Why do apostilles from different countries look different?

You might notice that an apostille obtained from the UK’s FCDO looks quite different from one issued in Spain, the USA, or another Hague Convention member state, even though they all serve the same purpose.

While the Hague Apostille Convention did introduce standardisation, this applied primarily to the apostille’s function and the essential information it must contain, not necessarily to its exact physical appearance across all member countries.

Think of it like passports – countries agree on the purpose and required data fields (name, DOB, photo, passport number, expiry, etc.). Still, the actual passport booklet’s design, colour, and layout vary significantly. Apostilles are similar.

Every apostille, no matter which member country issues it, must include the following standard elements to be valid under the Convention:

1. The title: It must always be headed “Apostille” and include the French reference “(Convention de La Haye du 5 octobre 1961).”
2. A numbered list of 10 information Points: These points clearly state specific details about the document’s origin, including the signatory’s name and capacity, seal details (if any), location and date of issue, the issuing authority, a unique number, and the authority’s seal and signature. (These points confirm the origin, but remember, as we explain in FAQ, does an apostille guarantee content validity? It doesn’t validate the document’s content.)

This standard information ensures that officials in any member country can easily understand what is being certified.

The visual differences you see arise because the Convention allows flexibility between countries in several areas:

• Layout & design: The physical size of the certificate, font choices, borders, the exact placement of the 10 points (though usually numbered 1-10), and the use of national crests or emblems are not rigidly dictated, allowing each country some design freedom.

• Language: As discussed in the FAQ, does the Hague Convention specify language? While the heading must be French, the main details can be provided in the issuing country’s official language. Many countries also include key terms in English or French alongside their local language, but the primary language used will differ. This is a major source of visual variation.

• Attachment method: How the apostille is affixed can vary internationally. Some use glue or staples for a separate certificate page, others use traditional ribbons and wax/embossed seals, and some older practices even involved stamping directly onto the document.

• Issuing authority seal/stamp: The official seal identifying the specific Competent Authority (see FAQ on who issues apostilles) will naturally look different for each country (e.g., the UK FCDO’s seal vs. a Spanish Ministry’s seal).

• Security features: Different countries may incorporate varying security features like specific paper types, watermarks, or holograms.

• Format (paper vs. electronic): The most significant modern difference is traditional paper apostilles and digital e-apostilles (PDFs). The adoption and format of e-apostilles vary depending on the country’s implementation of the e-APP (see FAQs regarding e-apostilles and the e-APP).

So, while the core information and legal function under the Hague Convention are uniform, the presentation is not.

As a London-based agency handling international documents daily, we are familiar with these variations and focus on ensuring the apostilles we obtain for UK documents via our express apostille service contain all the essential elements required for acceptance by other Hague Convention members.