Apostille vs. Certification: What’s the Difference?
When presenting documents intended for use in foreign countries, including legal, commercial and international trade documentation, they will often first need to be verified by relevant authorities in the country of issue. However, the way in which this is done can vary significantly, depending on any country-specific requirements where the document is intended to be used.
In many cases, documents can be certified by way of a singular authentication certificate, known as an apostille, although some countries may require additional authentication or certification steps to be taken. The following blog looks at the similarities and differences between apostille and certification, including the different types of certification that may be needed, including but not limited to the use of an apostille.
What is an apostille?
An apostille is one of the quickest and easiest methods of certifying important documents issued in one country for use in another. An apostille authentication certificate is issued by the competent authority for the country in which the document originated. In the UK, this is the Legalisation Office of the Foreign, Commonwealth and Development Office (FCDO).
This could be a certificate for a single document or a number of documents at the same time, depending on the specific requirements of any one signatory country. The Legalisation Office will check the documentation submitted to see if any signatures, stamps or seals match their own records. If they do match, they will legalise the document by attaching a stamped official certificate, known as an apostille.
There are two types of apostille certificates, namely paper-based or an electronic certificate known as an e-Apostille. Either type of apostille ensures the use of that document when presenting it to any public official or overseas party of a signatory country.
What is certification?
Certification, or document certification, refers to any process required to certify or legalise a document for use overseas. In broad terms, having a document certified refers to the act of certifying that a particular document has been issued by an official authority in its country of origin, and that the document’s signature, stamp, or seal is genuine.
In the context of submitting documents for use anywhere outside of the country of issue, the term “certification” is synonymous with “legalisation,” where these are umbrella terms for different verification and authentication processes. Indeed, an apostille is both a form of certification and legalisation, although there are additional types of certification that may be required when using documents abroad, in addition to or instead of an apostille certificate.
What are the different types of certification?
There are several ways in which documents issued in the UK for use in foreign countries can be certified. Essentially, certification of a document can involve any process in which a stamp or certificate is obtained from the relevant officials. This can include apostille certification, embassy legalisation, and document notarisation.
Apostille certification
Apostille certification is available to a number of countries that are signatories to the Hague Convention of 1961. This international treaty allows for streamlined legalisation by way of a certified authentication issued by the FCDO, abolishing the lengthy requirements of embassy legalisation for foreign public documents to be used in signatory countries.
In this way, it may be possible to benefit from a single certification process when using documents in your destination country and other signatory countries. Under the 1961 Convention, rather than adopting a lengthy chain of certifications, which can be time consuming and costly, an apostille can be used to verify the authenticity of all kinds of public and official documentation for use in a participating country.
Embassy legalisation
The longer and far more complex way to certify a document is by way of embassy or consulate legalisation, typically involving a number of certification steps for non–apostille member countries. This is where documents from one country again need to be certified for use in another, but the destination country is not a signatory to the Hague Convention. As such, the simpler and singular process of an apostille certificate cannot be relied upon when presenting documents for use in any non-participating country.
It is not uncommon for some countries to use certain terms interchangeably, including “apostille certification” and “legalisation,” so you must ensure compliance with the correct regulatory rules for the destination country. In broad terms, embassy or consulate legalisation usually involves several steps. This will often include obtaining an apostille, but with other important processes that must be followed, such as notarisation prior to having documents apostilled, before seeking approval from the relevant consular officials.
Document notarisation
Notarisation is where a document is authenticated by a notary public. A notary public is an internationally recognised legal professional with the authority to certify the authenticity of certain documents, as well as signatures to those documents, primarily for use overseas.
The facts contained in any document bearing an impressed seal and notary’s signature will be treated as the evidence of a responsible legal officer, and will therefore be universally recognised and accepted. However, obtaining a notary stamp, together with a notary signature, may represent only the very first stage of a far lengthier certification or legalisation process, including apostille certification and/or embassy legalisation.
At Blair, we work closely with the FCDO, different embassies and consulates, as well as a whole network of notaries to obtain that all-important notary stamp as needed. As such, we can help with all your certification needs when it comes to international trade and commercial documentation, providing tailored advice based on your unique set of circumstances, from the documents needed to the different destination guidelines.
To get in touch, or to discuss your requirements, call our Sales Team on +44 (0) 1784 254123 or contact us online to learn more today.
Frequently Asked Questions (FAQs)
What is document certification?
Document certification can include a number of different processes, including the use of an apostille issued by a competent authority or the lengthier process of embassy legalisation. The latter can involve a sequence of different authentication steps for use of a document in any given foreign country.
What is the difference between apostille and certification?
Obtaining an apostille certificate and having a document certified are often one and the same, although certification is a much broader term, including other forms of verification and authentication in the context of validating documents for use abroad.
How do you get documents certified or apostilled?
In the UK, the way in which a document is certified will depend on the requirements of the destination country. This could involve multiple steps, although the FCDO is the competent authority for issuing apostille certificates before submitting documents for use abroad.
How can Blair help you with document certification?
Here at Blair, we work closely with the FCDO and various embassies and consulates to help meet our client’s documentation and certification needs, together with a network of notaries public for clients needing a certified copy of any document. We can also provide tailored advice on the different certification steps required for different destinations.
To discuss your document certification needs, and to find out more about how Blair can help you or your business, please telephone our Sales Team on +44 (0) 1784 254123 or contact us to learn more today.
Legal disclaimer
The matters contained within this article are intended to be for general information purposes only. This blog does not constitute legal advice, nor is it a complete or authoritative statement of the law in England and Wales and should not be treated as such. Whilst every effort is made to ensure that the information is correct, no warranty, either express or implied, is given as to the accuracy of the blog contents, and no liability is accepted for any errors or omissions. Before acting on any of the information contained herein, expert advice should be sought.