Key takeaways
- A sworn translation is a translation that the receiving country treats as official because a state-authorised translator, or a court or notary, has certified it.
- Spain's sworn translators are appointed by the Ministry of Foreign Affairs, European Union and Cooperation and certify translations with their signature and seal.
- In Italy, a translation has no legal value for official use unless it is sworn before a court or a notary, according to the Italian Consulate General in London.
- France uses translators registered as judicial experts with the courts of appeal or the Cour de cassation, and Germany uses translators authorised or sworn under state law.
- Poland's sworn translators are entered on a Ministry of Justice list and certify with an official seal, while Romanian authorised translators are listed in a Ministry of Justice database.
If you are sending a UK birth certificate to a registry in Madrid for a wedding abroad, a company extract to a notary in Milan, or a degree certificate to an employer in Warsaw, you will probably be told it needs a "sworn translation". The term covers several different national systems, and a translation that is official in one country may carry no weight in the next.
This article compares the six systems UK clients meet most often in continental Europe. It explains who appoints the translators, how a translation is certified, and where to check a translator's status. It sits within our guide to apostille and translation for UK documents used abroad.
What is a sworn translator?
A sworn translator is a translator whom a state has authorised to certify that a translation is accurate, so that courts and public bodies can rely on it without further checks. The authorisation usually comes from a ministry or a court, and the translator signs and seals each translation.
The UK has no equivalent public office. A UK certified translation is a translation that the translator or agency confirms in writing is a "true and accurate translation of the original document", in the wording GOV.UK suggests. That is enough for many UK bodies, but civil-law countries often expect their own sworn format instead. Our article on certified vs notarised vs sworn translation explains the UK side in more detail.
How do sworn translation systems compare across six countries?
All six countries have an official route, but the authority behind it differs. The table summarises the main features.
| Country | Local term | Who authorises or lists them | How the translation is certified | Official register |
|---|---|---|---|---|
| Spain | Traductor/a jurado/a | Ministry of Foreign Affairs, European Union and Cooperation (MAEC) | Translator's signature and seal, using the ministry's wording | MAEC list of sworn translators and interpreters |
| Italy | Traduzione giurata or asseverata | Lists of sworn translators held by Italian courts | Translation sworn before a court, a notary or (per the London consulate) a municipality | Court lists |
| France | Traducteur agréé (expert traducteur) | Courts of appeal and the Cour de cassation | Translator registered as a judicial expert certifies the translation | Court of appeal and Cour de cassation lists |
| Germany | Ermächtigter or beeidigter Übersetzer | The justice administrations of the federal states (Länder) | Translator's certificate of accuracy and completeness, signed and dated | Joint federal-state database of interpreters and translators |
| Poland | Tłumacz przysięgły | Minister of Justice | Seal showing name, language and list number; qualified e-signature for electronic translations | Ministry of Justice list of sworn translators |
| Romania | Traducător autorizat | Ministry of Justice | Translator signs the certification; a notary may then legalise the signature | Ministry of Justice database |
What are the rules in each country?
Each country's system has its own legal basis and practical quirks. The summaries below link to the official source for each.
Spain: traductor jurado
Spain's sworn translators hold a title granted through the Language Interpretation Office of the Ministry of Foreign Affairs, European Union and Cooperation, under Royal Decree 724/2020. The ministry states that their translations "tendrán carácter oficial, pudiendo ser aportadas ante los órganos judiciales y administrativos", meaning they have official status before courts and administrative bodies.
The same page says sworn translators "certificarán con su firma y sello la fidelidad y exactitud de sus actuaciones", certifying accuracy with their signature and seal. The ministry publishes a list of all appointed sworn translators by language, and the Spanish Consulate General in London points applicants to translators "reconocido por el Ministerio".
Italy: traduzione giurata (asseverazione)
Italy's approach centres on the act of swearing rather than a single national title. The Italian Consulate General in London says that for British documents translated into Italian, lists of sworn translators are available at Italian courts, and that the translation "has no legal value unless it is sworn before a Court or a notary" (Consolato Generale d'Italia Londra).
The consulate also lists a second option: having an existing translation sworn before an Italian court, an Italian municipality or a notary. The London consulate does not translate documents and certifies translations only in two narrow cases, so most UK senders arrange the sworn translation in Italy.
France: traducteur agréé
In France, an official translation is made by a traducteur agréé, defined by Service-Public.fr as an "expert judiciaire inscrit sur les listes établies par les cours d'appel et la Cour de cassation". These are often called experts près la cour d'appel.
For translations made abroad, Service-Public.fr says the list of translators approved by local authorities is available on the French consulate's website, and that "La signature du traducteur devra être certifiée matériellement par le consulat". Check with the French authority whether it wants a translator on a French court list or one approved by the consulate.
Germany: ermächtigte and beeidigte Übersetzer
Germany authorises translators at federal-state level, so the title varies: ermächtigt (authorised), beeidigt (sworn) or öffentlich bestellt (publicly appointed). The state justice administrations run a shared search platform, the Dolmetscher- und Übersetzerdatenbank, and court interpreters have been governed by a federal Court Interpreters Act since 1 January 2023.
The legal weight of such a translation is clear in civil procedure. Section 142(3) of the Code of Civil Procedure (ZPO) provides: "Eine solche Übersetzung gilt als richtig und vollständig, wenn dies von dem Übersetzer bescheinigt wird." A translation by an authorised translator is presumed correct and complete once the translator certifies it, although a party may still prove otherwise.
Poland: tłumacz przysięgły
Polish sworn translators are regulated by the Act of 25 November 2004 on the Profession of Sworn Translator and entered on a list kept by the Minister of Justice. Under Article 13 they may make and certify translations, and also check and certify translations made by other people.
Article 18 requires a seal showing the translator's name, the language and their position on the list. A Polish sworn translator may also certify a translation in electronic form with a qualified electronic signature, which helps when the original carries an e-Apostille.
Romania: traducător autorizat
Romania's authorised translators are listed in a database owned and maintained by the Romanian Ministry of Justice. According to the European e-Justice Portal, "Law No 178/1997 regulates the authorisation and payment of interpreters and translators", who work for courts, prosecutors, notaries, lawyers and bailiffs, among others.
The public can search the database free of charge by name, language, authorisation number and telephone number. When a notary is involved, the Romanian notaries' law provides that the authorised translator signs the certification and the notary legalises the translator's signature (Law 36/1995, Article 152). This is often called a traducere legalizată.
How do I use a sworn translator when I am in the UK?
The process is similar for all six countries. Follow these steps:
- Get the original document apostilled first if the receiving authority requires it, so the sworn translator can include the apostille. See whether to translate before or after the apostille.
- Ask the receiving authority which translator it accepts: a sworn translator in its own country, a translator approved by its consulate in the UK, or a notarised UK translation.
- Find the translator in the official register listed in the table above and confirm the language pair.
- Ask how the translator needs the original: paper by post, a scan, or an e-Apostille PDF.
- Agree the spelling of names and how dates, addresses and qualifications should appear, so they match other documents in your file.
- Check the result for the seal, signature and certification wording before submitting it.
Common mistakes with sworn translations
- Assuming one country's sworn translation works in another. A Spanish sworn translation is made for Spanish authorities; check before reusing it in France or Italy.
- Translating the document before it is apostilled. If the apostille must also be translated, you may pay twice.
- Using a translator whose authorisation has lapsed or covers another language. Check the official register, not just the translator's website.
- Ignoring regional differences. In Germany authorisation is granted by the federal states, and in Spain individual registries can ask for different documents.
- Expecting a sworn translator to stamp an unchecked draft. Sworn translators certify accuracy under their own name, so expect them to review or retranslate any draft you supply, including machine translations.
How TranslationWorks can help
TranslationWorks is a UK-based translation agency that provides professional human translation by native-speaking linguists in 150+ languages, with dedicated pages for Spanish, Italian, French, German, Polish and Romanian translation. Sworn translations are made by translators authorised in each country. We can translate documents for review, for UK use or for authorities that accept a professional translation, through our legal translation work. 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.
