The one-line distinction
- Apostille — for destinations that are party to the Hague Apostille Convention. One certificate, issued by the state or federal competent authority. Done.
- Authentication certificate (also called a “certification” or, loosely, a “great seal”) — for destinations that are not party to the Convention. Issued by the same competent authority, but it must then be legalized by the destination country’s embassy or consulate in the United States.
- Legalization — the embassy or consulate’s own stamp confirming the authentication certificate. Only non-Hague destinations require it.
The request form for every U.S. competent authority asks for the destination country precisely so it can issue the correct certificate.
Which countries are which
As of late 2026 more than 125 jurisdictions are Hague members, including every EU country, the United Kingdom, Mexico, Brazil, India, Japan, South Korea, China (since November 2023), Canada (since January 2024) and Vietnam (since September 2026). Notable non-members where U.S. documents are commonly sent include the United Arab Emirates, Qatar, Kuwait, Egypt, Jordan, Lebanon, Iraq, Kenya, Ethiopia, Thailand, Malaysia, Taiwan and most of Africa and the Middle East. The country directory lists the status and date of entry into force for each destination.
The non-Hague chain, step by step
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Fees and timing stack up: the state or federal authentication fee, then the embassy’s legalization fee (anywhere from about $30 to several hundred dollars, often higher for commercial documents), plus courier costs for each leg. Several embassies also require that the document be translated into their official language — sometimes before legalization — and some require a cover letter, a copy of the applicant’s passport or an authorization letter if someone else submits it.
State documents bound for non-Hague countries
A state-issued document bound for, say, the UAE needs three certifications: the state authentication certificate, the U.S. Department of State authentication of the state certificate, and the UAE Embassy legalization. Florida, for example, issues a “certification” rather than an apostille when the request form names a non-Hague country. The federal step adds several weeks unless the document is hand-carried.
Federal documents bound for non-Hague countries skip the state step: U.S. Department of State authentication, then embassy legalization.
Common errors
- Requesting an apostille for a non-Hague destination. The embassy will not legalize an apostille; the request has to be redone as an authentication.
- Requesting an authentication for a Hague destination. The receiving authority expects the ten-field apostille and may reject a certification.
- Wrong country on the form. The certificate names the destination; a document apostilled “for Spain” is routinely accepted elsewhere in the Hague area, but authentications issued for one embassy will not be accepted by another.
- Skipping the federal step for state documents going to a non-Hague country. Embassies legalize only U.S. Department of State certifications.
Getting help with the chain
Because the non-Hague chain involves two or three offices in different cities, most people either use the embassy’s listed agents or a service that handles the Department of State authentication and embassy legalization steps. The state leg for Florida documents can be handled by a statewide Florida apostille service that files in Tallahassee, which issues the Florida certification; the federal and embassy legs are then completed in Washington.
Frequently asked questions
Is an 'authentication' the same as an apostille in a Hague country?
No. For a Hague country you need the apostille. An authentication certificate is only for countries outside the Convention and must be followed by embassy legalization.
Does an apostilled document need embassy legalization too?
No. The whole point of the Convention is that the apostille replaces legalization. An embassy of a Hague country will usually refuse to stamp an apostilled document because it is unnecessary.
What if the country joined the Convention recently?
Once the Convention is in force for that country, its authorities must accept apostilles — unless a country has objected to the accession, in which case the Convention does not apply between those two countries. The U.S. has not objected to recent accessions; some other states have objected to one another (for example, several countries have objected to accessions by India, the Philippines or others in the past).
Which office issues authentications for federal documents?
The U.S. Department of State, Office of Authentications, issues both apostilles and authentication certificates for federal documents depending on the destination.
