Legalisation Glossary: Terms Explained
Reference
Legalisation Terms, in Plain English
Three authorities can use three different words for the same act, and one word for three different acts. These are the terms that actually appear on mission websites and in rejection slips.
The vocabulary
- Apostille
- A single certificate that replaces the whole legalisation chain, valid only between countries that are both party to the Hague Apostille Convention.
- Attestation
- The word most Gulf and South Asian countries use for the same idea, and also for the ministry step performed after the document arrives.
- Authentication
- The U.S. term for the federal layer performed by the Department of State Office of Authentications.
- Certified copy
- A copy issued and sealed by the office that holds the original record. Not a photocopy, and not a notarised photocopy.
- Chamber of commerce certification
- A pre-embassy step required for many trade documents, confirming the exporter and the goods.
- Consular district
- The group of U.S. states a particular embassy or consulate is responsible for. Assigned, not chosen.
- DS-4194
- The U.S. Department of State request form that must accompany documents sent for federal authentication.
- Exemplification
- A court clerk's certificate confirming a judge's signature and authority, required for many court documents.
- Legalisation
- The older multi-step chain used when the destination is not a Hague party. Each authority certifies the one before it.
- MoFA
- Ministry of Foreign Affairs, the destination country's own authority, which often adds a final attestation in country.
- True copy
- A notarised declaration that a copy matches an original, used when the original cannot be surrendered.
- Wet-ink signature
- An original hand signature rather than a printed, stamped or electronic one. Required for most commercial documents.
Requirements on this page were last checked against official sources on .
Questions people actually ask
Is attestation the same thing as legalisation?
In practice yes. Most Gulf and South Asian authorities say attestation where U.S. offices say authentication or legalisation. The confusion matters only when a mission uses attestation to mean the extra step performed by its own ministry after the document arrives.
What is the difference between a certified copy and a notarised copy?
A certified copy is issued and sealed by the office holding the original record, such as a vital records registrar. A notarised copy is a photocopy with a notary declaring it matches an original they saw. Most missions require the former for vital records and will refuse the latter.
This guide is published by a private document processing service. It is not legal advice and we are not a government agency. Requirements change without notice, so confirm anything critical with the mission before you post documents.
