Apostille vs légalisation
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.
Checked on 8 September 2026 Last updated 8 September 2026
Both words describe the same problem: an official document is trusted at home because the receiving office recognises the signature and seal on it, and abroad nobody does. The two words describe different solutions to that problem, and using them interchangeably will get your file wrong.
Apostille: one certificate, many countries
Under the 1961 Hague convention abolishing the requirement of legalisation for foreign public documents, the state that issued a document appoints an authority to certify the signature and seal on it. That certificate — the apostille — is then accepted by every other contracting state without further steps.
In Türkiye the competent authority depends on the document: provincial governorships and district offices handle administrative documents, judicial commissions handle court and criminal record documents. France, Belgium, Switzerland and Luxembourg have all been parties for many years. Canada joined much later, the convention having entered into force there in January 2024 — worth confirming at source if you are reading older guidance, because much of what circulates online predates it.
Légalisation: the chain
Where the convention does not apply between two states, the older route is used: the document is certified by the issuing country’s foreign ministry and then by the destination country’s consulate in that country. More steps, more time, and each office charges its own fee. For the francophone destinations covered on this site the apostille route is the normal one.
The false friend
In everyday French and in Belgian municipal practice, légalisation de signature means something completely different: a town hall confirming that a signature on a private document belongs to the person who claims it. That is a local formality, not international certification. If your instructions mention légalisation, work out which of the two is meant before you book anything.
What an apostille does not do
- It says nothing about content. It certifies the signature, the capacity of the signatory and the seal — not that the statements in the document are true.
- It does not translate anything. A translation requirement is separate and unaffected.
- It does not certify a translation. Where the translation must itself be certified, an apostille is normally applied to the notary’s certification of the translator’s signature, not to the translation as such.
- It does not fix the order of steps. Belgium expects the apostille before translation, as set out in apostille first, then translation; some Swiss cantons expect the reverse. Confirm before starting.
- It settles nothing about acceptance. A properly apostilled document can still be refused for being out of date, incomplete or in the wrong version.
Whether your particular file needs one at all is a separate question, taken up in do you need an apostille for Québec.
Frequently asked questions
No. An apostille is issued only by the country where the document was issued. A Belgian document is apostilled in Belgium; Türkiye can then translate and notarise it for use here.
In Belgium, yes — the sworn translator translates the document and the apostille together. Elsewhere practice varies, and the standard apostille headings are multilingual in any case. Ask the receiving office.
The certificate has no expiry of its own, but the document underneath it does. Once a criminal record certificate or a registry extract falls outside the validity window, a new document and a new apostille are needed.