Key takeaways
- An apostille is a single certificate, issued in the UK by the FCDO Legalisation Office, that confirms the signature, seal or stamp on a UK public document is genuine.
- An apostille is only enough when both the UK and the destination country are parties to the 1961 Hague Apostille Convention, which has 130 Contracting Parties.
- Countries outside the Convention usually require a chain of authentications: the UK apostille, then the destination country's embassy, and sometimes its foreign ministry.
- Neither an apostille nor legalisation certifies the content of a document or its translation, so translation requirements must be checked separately.
- The standard UK paper apostille costs £45 per document and usually takes up to 25 working days, plus courier or postage time.
If a bank, registry, university or court abroad has asked for your UK document to be "apostilled" or "legalised", you are dealing with the same underlying question: how does a foreign official know that a British signature or seal is genuine? The answer depends on whether the country you are sending the document to has signed the Hague Apostille Convention.
This article is for individuals and businesses sending UK documents overseas. It explains what each formality is, compares them side by side, shows how to check which one your destination accepts, and covers where translation fits in. For the full process from document to translation, see our guide to apostille and translation for UK documents used abroad.
What is an apostille?
An apostille is a standard certificate, attached to a public document, that confirms the origin of the signature, seal or stamp on it. In the UK, apostilles are issued by the Legalisation Office of the Foreign, Commonwealth and Development Office (FCDO).
GOV.UK describes the check in plain terms: "The Legalisation Office will check the document and see if any signatures, stamps or seals match their own records." If they match, the office attaches the apostille, either as a paper certificate or as an electronic e-Apostille.
The apostille exists because of the Hague Apostille Convention of 5 October 1961. Article 3 of the Convention makes the apostille the only formality a member country may demand to authenticate a public document from another member country.
What is legalisation, and how is it different from an apostille?
Legalisation (often called embassy or consular legalisation) is the older, multi-step way of authenticating a document for use abroad. The Convention itself defines it in Article 2:
"legalisation means only the formality by which the diplomatic or consular agents of the country in which the document has to be produced certify the authenticity of the signature, the capacity in which the person signing the document has acted and, where appropriate, the identity of the seal or stamp which it bears." (Hague Apostille Convention, Article 2)
In practice, legalisation is a chain. Each official authenticates the signature of the one before. The Hague Conference on Private International Law (HCCH) notes in its guide, The ABCs of Apostilles, that because so many authorities are involved, "the legalisation process is frequently slow, cumbersome and costly".
For a UK document, the chain usually starts with the FCDO apostille anyway. GOV.UK's guidance for Qatar, for example, sets out three steps: legalisation by the UK Legalisation Office, then by the Qatar Embassy in London, then attestation by the Ministry of Foreign Affairs in Qatar.
Apostille vs legalisation: what are the differences?
The main difference is the number of steps. An apostille is one certificate from one UK authority, while legalisation adds at least one foreign authority after it.
| Feature | Apostille | Embassy legalisation |
|---|---|---|
| When it applies | Destination country is a party to the 1961 Apostille Convention | Destination country is not a party, or the Convention does not operate between it and the UK |
| Who issues it in the UK | FCDO Legalisation Office only | FCDO Legalisation Office first, then the destination country's embassy or consulate |
| Further steps abroad | None needed to prove the signature is genuine | Often attestation by the destination country's foreign ministry |
| UK fee | £45 standard paper, £35 e-Apostille | FCDO fee plus the embassy's own fee, which each embassy sets |
| Electronic option | e-Apostille available for many documents | Depends on the embassy, so check before applying |
| What it proves | Origin of the signature, seal or stamp, not the content | Same, repeated at each step |
How do I check whether a country accepts an apostille?
Check the HCCH status table for the Apostille Convention. The status table lists every Contracting Party, and the HCCH states that the Convention has 130 of them.
When you read the table, look for three things:
- Both countries must be listed. The UK has been a party since 24 January 1965, so the question is whether your destination is listed.
- Check the entry-into-force date. A country that has signed but whose entry into force is still in the future does not yet accept apostilles.
- Check for objections. Under Article 12, an accession only takes effect between the acceding state and the states that did not object. Some accessions, such as China's, are flagged in the table with an objection, so read the linked notes.
Countries such as Spain, Italy, France, Germany, Poland and Romania have accepted apostilles for decades. Qatar and the United Arab Emirates, by contrast, do not appear in the table, and GOV.UK's Qatar guidance shows the multi-step process that follows.
If the destination is not a Convention country
Contact the embassy or consulate of the destination country in the UK. The HCCH advises exactly this for non-member countries, as its Permanent Bureau does not help with individual cases. Ask the embassy for its current fee, opening hours, and whether it needs the original or a notarised copy.
Which UK documents can be apostilled?
The FCDO can apostille UK documents that carry the signature or seal of a public official it can verify. According to GOV.UK, these include documents issued by a court with a wet ink seal, a public registry (such as birth, marriage and death certificates, or Companies House certificates), a government department, or a registered doctor.
Private documents, such as contracts, powers of attorney, qualification certificates and copies of passports, can also be apostilled once a UK notary or solicitor has certified them. The apostille then authenticates the notary's or solicitor's signature, not the private document itself.
GOV.UK is also clear about one limit: "You cannot get documents issued outside the UK legalised using this service." A foreign document must be apostilled in the country that issued it, which we cover in using foreign documents in the UK.
Does a translation need an apostille or legalisation too?
A translation needs its own authentication only if the receiving authority asks for it. An apostille on the original document says nothing about the translation, because, in the HCCH's words, "An Apostille does not certify the content of the public document to which it relates."
Many European authorities want a translation by their own sworn translator instead of an apostilled UK translation. Others accept a UK translation that a notary has certified and the FCDO has apostilled. Our article on whether to translate before or after the apostille sets out both routes, and our comparison of sworn translators in six European countries explains the local rules.
How much do apostilles and legalisation cost, and how long do they take?
The FCDO apostille is charged per document, and embassy fees come on top where legalisation is needed. The GOV.UK fee table lists four UK options:
- Standard paper apostille: £45 per document, usually up to 25 working days, plus courier or postage costs.
- e-Apostille: £35 per document, up to 2 working days.
- Next-Day paper service: £40 per document, for registered businesses only.
- Restricted Urgent paper service: £100 per document, same day, for registered businesses only and pre-approved by email.
Fees are not refunded if a document cannot be legalised. For embassy legalisation, each embassy sets its own fees and processing times, so budget extra time for the second and third steps of the chain.
Common mistakes when choosing between an apostille and legalisation
- Assuming every country accepts apostilles. Check the status table before you pay, especially for Gulf states.
- Apostilling a plain photocopy. The FCDO cannot verify a signature on an uncertified copy. Get the copy certified by a UK notary or solicitor first.
- Using an old certificate. Some authorities want documents issued within the last three or six months. Order a fresh certificate before legalising it.
- Forgetting the translation step. An apostille does not make a document understandable abroad. Ask early whether a local sworn translation is required.
- Choosing an e-Apostille without checking. Birth, marriage and death certificates, and police certificates, cannot get an e-Apostille, and some recipients still want paper.
How TranslationWorks can help
TranslationWorks is a UK-based translation agency that provides professional human translation of personal, legal and corporate documents by native-speaking linguists in 150+ languages. Apostilles and embassy legalisation are issued by the FCDO and the relevant embassy; we translate the documents you are sending abroad, from certificates to company records. Our legal translation work covers certificates, contracts, powers of attorney and company records, and we have dedicated language pages for Spanish, Italian, German, French, Polish and Romanian, among others. Tell us where the translation will be submitted and what format the authority requires, and we will confirm what we can provide in your free quote.
