Apostille or Embassy Legalisation?
Apostille or embassy legalisation?
The question that determines whether your documents take one step or four, and the one people most often answer wrongly. The answer depends entirely on the destination, and it changes when a country joins the Convention.
Apostille
A single certificate, issued by a designated authority in the country where the document was made, that other member countries accept without further checks. It exists because of the 1961 Hague Apostille Convention. One step, one fee, universally recognised among members.
Who issues it in the United States. For a document issued by a state, such as a birth or marriage certificate or a notarised letter, the Secretary of State of that state. For a federal document, such as an FBI Identity History Summary or a Consular Report of Birth Abroad, the U.S. Department of State Office of Authentications.
Consular legalisation
The longer route used when the destination is not a Convention member. The document is authenticated domestically, then stamped by that country’s embassy or consulate, and in several countries attested again by their own foreign ministry after it arrives. Multiple steps, multiple fees, and it is specific to one destination.
The Gulf is the clearest example. The United Arab Emirates is not a Convention member and requires full attestation ending at its own Ministry of Foreign Affairs. Saudi Arabia, next door, joined in 2022 and accepts apostilles. Two neighbours, two completely different processes.
- 1 Obtain a certified original From the issuing authority. Photocopies, scans and souvenir certificates cannot be authenticated.
- 2 Notarise, if it is a private document Letters, affidavits, powers of attorney and diploma copies need a notary acknowledgement first. Government-issued vital records do not.
- 3 County clerk, in some states A handful of states require the county clerk to certify the notary commission before the Secretary of State will act.
- 4 Authenticate at the right level State-issued documents go to the Secretary of State of the ISSUING state. Federal documents, including the FBI Identity History Summary, go to the U.S. Department of State Office of Authentications.
- 5 Apostille or embassy legalisation Hague Convention destination: the apostille ends the chain. Non-member destination: the document then goes to that country embassy or consulate.
- 6 Certified translation Translate the document together with its apostille or legalisation certificate. Doing this first means paying twice.
- 7 File with the right consulate Jurisdiction is by your U.S. state of residence. Bring originals plus a full copy set.
The two expensive mistakes. Sending a federal document such as an FBI Identity History Summary to a Secretary of State, which cannot authenticate it. And translating before authentication, so the apostille certificate is not inside the translation and the whole set has to be paid for twice.
Which route does my destination need?
Apostille — 47 destinations
- Argentina
- Australia
- Austria
- Belgium
- Brazil
- Canada
- Chile
- China
- Colombia
- Costa Rica
- Croatia
- Czechia
- Denmark
- Dominican Republic
- Finland
- France
- Germany
- Greece
- Hungary
- Iceland
- India
- Indonesia
- Ireland
- Israel
- Italy
- Japan
- Mexico
- Morocco
- Netherlands
- New Zealand
- Norway
- Panama
- Peru
- Philippines
- Poland
- Portugal
- Saudi Arabia
- Singapore
- South Africa
- South Korea
- Spain
- Sweden
- Switzerland
- Turkey
- United Kingdom
- United States (inbound)
- Vietnam
Embassy legalisation — 5 destinations
This list covers the destinations in this guide. The authoritative and complete list, including the exact date the Convention entered into force for each country, is the HCCH status table, and it should be your source before you spend money.
Changing soon
These destinations have acceded to the Convention with a known entry-into-force date. If you are filing around the transition, confirm with the receiving authority which chain it will accept, because administrative practice sometimes lags the treaty date.
- Thailand — 28 February 2027
- Thailand has acceded to the Hague Apostille Convention and it is scheduled to enter into force for Thailand on 28 February 2027. Until then, the consular legalisation chain through the Royal Thai Embassy still applies. If you are filing in 2027 or later, check the HCCH status table first, because this changes the process substantially.
- Vietnam — 11 September 2026
- Vietnam acceded to the Hague Apostille Convention and it enters into force for Vietnam on 11 September 2026. Documents prepared before that date may have been processed under the older consular legalisation chain. Because administrative practice sometimes lags a treaty date by months, confirm with the receiving Vietnamese authority which chain they will accept if you are filing around the transition.
Common questions
What actually is an apostille?
A standardised certificate proving a public document is genuine, so a foreign government can accept it without further checks. It exists because of the 1961 Hague Apostille Convention and it only works between member countries.
My destination is not a member. What changes?
The chain gets longer and becomes destination-specific. The document is authenticated domestically, then legalised by that country's embassy or consulate, and several countries then require attestation by their own foreign ministry after the document arrives. The United Arab Emirates is the clearest example.
A country is joining the Convention soon. Which route do I use?
Whichever the receiving authority will accept on the day you file. Administrative practice sometimes lags the treaty date by months, so around a transition ask the receiving office directly rather than assuming the new rule is live.
Authoritative sources
Where this tool disagrees with one of these, the official source is right. Tell us and we will correct it.
- U.S. Department of State: Learn About Your Destination Entry, exit and visa requirements for U.S. citizens, country by country. The authoritative U.S. government starting point.
- U.S. Department of State: Records and Authentications Federal document authentication, including the Office of Authentications.
- HCCH: Apostille Convention status table The authoritative list of which countries are party to the Apostille Convention, and the entry-into-force date for each.
- Foreign embassies in the United States Directory of every foreign embassy in Washington, which is where legalisation happens for non-Convention destinations.
- U.S. embassies and consulates worldwide For U.S. citizen services abroad and notarials.
- Smart Traveler Enrollment Program Register your trip so the nearest embassy can reach you.
- CDC Travelers Health Vaccination and health entry requirements by destination.
- IATA Travel Centre The database airlines actually check at the boarding gate.
Verified Sep 7, 2026 Primary sources: travel.state.gov, www.hcch.net
This resource is provided free by Federal Apostille as an educational tool. It is not legal or immigration advice, and no attorney-client relationship is created by using it. Visa rules, fees, processing times and entry requirements change frequently and often without notice, and individual circumstances change the answer. Always confirm current requirements with the official government source and the specific embassy or consulate that has jurisdiction over your place of residence before you book travel or file an application. Every figure on this site carries the date we last verified it and a link to the primary source.
