The Hague Convention doesn’t mandate one single language for the entire apostille certificate, aiming instead for a balance between local language use and international comprehension. It sets specific guidelines:
- Mandatory French heading: The Convention requires the title to always be in French: “Apostille (Convention de La Haye du 5 Octobre 1961).” This exact heading is on all official apostilles from member countries.
- Primary content language: The central operative part of the certificate (the numbered points detailing the origin of the underlying document’s signature/seal) can be in the official language of the issuing authority.
- Recommended additional languages: To aid understanding across borders, the Convention recommends that the standard terms within the numbered fields may also be presented in a second language, suggesting English or French are beneficial.
UK FCDO apostille language layout:
Here in the UK, the apostilles issued by the FCDO follow these guidelines very clearly:
- They feature the mandatory French heading.
- The labels for the standard numbered fields (e.g., 1. Country, 3. Acting in the capacity of, 4. Bears the seal/stamp of) are typically presented trilingual: in English, French, and Spanish.
- However, the specific information filled into those fields by the FCDO official (e.g., the name of the notary or registrar, their capacity, the date of the apostille) is entered in English.
How other countries compare (examples):
Other member countries apply the same principles, leading to variations primarily in the language used for the inputted information:
- Spain: An apostille will have the French heading and the inputted details in Spanish, but it often includes the standard field labels in Spanish, English, and French.
- USA: Apostilles (usually issued at the state level) have French headings and input details in English. Depending on the state, Spanish terms might also be included alongside English labels.
- France / Germany: Expect the French heading and inputted details in French or German, respectively, and likely the inclusion of standard field labels in English and/or the other recommended language.
This variation in language presentation alongside consistent core elements is one reason apostilles can look different depending on the issuing country.
Important Reminder: These language rules apply only to the apostille certificate itself.
The Hague Convention does not govern whether your original document needs translating.
Translation requirements are determined solely by the receiving authority in the destination country (we discuss this in the Hague Convention & Document Translation Rules).
Understanding the standard structure, including the languages used, helps verify documents and ensures clarity when we process your paperwork for an express apostille.
