A French document intended for a foreign authority — or the reverse — often goes through three distinct steps that are easily confused.

Three procedures often confused

Sworn translation gives the document official value in the target language. It is produced by a translator registered on the list of a court of appeal.

The apostille certifies the authenticity of the signature on the document. It says nothing about its content.

Legalisation serves the same purpose as the apostille but follows a longer procedure, reserved for countries that are not party to the Hague Convention.

None replaces the others. The most common mistake is having a document translated before having it apostilled, or the reverse — the order changes depending on the country.

Apostille or legalisation: how to tell

The criterion is the Hague Convention of 5 October 1961. Contracting state: apostille, a simple procedure involving a single authority. Non-contracting state: legalisation, via the Ministry for Europe and Foreign Affairs and then the consulate of the destination country.

Some markers for the languages we handle. Russia, the United Kingdom, Morocco and Tunisia fall under the apostille. So does Saudi Arabia, since 7 December 2022. The United Arab Emirates, Qatar, Kuwait and Algeria, however, are not party to the Convention: consular legalisation remains mandatory.

Contrary to a widespread belief, a document intended for Dubai or Abu Dhabi therefore does not go through the apostille. These lists change: the reference is the official table published by the Hague Conference.

What changed in 2025

The apostille of French public documents now falls to the notarial profession rather than the general prosecutors' offices of the courts of appeal: since 1 May 2025 for the apostille, and since 1 September 2025 for legalisation.

Fifteen notarial centres are authorised to handle any document, with no territorial restriction: the division by court of appeal has ended. The procedure is largely digital. Legal basis: the Act of 23 March 2019, and the decree and order of 23 December 2024.

In which order

The order depends on what the receiving authority requires. In the most common case the apostille applies to the original document: you obtain a recent original, have it apostilled, then have the whole thing translated, apostille included.

Some countries require the reverse: the sworn translation is produced first, and it is the translator's signature that is then apostilled. Asking the receiving authority before starting avoids having to redo everything.

Documents concerned

The items most often requiring an apostille or legalisation: civil status records (birth, marriage, death), diplomas and transcripts, criminal record extracts, notarial deeds (power of attorney, attestation, title deed), company documents (registration extract, articles, powers) and court decisions.

Mistakes that cost time

Having a document translated when it is too old. Many authorities require a record less than three or six months old. A perfect translation of an expired record will be refused.

Translating before apostilling when the reverse order was required. The translation then has to be redone to include the apostille.

Using a translator who is not sworn. A free translation, however excellent, has no value before an authority.

Forgetting to translate the apostille itself. When it appears on the original document, it forms part of what must be translated.

Where sworn translation comes in

Our role concerns the translation, not the apostille or legalisation: those formalities fall to the notary, the ministry or the consulate.

We handle the translation itself, in Arabic, Russian, English and French, by translators registered with the Montpellier Court of Appeal — a registration that confers authority throughout France. And, beforehand, guidance on the order of the steps, to avoid incurring costs in the wrong direction.

If you are unsure which procedure applies to your file, tell us the destination country and the nature of the document.