The Hague Convention, legalisation, apostilles, notarisation, certification, certified translations
I've had a crazy few weeks with a big legal project and conferences abroad, so I’ve just managed to find some time to publish this post, clarifying the above words, for you.
Often my clients call me in relation to translation of official documents and the above terms come up during our conversation. From my customers’ questions, I understand that they often are confused as to what the differences between all these words are. And the truth is, they are very confusing as they are all very similar processes.
But, I am going to explain what the differences are in the simplest way possible. So, next time, when you find yourself having to deal with the bureaucracy of Greece or UK, you’ll know exactly what’s what! So, let’s start at the beginning!
The Hague Convention 15 October 1961
This is an international treaty which says that all the countries that have signed this treaty, will accept the foreign, public documents of all the other signatory countries without the need for legalisation. The list of countries that have entered The Hague Convention can be found here. And how is that possible? The answer is, with the Apostille stamp, which takes me to the next word.
The Apostille is the product of the legalisation process. It is a little piece of paper which is affixed to the back of your document. And what it does is, it identifies the person who signed your official document (let's say birth certificate) and attests their signature. Meaning, it says that person X is indeed the Registrar of the London City Council and this is indeed their signature. Once you have this on your public document, in theory, it should be accepted by any country that has entered The Hague Convention.
Is the process during which the above happens. An official looks at your document and confirms the signature of the person that signed it. It can be ordered online at https://www.gov.uk/get-document-legalised. You post your documents to the Legalisation Office, they legalise them, and they post them back to you. Note that UK’s public documents can be legalised in the UK, Greece’s public documents can be legalised in Greece, France's in France and so on. Meaning, you cannot use the above link to legalise a document that is not issued by a UK authority. You may, however, be able to go to the Consulate of your country and get a public document legalised there instead.
It is similar to legalisation, only the Notary Public, who is a qualified legal professional, does this for you, instead of you going online to do it. But it is not just that. Notarisation goes a step further. It also confirms who you are by you presenting your passport/ID to the Notary. The Notary then produces a statement confirming that you are the person that you say you are and that they have seen your documents and that they are originals or true copies. The Notary sings this statement and affixes their embossed seal on your document.
This is yet another process which confirms that a photocopy is faithful to its original document. This can be done by a solicitor or Public Notary or even the Post Office.
That’s what we call the statement that the translator produces stating that their translation is “true and accurate of the original document rendered to the best of their knowledge and ability”. This statement is issued by the translator who carried out the translation work. This translator is a qualified professional, often also registered with the respective Consulate, and with various professional bodies or associations. Not to be confused with ‘sworn translator’ which is a concept that exists in some European countries but not in the UK. A sworn translator is appointed by the Court of their country of origin or Ministry of Foreign Affairs. This concept does not exist in the UK.
And last but not least…legalisation of the translator's signature
This refers to the legalisation of the translator’s signature by the Greek Consulate. This takes place at the Greek Consulate where you present your original documents and the certified translations. The Consulate compares the translator's signature found on your translations against the one the Consulate keeps in their records. If the translator is indeed registered with the Consulate, then the Consulate legalises the translator's signature on the translation and stamp the translation with the Consulate's stamp.
Vasiliki is a translator, interpreter, transcreator, blogger, consultant and director of Greek to Me Translations Ltd. She works with English and Greek and specialises in legal, creative, and psychometrics. She is a Chartered Linguist, member of CIoL, ITI and PEM and she is registered with the Greek Consulate as a certified translator and interpreter. She holds a BA in English and Masters in Business Translation and Interpreting. She is a Steering Group Member of the CIOL Translating Division and CIOL Business, Professions and Government Division. She is an Associate Lecturer in Legal Translation at London Metropolitan University, a public speaker and writer for industry magazines. Her mission is to help you achieve your goals through the power of words. You can follow her on LinkedIn, Facebook, Twitter and Instagram.