French document terms

An apostille is a single certificate that makes a document usable in every other state party to the Hague convention. Légalisation is the older consular chain used where it does not apply — and the same French word also names a simple signature certification at a town hall.

The French terms that turn up in almost every francophone file, with their English equivalents and the Turkish document that corresponds to them. Where a term hides a trap, the trap is named rather than glossed over.

A sworn translation is one whose author has taken an oath before a court or an authority and certifies it under their own seal. The trap is that the oath is national: a translator sworn in one country is an ordinary translator in the next, and Türkiye works differently again.

An acte authentique is drawn up by a public officer who is answerable for its content, and it carries evidential force accordingly. Common-law readers hear “notarised” and think of a witnessed signature — a much weaker thing, and the source of a great deal of misunderstanding.

In French an acte is the entry in the civil register, not the paper in your hand. What you are given is a copy or an extract of it, in one of several versions, and the version is what the receiving authority is specifying when it uses a longer phrase than “birth certificate”.

The casier judiciaire is the criminal record held by the state, and it is issued in more than one form. The form an individual may request is deliberately the narrowest one, which is why an authority sometimes asks for something you cannot obtain for yourself.

A copie intégrale reproduces the whole civil status record, including parentage and every later annotation. An extrait gives selected fields, with parentage or without. Authorities ask for one or the other deliberately, and sending the wrong one gets the file returned.

An équivalence or comparative evaluation says what your foreign diploma resembles in the local system. A reconnaissance is the decision that lets you practise. They are different procedures, run by different bodies, and holding the first gives you no claim on the second.

A multilingual extract is a civil status record issued on a standard international form with headings pre-printed in several languages, French included. Where accepted it removes the need for translation and often certification too — but Canada is the exception people get wrong.

The livret de famille is a booklet issued to a couple and updated over the years with marriages, births and deaths. It is a convenient household record rather than a civil status certificate, and an authority that names it usually wants the register extracts behind it as well.

Marginal notes are annotations added to a civil status record after it was drawn up: marriage, divorce, name change, adoption, death. They are the part translators skip and applicants crop, and they are frequently the exact entry the authority is looking for.

A professional order is the body that controls entry to a regulated profession: it keeps the register, issues the permit and disciplines its members. In Québec it is also the reason a translation for certain files must come from a translator on its own list.

A procuration lets someone act for you. For anything to be done in Türkiye from abroad there are two routes with very different costs: one drawn up at a Turkish consulate, which is directly usable here, and one before a local notary, which then needs an apostille and a translation.

In Québec a traducteur agréé is a certified translator who belongs to the province’s professional order and works under a seal bearing a membership number. It is not an oath and not a state licence — it is membership of a self-regulating body.

In Belgium a traducteur juré is a sworn translator entered on the national register, working under a seal that carries a national registration number. The Belgian rule that surprises people is the order of steps: the apostille goes on first, and the sworn translator translates the apostille as well.