct order
These mistakes can cause rejection, delay and extra cost.
How to choose the right apostille route
The safest route depends on the document and where it will be used.
Start by checking:
- what type of document you have
- whether it is original, copy, scan or PDF
- whether it has a verifiable signature, stamp or seal
- which country it will be used in
- whether the recipient needs paper or digital format
- whether solicitor or notary certification is required
- whether embassy legalisation is needed
- whether translation is required
Do not rely only on the word “apostille”. The receiving authority may actually need a certified, notarised, apostilled, translated or embassy-attested document.
How we can help
We can help prepare UK documents for apostille and overseas use.
Our service can include checking whether your document can be apostilled directly, advising whether solicitor or notary certification is needed, arranging certification, submitting the document for FCDO apostille, advising on e-Apostille or paper apostille, arranging embassy attestation and helping with certified translation.
If you are unsure who should certify your document before apostille, send us a clear scan and the country where it will be used. We can confirm the safest route before you send the original.