Apostille before or after translation: what if the translation is already done?

Where is the apostille needed: on the original, a copy or the translation?

An apostille on the source document, a notarised copy and a certified translation concerns different signatures and certifications. These options cannot therefore be treated as automatically interchangeable.

An apostille certifies the authenticity of a signature, the capacity in which the signatory acted and, where applicable, the seal or stamp. This is the scope established by the Hague Apostille Convention.

To choose the order of steps, distinguish three situations:

• Apostille on the source document. It certifies the signature and seal relating to the authority that issued the document.
• Apostille on a notarised copy. It relates to the notarial act certifying the copy.
• Apostille on a certified translation. It certifies the relevant signature or certification associated with the translation.

If an institution requests a document with an apostille, ask which of these it needs. Otherwise, you could correctly obtain a certification that does not meet the requirements of your submission.

What to confirm with the receiving institution before ordering

Before paying for an apostille and translation, obtain the requirements of the institution where you will submit the documents. Ideally, get them in writing and for your specific procedure.

Start with five questions:

1. Is an apostille required for this document and this submission?
2. Where must it appear: on the source document, a notarised copy or the translation?
3. What language is needed, and who must certify the translation?
4. Which parts must be translated: the main text, attachments, reverse side and additional endorsements?
5. What form is accepted: a paper document or electronic file, an original or a copy?

State the country that issued the document and the country where it will be used. An English-language document may have been issued in different countries. Language alone does not determine the certification process.

Check whether an apostille is needed separately from whether a translation is needed. Some documents and situations are exempt from authentication; exemptions are described, for example, in the Polish Ministry of Foreign Affairs guidance.

If the apostille is required on the source document

When the receiving institution requires the source document with an apostille and a translation of the whole set, obtain the apostille first. Then give the translator the document together with the new endorsements and attachments.

The sequence for this case is:

1. Prepare the required version of the document.
2. Obtain any preliminary authentications required for it, then obtain the apostille.
3. Provide the complete set to the translator.

Show more than the front page. The apostille and other endorsements may be on the reverse or on a separate attached sheet. The translator needs to see everything included in the agreed scope.

Consider a civil-status certificate. The receiving institution confirms that it needs the certificate with an apostille and a translation of the set. If the certificate is translated before the apostille is issued, the translation will not yet include the new endorsements. Once they appear, you will need to agree separately how to supplement the result.

For this particular scenario, “apostille → translation” helps avoid additional preparation.

If the apostille is specifically required on the translation

First prepare the translation in the required form, then obtain the apostille on the certification relating to it. Establish in advance who must produce the translation and whose signature needs to be authenticated.

The Polish Ministry of Foreign Affairs lists sworn translations as a separate document category and expressly states that an apostille cannot be issued on a photocopy of a sworn translation. This condition appears in its official guidance.

An apostille on the translation does not remove a separate requirement concerning the source document. If both certifications are required, the sequence needs to be agreed for both documents.

Before ordering a sworn translation, tell the translator the country of submission and provide the exact wording of the requirement. Also ask whether endorsements added after certification must be reflected in the final set.

If a notarised copy is proposed instead of the original

Use a notarised copy in place of the source document after confirming that the receiving institution accepts that form. An apostille on the certification of a copy does not authenticate the signature of the authority that issued the original.

The Polish Ministry of Foreign Affairs highlights this distinction in its frequently asked questions. In the case described there, the certification concerns the copy’s conformity with the original; whether that form is suitable must be checked in the destination country.

You can ask the receiving institution directly:

Do you accept a notarised copy with an apostille on the notarial certification, or do you require an apostille on the source document?

This helps you agree the appropriate option before contacting a notary.

Five situations: what to do about the apostille and translation

The next step depends on what is already prepared and exactly what the receiving institution requires. Find your situation in the table and start with the clarification shown.

If the translation is already complete, start your enquiry to the agency by explaining what has changed. Show the institution’s requirement and the result you already have. This makes it possible to discuss the specific work still needed.

Does the document need translating again after the apostille?

Adding an apostille does not, by itself, mean the entire translation must be redone. First check whether the existing text can be used and how the missing part should be prepared.

If the issue is only new endorsements, ask the translator whether a supplement is possible. Establish how it will be linked to the original translation and whether the receiving institution accepts that set. Do not assume in advance that translating one separate sheet will be enough.

A different result may be needed if:

• the institution requires a different form of translation certification;
• the translation was prepared from a copy, but the submission requires one based on the original presented to the translator;
• the source document has been replaced by a new version;
• the existing translation does not meet the language or content requirements.

Give the translator the receiving institution’s exact objection. Saying “the translation is unsuitable” does not explain what needs correcting.

Do not add text, replace pages or attach sheets to a certified translation yourself. Agree the method of preparation with the translator.

Translation from a scan or from an original: what to check

Sending a scan for a quote and obtaining a translation certified from the original presented are different tasks. Check which source material is identified in your translation’s certification statement.

In Poland, Article 18(2) of the Act on the Profession of Sworn Translator provides for indicating whether the translation was made from an original, a translation or a copy, together with information about certification of the source material.

Start with the certification statement in the completed translation. Then compare it with the institution’s requirement: does it call for the original to be presented and the translation to be made specifically from it?

If so, show the requirement to the translator and ask how to prepare a suitable result. The use of a scan alone does not establish that a translation is necessarily unsuitable for every submission.

For an initial enquiry, you can send document images and explain your task. Agree whether the original must be presented before the final result is prepared.

How to check whether Poland will accept a translation notarised abroad

Show the receiving institution your completed translation and ask whether it meets the requirements of your procedure. The label “notarised translation” alone does not answer that question.

In Poland, tłumaczenie przysięgłe means a sworn translation, produced and certified by a sworn translator within their statutory authority. The profession is governed by Polish law. A translation called “certified” or “notarised” in another country does not automatically have the same status.

The translator, certification method and language of a foreign notarised translation may differ. Before ordering a replacement, therefore, ask the institution:

• whether the existing translation’s language is suitable;
• whether that certification method is accepted;
• whether a Polish sworn translator’s translation is required;
• whether the original must be presented;
• whether all necessary parts of the document have been translated.

If the set is refused, ask for the specific reason. You can then establish whether a different translation is needed or the issue concerns only one part of its preparation.

Does the apostille itself have to be translated?

Translation is not a condition for recognising an apostille under the Hague Convention. Requirements concerning the language of the underlying document still apply. These are separate questions.

Paragraphs 304–305 of the HCCH Apostille Handbook explain that an apostille cannot be rejected because of the language in which it was issued or because it has not been translated. An institution may, however, require a translation of the underlying document under the applicable rules.

The general advice “an apostille must always be translated” therefore does not give a precise answer for your submission. It is equally insufficient to say that having an apostille removes the need to translate the document.

If the receiving institution requests a translation of the set including its endorsements, confirm the scope and basis of that requirement. If translation of the apostille is described as a mandatory condition for recognising the certificate itself, ask for clarification in light of the Convention.

How to confirm document requirements in writing

Send the receiving institution one enquiry describing the document, the completed translation and your planned submission. This helps you obtain an answer about your own set rather than general advice.

You can use this template:

Hello,

For [procedure], I plan to submit [document type], issued in [country] by [issuing authority].

I currently have [the original / a certified copy / a translation]. The translation was made [from the original / a copy / a scan — as stated in its certification]. The apostille [has already been obtained / has not yet been obtained].

Please confirm:

1. Is an apostille required for this document and procedure?
2. Where must it appear: on the source document, a notarised copy or the translation?
3. What language is required, and who must certify the translation?
4. Which pages, attachments and endorsements need translating?
5. In what form should the set be submitted?
6. If the apostille is added after the translation is complete, do you allow a supplement, or is a new translation required?

If possible, please provide a link to the applicable requirements.

Thank you.

Give the reply to the translator before work begins. If the document, institution or purpose of submission later changes, check the requirements again.

What to check before ordering an apostille and translation

Ordering is easier when the required set and sequence are clear. Check whether you can confirm each point:

• I know where and for which procedure I am submitting the document.
• It is clear whether an apostille is required and on which document.
• The translation language and certification method have been agreed.
• It is clear whether the original is needed to complete the order.
• The pages and endorsements to include in the translation have been identified.
• If the translation is already complete, it is clear whether it can be used or supplemented.

You can discuss questions about obtaining certification through the document apostille service. In your first message, state the document type, the issuing and destination countries, and what has already been prepared.

We can help agree the translation of your document set

If you are unsure what to do with an existing translation, contact Translate Service for a consultation. Show the document, your translation and the receiving institution’s requirements. We will clarify the scope of work and agree a suitable way to prepare the result.

You do not need to choose in advance between “translate only the apostille” and “redo everything”. First, we will establish the result needed for your task.

About the author

Karolina Bałabon

Sworn translator of Russian

Working in translation since 2000, she has been a sworn translator of Russian since 2006. She graduated in applied linguistics from the University of Warsaw.

She specialises in legal, court and notarial translation. She works with Russian, Ukrainian, Polish and English, and deals with apostilles, legalisation and the preparation of foreign documents for use in Poland.

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