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Notarisation vs. Apostille: What’s the difference?

Very simply put, notarisation is where you need a notary to sign your document and an apostille is the verification of a signature and/or seal on a document.

Notarisation is a widely used service that covers all kinds of documents. They could be declarations for a wedding abroad, powers of attorney or incorporation documents for your company. A notary will identify a person or corporation and take an action. Typically, this is witnessing a signature or verifying that a document is genuine, sometimes both. Notarisation is often needed when documents are being used overseas.

An apostille is a document issued by the Foreign, Commonwealth and Development Office (FCDO) and they will check their databases for the signatures of notaries, solicitors and government officials like registrars. If the details match, then they will attach the apostille, if not, they will start a verifying process for registrars or other government official. They will no longer make contact with solicitors to verify their signature, so if they aren’t already registered, it is a good idea to ask them to lodge their signature at the same time as your application to prevent delays. Most solicitors are happy to help, but a few don’t want to do this. The same applies to doctors, and if you need to submit a medical report for Spain for example, then you will need to contact a doctor that will register their signature with the FCDO. There are several companies now that have realised this, and you can contact them to obtain the medical documents you need and then apply for the apostille to be attached. All notaries register their details with the FCDO, so this won’t be an issue when a document is notarised.

Sometimes you need to have both, and this will depend on what your document is and where it will be used. Birth, marriage and death certificates can have apostilles attached directly, and similar to ACRO certificates, this is all that the recipients want. Sometimes, adding a notarial certificate is too much, and the recipient will not want it, as they want the registrars signature verified, not the notary. Some documents cannot be signed in this way, such as degree or education certificates, so they have to be notarised or certified first to get the apostille.

In recent years the FCDO have started to use an e-apostille, but their application is more limited and the documents have to be digitally notarised or certified using and AES or QES signature. As a general rule of thumb, this means that paper documents that can have a paper apostille attached directly, cannot have an e-apostille at all. There are also limitations on who will receive them as they cannot be printed (all the important information is embedded in the document).

As we can see, there are lots of factors to consider when legalising your documents for use abroad. The recipient is usually the best source of information as they can confirm what it is they expect to see, we can then take it from there and produce exactly what you need.

If you have any questions, please don’t hesitate to contact me.