How does an apostille differ from legalisation?

An apostille is a simplified authentication of a document by a single stamp, valid between countries party to the 1961 Hague Convention. Consular legalisation is a lengthy chain of certifications through ministries and a consulate, used when the destination country is not party to the Convention. The choice is not yours to make — it depends on whether both countries are members of the Convention, and one cannot substitute for the other.

Will a standard stamped translation from a bureau work?

As a rule, no. Visa and residence permit applications require a sworn (official) translation — done by a translator accredited by the ministry of the destination country. In Spain this is a traductor jurado; other countries have their own equivalents. An ordinary translation with a translation agency stamp is rejected in most cases, and the entire package has to be reassembled.

Where to get an apostille — in your home country or in the destination country?

Always in the country that issued the document. An apostille on a Russian birth certificate is obtained in Russia; on a Spanish certificate — in Spain. The competent authority depends on the document type: it differs for educational documents, civil registry records and criminal record certificates.

SVOY LEGAL/Documents

Practice area · Documents

Apostille, legalisation, certified translation

A good venture most often falls apart not at the foundation, but on paper, certified by the wrong method. We will explain what needs to be certified and how.

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In brief: apostille is affixed in the country that issued the document, and it works only between countries that are party to the Hague Convention. If the destination country not a party to the convention — consular legalisation is required, which is a different procedure and other timelines. A certified translation is required almost everywhere: a standard bureau with a stamp won’t do.

What we we do

Separately or as a package — together with your visa application.

Apostille

A stamp by which a country confirms the authenticity of its own document for all signatories to the Hague Convention. It is affixed in the country that issued the document — not the country you are travelling to. It does not last indefinitely: certificates have their own validity period.

Hague Convention
In the issuing country

Consular legalisation

A lengthier procedure for countries outside the convention: a chain of certifications through ministries and the consulate of the destination country. Takes weeks, not days, and cannot be replaced by an apostille.

Outside the convention
Weeks

Certified translation

A translation accepted by the country’s authorities is made by a translator accredited by its ministry (traductor jurado in Spain and equivalents elsewhere). An ordinary translation agency with a stamp will not do — this is the most common and most frustrating rework people face.

Certified translator
Not a bureau

Criminal record certificate

Required for almost any long-term status. The apostille matters, but so does timing: many countries only accept a certificate issued within the past three months of the application date.

3-month period
Apostille is required

Degree recognition

A separate procedure (homologación, nostrification). Required for working in regulated professions and for admission to higher education. It runs in parallel with the visa process and takes several months.

For work and study
Months

Children’s documents

Birth certificate, second parent’s consent to travel, custody documents. This is where mismatches in the spelling of names across different documents most often come up — and that can bring the whole case to a standstill.

Transliteration
Parental consent

Three mistakes that cost months

Translation by the wrong translator

Two months collecting documents, translation done at the local bureau — and that was that returns. Sworn translators are booked in advance — they have waiting lists.

The certificate expired while waiting in the queue

The criminal record certificate was obtained in March, the application was submitted in July — and by then it are accepted within three months. The correct procedure matters more than speed.

Names are spelled differently

One transliteration in the international passport, a different one in the marriage certificate. To the authority these are two different people, and the case stalls.

Complete list: what is usually required to be legalised

The required documents depend on the grounds, but the set of documents that go through through legalisation and translation, almost always the same:

Document	What is done with it	What to look for
Criminal record certificate	Apostille or legalisation + certified translation	Validity period — often three months from the date of submission
Birth certificate	Apostille or legalisation + certified translation	Names must match the passport
Marriage or divorce certificate	Apostille or legalisation + certified translation	For divorce — entry into force of the decision
School-leaving certificate and transcript	Apostille + translation, sometimes nostrification	A transcript is almost always required
University degree and transcript	Apostille + translation; for work purposes — nostrification	Regulated professions = mandatory recognition
Medical certificate	Translation, and sometimes legalisation	The wording must meet the requirements of the destination country
Consent for the child to travel, guardianship documents	Notarised + apostille + translation	Valid for a limited time
Powers of attorney	Notarised + apostille + translation	A power of attorney scoped to a specific action
Income statements, bank statements, tax returns	Translation, and sometimes legalisation	A history matters, not just a balance

Apostille or consular legalisation

These are not two ways of doing the same thing — the choice has already been made for you whether both countries are party to the 1961 Hague Convention.

	Apostille	Consular legalisation
When it applies	Both countries are in the Hague Convention	At least one country outside the convention
What it looks like	A single stamp or app in the prescribed form	The legalisation chain: notary → ministries → consulate
Where it is done	In the country that issued the document	In the issuing country, with the final step at the consulate of the destination country
How long it takes	Usually days or weeks	Usually weeks, sometimes longer
Can one replace the other?	No. This is determined by the convention, not by convenience.

How to check what you needTwo questions: which country issued the document and to which country you are you are submitting. If both countries are in the convention — apostille. If not — legalisation. The competent authority for an apostille depends on the type of document: for documents from civil registry offices, educational institutions, and criminal record certificates varies.

Nostrification: recognition of qualifications

An apostille confirms that a document is genuine. It does not confirm that your degree is equivalent to a local one — that is a separate recognition procedure (nostrification, homologación, equivalencia).

For enrollment recognition of the previous status is usually required educational level: school-leaving certificate for a bachelor’s degree, a diploma for master’s programme. The procedure runs in parallel with the document submission, and its timeline does not align with the admissions cycle — you need to start well in advance.
For work in a regulated profession — doctor, lawyer, engineer, teacher, architect — recognition is mandatory, and often requires additional exams or practical training. Without it, working in specialisation is not allowed, even with a work residence permit.
For all other professions formal recognition is often not required at all: a diploma with translation is sufficient for the employer. It is worth clarifying this before starting a lengthy procedure.

About timelines and requirements by countryWhat exactly is accepted, which authority issues the apostille, and whether one is required diploma recognition — determined by the country of application and document type, and rules change. We do not publish a country-by-country table precisely because it goes out of date faster than it can be read: let us tell you personally of documents and country.

For Spain, individual steps can already be ordered at a fixed price — apostille, criminal record certificates, duplicate documents.

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