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, the apostille is issued by the public prosecutor (procureur de la République) at the competent judicial court, or by certain ministerial departments depending on the nature of the document. It applies only to official documents (notarial deeds, judgments, civil status certificates) intended for use in a foreign country that is a party to the Convention.
What is a certified translation?
A certified translation is a translation produced by a sworn translator — listed as a judicial expert at a French Court of Appeal — who certifies by their signature and official stamp 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 | A public authority (public prosecutor, ministry) | A sworn translator at 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 signed and stamped translated document |
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.