Apostille and Notarised Translation

In practice, though, three separate ideas are endlessly confused: sworn translation, notarisation and the apostille. They are not alternatives to one another but layers that sit one on top of the next. This page sets out what each layer is for and where the translation process fits into the chain.

Three layers: sworn translation, notarisation, apostille

Sworn translation means that a translator who has sworn an oath before a notary signs and stamps the translation. Responsibility for its accuracy rests with the translator. Notarisation attests not to the content of the translation but to the fact that the signature really belongs to that sworn translator. The notary does not check whether the text is correct, and this is precisely where the common misunderstanding lies.

The apostille is the topmost layer, and it confirms the authority of the office that issued or attested the document. An apostille verifies that the notary really is a notary, or that the seal of the civil registry office is genuine. It has nothing at all to do with the content of the document or the quality of the translation. Once this distinction is clear, it becomes far easier to see which layer a given document actually needs.

The order of the layers is not arbitrary either. First the document exists, then it is translated, then the translation is approved, and only at the end is the chain of certification built. Each layer confirms the existence of the one beneath it; if a lower link is missing or faulty, the layers above will not correct it, they will only make the error official. That is why, in most rejected files, the trouble lies not in the apostille but in the translation underneath it, or in the document itself.

Who issues the apostille in Türkiye

In Türkiye the authority to issue an apostille divides in two according to the nature of the document. Administrative documents – civil registry extracts, certificates of residence, diplomas, medical reports, tax registration certificates and the like – are endorsed by governors’ offices and district governors’ offices. Judicial documents, meaning court judgments, enforcement papers and anything at all drawn up before a notary, go to the relevant judicial justice commission.

The practical consequence is this: if you want an apostille on a notarised translation, you must go to the courthouse rather than the governor’s office, because what you now hold is a notary-signed paper and therefore judicial in nature. Which office in which province you apply to depends on where the document was issued; for province-level detail you can look at our province pages.

Barcoded documents obtained through e-Devlet stand a little apart. These printouts bear no wet signature; verification runs through the QR or barcode number on them. Some apostille offices endorse such printouts directly, while others ask for the document to be obtained again from the institution with a wet signature. If you are assembling a file for use abroad, asking about this detail before you set off with an e-Devlet printout will save you time.

Translation first, or apostille first?

This is the question that costs the most: the wrong order means having the entire job done again. The general rule points towards obtaining the apostille on the original document first. The endorsement is itself a printed text, added to the document or to its reverse. Have the translation done first and the endorsement that arrives later will not appear in it, so the receiving institution may refuse the file on the ground that the document has not been translated in full.

Some countries want one further step: an apostille on the original, then the translation, then notarisation of the translation, and finally a second apostille on that notarisation. This is known as the double apostille and it comes up particularly in certain Gulf and Eastern European practice. Reading the wording of the requesting institution word for word is the only dependable way to build the chain correctly from the start.

The reverse situation exists as well: a document from another country to be used in Türkiye. This time the apostille is obtained in the country of origin, the document arrives in Türkiye already endorsed, and here it is translated by a sworn translator and notarised. The institution in Türkiye wants to see the endorsement of the country of origin, and a foreign document that arrives without one is usually not processed at all. The direction of the chain, in short, follows the country in which the document was issued.

Is the apostille endorsement itself translated?

Under the Hague Convention the apostille endorsement is a standard form made up of ten numbered fields: country, name of the signatory, the capacity in which they acted, the authority whose seal it bears, place, date, number, seal and signature. Its heading remains fixed in French as “Apostille (Convention de La Haye du 5 octobre 1961)”, and that line is not translated but preserved as it stands.

The Turkish text inside the fields, by contrast – the name of the office, the title of the signatory, the name of the province – is translated. The trap inexperienced translators fall into is either to skip the endorsement entirely or to translate all of it. The correct practice is to keep the numbered structure and carry only the completed fields into the target language. The serial number and the date of the endorsement are transferred digit for digit.

The same care applies to seal and stamp texts. Every seal, every embossed stamp and every handwritten initial on the document is described in square brackets in the translation: which institution the seal belongs to, its wording if it can be read, and a note that it cannot be read if it cannot. A seal field left blank tells the receiving institution “we do not know what this document says”, and that breeds hesitation.

Countries outside the Convention: the chain of certification

Not every country belongs to the apostille system. Where a country is not a party, the older procedure applies: the document is first approved by the relevant Turkish authority, then certified by the Ministry of Foreign Affairs, and last of all attested by the destination country’s consulate in Türkiye. This three-link chain is both slower and more expensive than an apostille.

Membership has changed often in recent years, and several large countries joined the system not long ago. We therefore suggest checking the current position of your destination country, and that country’s own rules on translation, in our countries guide. Germany, for example, expects your document to be translated only by a court-sworn translator, whereas the United Kingdom has no sworn translator system at all and a declaration of accuracy from the agency is enough. In Australia a translation without the NAATI stamp is not accepted even when it carries an apostille.

Which purpose, which level of approval

Frequent mistakes

• Trying to obtain an apostille on a photocopy. The endorsement is given on a document bearing a wet signature or a verifiable original.
• Having the translation done before the apostille and leaving the endorsement out of it.
• Believing that notarisation takes the place of an apostille; the two are different layers.
• Going to the governor’s office for a judicial document, or to the courthouse for an administrative one, and losing days.
• Having the document translated into English rather than into the official language of the destination country. You can see which language will be wanted on our language pages.

Build the chain correctly from the start

Planned in the right order, apostille and approval procedures finish in a single pass; planned in the wrong order, every step is repeated. Tell us which layers your document needs, the destination country and the purpose of the application, and we will map the chain out for you. Current information on translation items is on our pricing page, and an assessment specific to your file can be had through the quote form.

This page is for general information; the level of approval required is decided by the institution asking for the document. Where you are in doubt, it is worth putting the question to that institution before you apply.