Translate after the apostille
Apostille the original document first, then translate. The receiving authority usually wants the translation to cover everything, including the apostille certificate and any notarial certificates. If you translate first and apostille second, the apostille is left untranslated and the translation may be rejected.
The exception is when the translation itself must be notarized and apostilled in the U.S. (see below). Then the sequence is: apostille the original → translate → notarize the translator’s affidavit → apostille the translation.
Three kinds of translator
- Sworn (official) translator — a translator licensed by a court or ministry in the destination country (traductor jurado in Spain, perito traductor in Mexico, tradutor juramentado in Brazil, vereidigter Übersetzer in Germany, traducteur assermenté in France). Their translations are accepted by public offices without further steps. Many work remotely from scanned documents.
- Certified translation (U.S. style) — a translation accompanied by the translator’s signed statement of accuracy, often notarized. Accepted by U.S. agencies and by some foreign authorities, but many civil registries and courts abroad refuse it.
- Consular or embassy translation — some consulates (for example, several Italian consulates for citizenship files) translate or certify translations themselves, or publish lists of approved translators.
Country patterns
| Destination | What is usually required |
|---|---|
| Spain | Translation by a traductor jurado authorized by the Spanish Ministry of Foreign Affairs, or a translation legalized by the Spanish consulate. U.S. notarized translations are generally refused for official use. |
| Mexico | Translation by a perito traductor registered with a Mexican court; often done in Mexico after arrival. |
| Italy | For citizenship: translations reviewed/certified by the consulate or a sworn translation (traduzione giurata) made in Italy. Some consulates accept certified translations from their lists. |
| Brazil | Tradutor público juramentado registered in Brazil. Foreign translations are not accepted. |
| Germany | Beeidigter/vereidigter Übersetzer in Germany; some authorities accept U.S. certified translations case by case. |
| France | Traducteur assermenté registered with a French court of appeal. |
| Portugal | Translation certified by a Portuguese notary, lawyer, or consulate; sworn translators as recognized. |
| Netherlands, Belgium, Scandinavia | English documents often accepted without translation for many purposes. |
| Colombia, Peru, Chile, Argentina | Official translator registered locally; Colombia also accepts apostilled translations made abroad in many cases. |
| Dominican Republic | Translation by a judicial interpreter in the DR; the translation frequently needs its own apostille or legalization. |
| Japan, South Korea, China | Translation usually prepared in-country by an agency or the receiving institution’s accepted translator. |
Always confirm with the specific receiving office — rules differ between a consulate, a civil registry and a university within the same country.
Apostilling a translation made in the United States
Some destinations (and some U.S.-based consulates) accept a translation completed in the U.S. if the translator’s affidavit of accuracy is notarized and the notarization is apostilled. The apostille then authenticates the notary’s signature on the affidavit, not the translation itself. This is common for documents going to the Dominican Republic, some Latin American countries and for corporate documents. Because the notary must be commissioned in the apostilling state, the translation affidavit is usually notarized and apostilled in the same state as the original document — or in whichever state is convenient, since the translation is a separate document.
Should the apostille certificate be translated?
The Convention does not require it: the apostille’s headings may be in the language of the issuing authority, and the title must appear in French. In practice most sworn translators include the apostille in the translation, and some registries (Spain, Italy, Brazil) expect it. Ask the translator to include it; the cost is minimal.
Multilingual apostilles
A few U.S. states print apostilles with headings in English and French or add a Spanish translation of the headings; most issue English-only certificates. Foreign authorities cannot refuse an English-only apostille under the Convention.
Frequently asked questions
Can I translate the document myself?
For official use abroad, almost never. Most authorities require a translator recognized by their own system. Self-translations are accepted only by some employers and universities.
Do I need the translation apostilled?
Only when the destination requires an authenticated translation made in the U.S. — then the translator’s notarized affidavit is apostilled. When a sworn translator in the destination country does the work, no U.S. apostille on the translation is needed.
How much does a sworn translation cost?
Rates are per page or per document and vary by country and language pair; a one-page U.S. birth certificate with apostille typically costs the equivalent of $30–$90 with a sworn translator in Spain or Mexico, more in Northern Europe.
