These terms all relate to making documents legally valid for use in another country but represent different steps and processes. Here’s a concise summary followed by a more detailed explanation:

  • Notarisation: A UK Notary Public (or Solicitor) verifies someone’s identity and witnesses their signature on a document. This is often the first
  • Authentication: A general term for verifying that a document and its signatures/seals are genuine.
  • Apostille: A specific type of authentication used only between countries that are part of the Hague Apostille Convention.
  • Legalisation is a more complex authentication process used for countries not part of the Hague Apostille Convention. It involves the UK FCDO and the foreign country’s embassy/consulate.

Detailed explanation:

Notarisation: Notarisation involves a Notary Public officially witnessing a signature on a document, verifying the signer’s identity, and adding their own signature and official seal.

For other documents, like a Power of Attorney, Affidavit, or Statements, the Notary will confirm the identity and witness the signing of the documents.  

Authentication: Authentication is a general term referring to the process of verifying that something is genuine. In the context of documents, it means confirming that the document’s signatures, seals, or stamps are legitimate.

Both apostille and legalisation are specific types of authentication used to make documents valid internationally. The process of authentication can vary depending on the specific situation.

Apostille: An apostille is a certificate issued by the UK FCDO under the Hague Apostille Convention. Its purpose is to verify the signature or seal of a UK public official on a document so it can be used in other countries that are also part of the Hague Convention.

The FCDO checks the signature or seal and then attaches the apostille certificate. It’s important to remember that an apostille is only valid for use between member countries of the Hague Convention.

For example, an apostille is required for a UK birth certificate that needs to be used in Spain (another Hague Convention country). 

Legalisation (Consular Legalisation): Legalisation is a more involved process used to verify a document’s authenticity for use in a foreign country that is not a member of the Hague Apostille Convention.

It makes a UK document legally recognised in that other country. The process typically involves several steps: first, the document might need certification by a UK solicitor or notary public; then, it’s sent to the UK FCDO for verification; and finally, it’s presented to the embassy or consulate of the destination country in the UK for their authentication.

For instance, a UK-issued power of attorney or educational degree intended for use in the UAE requires legalisation.

In summary, notarisation verifies a signature. Authentication is the general process of proving a document is genuine. Apostille is a specific type of authentication for Hague Convention countries, and legalisation is a more complex authentication for non-Hague countries.