What is an apostille?
An apostille is an administrative certification affixed to an official document — not a translation. It attests to the authenticity of the signature and seal of a public authority (notary, court clerk, préfecture, etc.). This procedure is governed by the Hague Convention of 5 October 1961, to which more than 120 countries are party.
In France, since 1 May 2025, apostille formalities are handled by the notarial profession (service-public.fr). Consular legalization also falls under notarial jurisdiction since 1 September 2025.
Apostilles apply only to documents intended for a foreign authority. Eligible documents include: civil status certificates (birth, marriage, death), notarial deeds (powers of attorney, wills, affidavits…), court documents (judgments, criminal record extracts…), administrative documents (diplomas, tax assessments, academic transcripts…) and commercial documents (Kbis company extracts, commercial contracts, assignments…).
What is a certified translation?
A certified translation is a translation produced by a sworn translator — listed as a judicial expert appointed by a French Court of Appeal — who certifies by their signature and official seal that the translation is faithful and complete with respect to the original document. It enables an administration to understand and rely on a document written in a foreign language.
The two procedures are independent
An apostille and a certified translation serve two different purposes:
- The apostille authenticates the origin of an official document
- The certified translation ensures its comprehension in another language
A document may require one, the other, or both, depending on the requirements of the receiving authority.
| Apostille | Certified translation | |
|---|---|---|
| Purpose | Authenticate the origin of the source document | Faithfully translate the content |
| Issued by | The notarial profession (since May 2025) | A sworn translator appointed by a Court of Appeal |
| Applies to | Official documents between countries party to the Hague Convention | Any document written in a foreign language |
| Result | A stamp or certificate added to the document | A translated document bearing the translator's signature and seal |
When are both required?
Certain procedures require both an apostille on the original document and a certified translation of it. This is common for international marriage files, cross-border estate proceedings, or judicial procedures involving multiple countries. In such cases, the apostille must be obtained on the original first, then the entire document — apostille included — must be translated by a sworn translator.
This is notably the case for foreign criminal record certificates (US FBI Identity History Summary, UK ACRO certificate…), which must be apostilled or legalised by the issuing country's authority before translation, for use in a French naturalization or talent passport application.