Sworn translation, notary certification and apostille: which applies when?

These three terms are often used interchangeably in everyday conversation. Knowing the difference is not a matter of terminology alone: both an unnecessary expense and an application rejected for missing paperwork arise from the same confusion.

Sworn translation

A translator who has taken an oath before a notary declares the translation with their own signature and seal. Many institutions accept a document in this form alone and ask for no further certification.

Notary certification

This is a separate step carried out at a notary office. The notary certifies the sworn translator’s signature rather than the content of the translation. Accuracy remains the translator’s responsibility.

Apostille

An apostille is a certificate issued by a competent authority so that a public document is recognised in another country, and it comes after notary certification. In Türkiye, which authority issues it depends on the type of document.

There has been a significant change on the Chinese side: China became a party to the Hague Apostille Convention on 7 November 2023. Public documents issued in China after that date may take the apostille route instead of the consular legalisation that was previously required. Practice varies between institutions, so the current requirement should be confirmed each time with the party requesting the document.

The order to follow in practice

1. 1Ask the requesting institution exactly what is required.
2. 2Get the answer in writing; verbal information changes over time.
3. 3Have the translation prepared.
4. 4Obtain notary certification if required.
5. 5Obtain an apostille from the competent authority if required.

Skipping a step is costly. A certification obtained unnecessarily cannot be undone; one that was needed but not obtained means the application is rejected and the process starts again.

Within the consultancy scope, the work consists of clarifying the required procedure with the relevant institution, preparing the document set in full and following the process on behalf of the company. Certification and apostille themselves are carried out by the relevant public authorities.