Apostille, legalisation and certified translation
Apostille, legalisation and certified translation form a chain, not a single step. Each stage certifies the one before it, not the content of the underlying registry document. A closing date leaves no margin for a step attached out of order. This page sets out the order, the limit of each stage and where the chain lengthens.
The order of the chain
The chain has three links, and each depends on the one below it. Link one is the underlying registry document: a certified extract, a certificate of good standing, a register entry. Link two is the certification step – an apostille where the receiving state is a party to the Hague Apostille Convention, or a legalisation stamp where it is not. Link three is the certified translation, added after certification, not before.
- The registry document is issued first, by the register or the authority that holds the record.
- The apostille or legalisation attaches to the signature and seal on that document, not to a translation of it.
- The certified translation is produced once the certified original exists, and it is usually bound to that original.
Reversing link two and link three is the most common fault in a chain assembled by a reader working alone. A translation prepared first has nothing on it for the apostille to certify, because the signature the apostille checks belongs to the issuing officer, not the translator. Where a jurisdiction inserts a fourth link – an embassy stamp after a ministry stamp, for example – the order still runs upward from the original document, never from the translation.
Compliance teams ordering a document that will sit inside a completion set – company records, a public register extract, a certified extract from a land register – meet this chain most often at the last stage of a transaction, when a closing date is already fixed. A chain started early leaves time to correct a link that returns to the wrong office; one started late does not.
The three links rarely compress into a single office visit; the underlying registry document is usually obtained separately, and the whole chain is timed from that first step, not from the certification step.
What an apostille does not certify
An apostille certifies the signature, the seal and the capacity of the officer who signed the underlying document. It does not certify that the content of the document is accurate, that the entity described in it is solvent, or that the record has not changed since the date of issue.
Legalisation performs the same narrow function through a different channel: a consular officer confirms the signature and seal of the authority before it, not the facts stated inside. Where a certified translation is added afterwards, the translator's certification covers the accuracy of the translation against the certified original, not the accuracy of the original itself.
A chain that is complete – original, apostille, translation – confirms that each link is what it claims to be. It does not confirm that the underlying registry document still reflects the current position of the entity named in it. Under the law in force in the receiving jurisdiction, a receiving party may ask for a document dated close to the transaction for that reason, not because the certification has expired.
Where the chain lengthens
The chain lengthens in three places. The first is jurisdictional: a state that is not a party to the Hague Apostille Convention replaces the single apostille step with a legalisation sequence that can run through a ministry of foreign affairs and then an embassy or consulate, adding a link the reader may not expect.
The second is the translation requirement itself. Some receiving jurisdictions accept a translation certified by any recognised translator; others require the translation to be produced by a sworn translator registered in that jurisdiction, or notarised separately after certification. Where the requirement is the stricter one, the certified translation becomes its own sub-chain, with its own signature for the apostille or legalisation to certify.
The third is re-certification. Where a document is translated and then needs a further stamp – because the receiving authority wants the apostille to cover the translation as well as the original – the chain effectively runs twice: once for the original, once for the bound translation. This is more common with register of directors extracts and land register entries than with a short certificate, because the receiving party often wants the annexed translation covered on its own signature page.
Where the chain runs through a licensed registered agent in the jurisdiction rather than directly through the register, an additional confirmation step is usually inserted before the certification stage, to confirm the extract is current before it is certified.
Reuse terms vary too: a certified copy issued for one recipient does not always extend to a second.
Where the chain breaks
The chain breaks most often at the join between certification and translation. A translation bound to the wrong page, or produced from an uncertified copy of the document rather than the certified original, is rejected on arrival, not on inspection at this end.
It breaks a second way when the certification is obtained for the wrong receiving jurisdiction – an apostille where the receiving state required legalisation, or the reverse. The stamp is valid on its face; it is simply the wrong stamp for that destination.
A third failure is timing. Where a closing date sits close to the order date, a chain that runs through more than one office has no slack for a rejected link to be corrected and resubmitted. Building the chain from the first link, well before the date it is needed, removes this failure without changing any step in it.
A fourth is scope: an apostille or legalisation obtained for one document in a set does not extend to a second document added later, even where both accompany the same filing.
How the chain is assembled
The issuing authority for the underlying registry document differs by jurisdiction and document family: a companies register, a court, a chamber of commerce, or a land register office. The apostille or legalisation stamp comes from a separate authority – typically a ministry of foreign affairs, a court, or an embassy for legalisation. Certified translation is usually supplied by a sworn or recognised translator, engaged after certification. A foreign applicant generally routes through a licensed registered agent in the jurisdiction rather than direct correspondence with the authority. Reuse terms are set by the receiving jurisdiction, not by REGISTRUM.
What does REGISTRUM cover?
REGISTRUM covers the route from a public register to a certified, translated document: which authority issues the underlying registry document, how it is certified for use abroad, and where a certified translation is added to the chain. The reference layer sets out the general order of these steps for registry documents across jurisdictions.
How current is this information?
The order of the chain – original document, then certification, then translation – is structural and does not change with a jurisdiction's fee schedule. Authority names, fees and turnaround times specific to a jurisdiction are confirmed against the primary source when an order is placed.
Can a document be obtained from any jurisdiction?
No. Some registers restrict access to a foreign applicant, some documents cannot be obtained through a public register at all, and some jurisdictions place the certification step outside REGISTRUM's reach. Where a document or a certification cannot be obtained, that is stated before an order is accepted, not after payment.
Does an apostille expire?
An apostille itself does not carry an expiry date; it certifies the signature and seal at the date it was issued. A receiving party may still ask for the underlying registry document to be dated close to the transaction, because the apostille does not confirm that the record's content is still current.
State the entity, the jurisdiction and the date you need it by; we confirm availability and the fee before you pay. If the document does not exist in this jurisdiction or cannot be obtained for you, we say so before you pay and we do not take the order.
REGISTRUM obtains and delivers official records issued by public registers and licensed registered agents. This page describes what those records contain and how they are obtained. It is not advice on the legal effect of any record. To order, write to info@registrumfirm.com.