Complete 2026 guide to the international authentication of public documents intended for use in France. Hague Convention (125 countries), EU Regulation 2016/1191, double legalisation: the full legal framework and every procedure, country by country.
Apostille and legalisation both address the same need: authenticating a public document so it takes legal effect in a country other than the one where it was issued. But the two procedures differ radically in complexity and speed.
An apostille is a single stamp affixed by a central authority in the country of issuance, which authenticates in one act the signature, the capacity of the signatory and, where applicable, the seal or stamp on the document. It makes the document directly usable in the 125 countries that signed the Hague Convention of 5 October 1961.
Legalisation is the historic form of international authentication. It requires two steps: authentication by the ministry of foreign affairs of the issuing country, followed by counter-legalisation by the destination country's consulate. Longer and more costly, it still applies to countries that have not signed the Convention.
The Hague Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents is one of the most effective multilateral treaties in the history of private international law. Ratified by France by the Act of 10 March 1964, it entered into force on 24 January 1965.
The Convention applies to public documents, a term defined in Article 1:
The Convention does not apply to documents executed by diplomatic or consular agents, or to administrative documents directly related to a commercial or customs operation (invoices, certificates of origin).
Many signatory countries have introduced an e-Apostille programme (e-APP): issuing apostilles as a digital certificate that can be verified online. France joined this programme in 2025. These electronic apostilles are legally equivalent to paper apostilles.
This list is indicative · check with the Hague Conference on Private International Law (hcch.net) before taking any steps, as the list changes regularly.
Germany, Andorra, Austria, Belgium, Belarus, Bosnia and Herzegovina, Bulgaria, Cyprus, Croatia, Denmark, Spain, Estonia, Finland, France, Georgia, Greece, Hungary, Ireland, Iceland, Italy, Kosovo, Latvia, Liechtenstein, Lithuania, Luxembourg, North Macedonia, Malta, Moldova, Monaco, Montenegro, Norway, Netherlands, Poland, Portugal, Czech Republic, Romania, United Kingdom, Russia (suspended in some communications), San Marino, Serbia, Slovakia, Slovenia, Sweden, Switzerland, Turkey, Ukraine, Vatican.
Antigua and Barbuda, Argentina, Bahamas, Barbados, Belize, Bolivia, Brazil, Canada (since 11 January 2024), Chile, Colombia, Costa Rica, Dominica, Ecuador, El Salvador, United States, Grenada, Guatemala, Guyana, Honduras, Jamaica, Mexico, Nicaragua, Panama, Paraguay, Peru, Dominican Republic, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines, Suriname, Trinidad and Tobago, Uruguay, Venezuela.
South Africa, Algeria (since 19 January 2023), Botswana, Burkina Faso, Burundi, Cape Verde, Comoros, Djibouti, Eswatini, Guinea-Bissau, Lesotho, Liberia, Malawi, Mauritius, Mozambique, Namibia, Niger, Rwanda, São Tomé and Príncipe, Senegal (since 23 March 2023), Seychelles, Tunisia, Zambia.
Armenia, Australia, Azerbaijan, Bahrain, Brunei Darussalam, China (in force since 7 November 2023), Cook Islands, South Korea, United Arab Emirates (in force since 2025), Fiji, Georgia, Hong Kong, India, Indonesia (since 2022), Israel, Japan, Kazakhstan, Kyrgyzstan, Macao, Malaysia (since 2023), Marshall Islands, Mongolia, New Zealand, Oman, Uzbekistan, Pakistan (since 2024), Palau, Philippines, Samoa, Singapore, Tajikistan, Tonga, Turkmenistan, Vanuatu, Vietnam.
Main countries where double legalisation still applies in 2026:
For these countries, double legalisation (local ministry + French consulate) remains unavoidable.
Regulation (EU) 2016/1191 of 6 July 2016, which came into application on 16 February 2019, simplified the circulation of public documents between EU member states.
This covers documents relating to: birth, death, name, marriage, capacity to marry, divorce, legal separation, annulment, registered partnership, parenthood, adoption, domicile, nationality, and criminal record.
1. No apostille required for these civil status records between member states.
2. A standard multilingual form attached to the record, which removes the need for translation when the recipient is an administration.
The regulation only covers the document's formal authenticity (that it really was issued by a town hall, etc.), not its legal content. It only applies to civil status records: a European diploma or a commercial judgment still needs an apostille.
Each country designates a central authority responsible for issuing the apostille. Here are the main ones for the countries most requested by our clients.
Competence lies at state level for local documents (the Secretary of State of the relevant state), and at federal level (U.S. Department of State, Authentications Office, Washington D.C.) for federal documents. Cost: $8 per apostille. Turnaround: 1 to 2 weeks.
Foreign, Commonwealth and Development Office (FCDO), Legalisation Office, Milton Keynes. Apply online at gov.uk/get-document-legalised. Cost: £30 per document (standard) or £75 (premium service). Turnaround: 5 to 10 days.
Decentralised competence: each Land designates its own authority (Bundesverwaltungsamt for federal documents, regional government presidencies for others). Cost: around €25. Turnaround: 1 to 3 weeks.
Ministerio de Justicia (judicial and notarial acts) or the Colegio de Notarios for notarial acts. Free or €3. Turnaround: a few days.
Procura della Repubblica (for judicial documents) or Prefettura (for administrative documents). Free. Turnaround: 1 to 2 weeks.
Since 7 November 2023, the Chinese apostille is issued by the Chinese Ministry of Foreign Affairs (MOFA) or by the Foreign Affairs Offices of authorised provincial governments. Cost: around CNY 80. Turnaround: 4 business days.
Since 19 January 2023, the Algerian Ministry of Foreign Affairs, Directorate of Legal and Consular Affairs, Algiers. The 48 wilayas can also issue apostilles for local documents. Cost: around DZD 500. Turnaround: 3 to 10 days.
Ministry of Foreign Affairs, Consular Directorate, Tunis. Cost: 5 TND (free for some records). Turnaround: 2 to 5 days.
The Valilik (governor's office) for administrative documents, or the local magistrate's court for notarial acts. Free. Turnaround: same day.
Since the reform of 1 May 2025, the French apostille is issued by a single centralised authority, replacing the former system decentralised by Court of Appeal.
Attached to the Central Authentication Service of the Ministry for Europe and Foreign Affairs, the BCAL has been the sole competent authority since 2025. Before the reform, each of the 36 Courts of Appeal issued its own apostilles.
Apply via the apostille.diplomatie.gouv.fr platform: upload the scanned document, choose the destination country, pay (free since the reform), then send the original by registered mail. The apostille is affixed and returned within 1 to 3 business days.
This is one of the most common questions · and a classic, costly mistake.
The apostille must be affixed to the source document before translation. The French sworn translator will then translate everything: document + apostille. Without following this rule, the apostille affixed in the country of issuance would not be translated, and the French administration would not be able to authenticate it.
When a French document is translated (for use abroad), it is the French translation that gets apostilled, since that is what carries the official signature (that of the expert translator). This case applies to documents being exported.
For countries that have not signed the Hague Convention, the procedure follows two mandatory steps.
For some countries (Morocco, Lebanon, Tunisia before 2018), it is possible to go through the issuing country's consulate in France: the document is legalised by that country's consulate in Paris, then by the French Ministry for Europe and Foreign Affairs. This route is sometimes faster.
| Country | Type | Average cost | Turnaround |
|---|---|---|---|
| France | Apostille | Free | 1-3 days |
| United States | Apostille | $8 | 1-2 weeks |
| United Kingdom | Apostille | £30 | 5-10 days |
| Germany | Apostille | €25 | 1-3 weeks |
| Spain | Apostille | €0-3 | 2-5 days |
| Italy | Apostille | Free | 1-2 weeks |
| China | Apostille | CNY 80 (~€10) | 4 days |
| Algeria | Apostille | DZD 500 (~€3) | 3-10 days |
| Morocco | Double legalisation | €60-120 | 3-6 weeks |
| Ivory Coast | Double legalisation | €80-150 | 4-8 weeks |
| Cameroon | Double legalisation | €80-120 | 6-12 weeks |
Before 7 November 2023, all Chinese documents required double legalisation. Since then, an apostille is enough. Note, however, that Hong Kong and Macao were already signatories since 1997 and 1999 respectively; their arrangements remain separate from mainland China.
Algeria is now an apostille country. This is a considerable simplification for the Algerian diaspora in France: Algerian birth certificates, divorce judgments and school enrolment certificates no longer require the burdensome double legalisation. However, documents issued before this date may still carry a double legalisation, which remains valid.
Morocco regularly considers acceding, but as of 1 April 2026 has not signed the Convention. Double legalisation therefore remains mandatory for all Moroccan documents intended for France. Procedure: the Moroccan Ministry of Foreign Affairs (MAEC) in Rabat, then the French consulate (Rabat or Casablanca).
New exemption from double legalisation for all UAE documents since their accession to the Convention took effect in 2025.
Gibraltar, Jersey, Guernsey, Isle of Man: covered by the UK's extension. French Polynesia, New Caledonia, Saint-Barthélemy: covered by France. Taiwan: special status, handled via the French Representative Office.
An apostille is a simplified formality (a single stamp) provided for by the Hague Convention of 5 October 1961, applicable between the 125 signatory countries. Standard legalisation is a double authentication (local ministry + destination country's consulate) that applies to countries that have not signed the Convention.
No, not any more for civil status records, since EU Regulation 2016/1191 of 16 February 2019. These records circulate freely between member states, optionally accompanied by a standard multilingual form issued free of charge by the issuing authority. For other documents (diplomas, commercial judgments, contracts), an apostille is still useful.
Always BEFORE translation. The apostille is affixed in the country of issuance, on the original document. The sworn translator then translates everything: document + apostille. Affixing the apostille after translation means everything has to be redone, since the apostille's text would not have been translated.
Since the reform of 1 May 2025, the French apostille is issued by the Central Apostille and Legalisation Office (BCAL), part of the Central Authentication Service of the Ministry for Europe and Foreign Affairs. Requests are made online via the apostille.diplomatie.gouv.fr platform. Issued within 1 to 3 days, free of charge.
In France, the apostille has been free since 2025. Abroad, costs vary: $8 in the United States, £30 in the UK, €25 in Germany, €0-3 in Spain, around €10 in China. Double legalisation is always more expensive: €60 to €150 depending on the country, with long turnaround times.
Yes, since 19 January 2023. Algerian documents no longer require double legalisation, only a simple apostille issued by the Algerian Ministry of Foreign Affairs. Morocco, however, is still not a signatory as of 1 April 2026: double legalisation is mandatory.
It varies widely by country: 1 to 3 days in France, 1 week in the United States, 2 to 4 weeks in many European countries, 1 to 3 months for double legalisation in Africa or Asia. Always plan for this formality several weeks before your administrative deadline.
We handle French apostilles on our own certified translations (for use abroad), but we cannot obtain a foreign apostille on your behalf: only the authorities of the issuing country are competent to do so. We do, however, guide you through the process by providing the exact addresses, contacts and procedures for each country.
Our expert translators handle the translation of the document and its apostille. Delivered in 48h.