Apostille vs Notary: What’s the Difference & When Do You Need Each?
Apostille and notarisation are two different steps in the authentication process for international documents. A notary verifies your identity and witnesses your signature. An apostille confirms that the notary’s certificate is genuine — so it will be accepted in another country.
This guide explains when you need one, the other, or both — with clear steps for getting your documents ready. Written by a London notary practice that handles both services every day.
Key Differences Between Apostille and Notary
Quick answer: A notary public is a legal professional who verifies the identity of signers and authenticates documents through a notarial act. An apostille is a government-issued certificate (from the FCDO in the UK) that authenticates the notary’s signature for international recognition in Hague Convention countries. They serve different purposes — but often work together.
| Feature | Notary (Notarisation) | Apostille |
|---|---|---|
| What is it? | A notarial act performed by a qualified notary public — verifying identity, witnessing signatures and issuing a notarial certificate | A government-issued apostille certificate authenticating the signature and seal on official documents |
| Who issues it? | A notary public — in the UK, a qualified legal professional regulated by the Faculty Office | A government department — in the UK, the FCDO Legalisation Office |
| Purpose | Validates identity of the signers, authenticates signatures, certifies copies of documents | Gives the notarised document international recognition under the Hague Apostille Convention |
| Where accepted? | Domestically and as a first step before apostille or legalisation | In all 124 countries that are members of the Hague Convention |
| Format | Notarial certificate attached to the document, bearing the notary’s signature and official seal | An apostille stamp or certificate — a standardised form attached or affixed to the document |
| When needed? | Whenever an overseas authority requires verified documents — powers of attorney, statutory declarations, certified copies | When a Hague Convention country requires proof that the notary’s signature is genuine |
| Typical cost (UK) | Varies by document — contact us for a quote | From £60 plus VAT (standard) + £40 FCDO fee (no VAT) |
| Turnaround | Usually same day or next day by appointment | Standard 10 working days, priority 5 days, express next day |
Understanding these key differences helps you identify the correct authentication path for your legal documents — and avoids delays or rejections at the destination.
Not Sure What You Need? Ask Us
Tell us about your document and where it’s going — we’ll confirm whether you need notarisation, apostille or both. No obligation.
What Is a Notary and What Does Notarisation Involve?
A notary public is a qualified legal professional authorised to perform notarial acts — including verifying the identity of the signers, witnessing signatures, administering oaths and certifying copies of documents. In the UK, notaries are regulated by the Faculty Office of the Archbishop of Canterbury.
Notarisation is the process by which a notary authenticates a document for use outside the UK (or domestically where a higher level of verification is required). The notary verifies your identity using official identification, witnesses the signing of the document, and then attaches a notarial certificate bearing their signature, seal and a description of the notarial act performed.
A notarised document carries the notary’s personal guarantee that the signatures are genuine, the signers understood the document, and that proper procedures were followed. This is essential for legal documents used in international transactions — from powers of attorney to company resolutions.
UK vs US Notary — an Important Distinction
In the United Kingdom, a notary public is a senior legal professional — either a solicitor with additional qualifications or a person specifically trained and admitted by the Faculty Office. They undergo years of legal training and are subject to regulation and professional indemnity requirements.
In the United States, a notary (sometimes called a “notary public” or “commissioned notary”) is typically an administrative role with minimal training. US notaries mainly verify identity and witness signatures but do not provide the same level of legal authentication as a UK notary.
This distinction matters: when a foreign country requests a “notarised document” from the UK, they are asking for the authentication services of a Faculty Office registered notary — not simply a witnessed signature.
How to Find a Registered Notary
In the UK, all practising notaries are registered with the Faculty Office. You can search the Faculty Office register or contact a notary practice directly. Look for a notary experienced in the specific type of document you need authenticated — whether that is a personal document like a birth certificate, or a commercial document such as a board resolution.
What Is an Apostille and What Does It Do?
An apostille is a government-issued certificate that authenticates the origin of a public document — specifically the signature, seal or stamp on the document — so it will be accepted in another country that is a member of the Hague Apostille Convention. In the UK, apostilles are issued exclusively by the FCDO Legalisation Office.
The apostille certification process exists to simplify the authentication of documents for international use. Before the Hague Convention, sending documents abroad required a lengthy chain of authentication through multiple government departments and embassies. The apostille replaced this with a single, standardised certificate recognised across all member countries.
An apostille stamp (or apostille certificate) is a standardised form that confirms the document bearing it has been properly authenticated. It verifies the signature of the person who signed the document, the capacity in which they acted, and the identity of any seal or stamp on the document.
Who Can Issue Apostilles in the UK?
Only the Foreign, Commonwealth & Development Office (FCDO) — formerly the Foreign & Commonwealth Office — can issue apostilles in the UK. You cannot obtain an apostille from a notary, solicitor, or any other private professional. However, a notary public or apostille services provider can submit your document to the FCDO on your behalf and manage the entire process.
What Documents Can Be Apostilled?
The FCDO can apostille documents that bear the signature or seal of a UK public official — including notaries public, court officials, and government registrars. Common examples include notarised documents, birth certificates issued by the General Register Office, court orders, and Companies House certificates. Private documents (such as a business contract) must first be notarised before they can be apostilled.
The Hague Apostille Convention Explained
The Hague Apostille Convention (formally the Hague Convention Abolishing the Requirement of Legalisation for Foreign Public Documents) is an international treaty established in 1961 by the Hague Conference on Private International Law. It simplifies the process of authenticating documents for use between member countries.
Before the Convention, getting a UK document accepted in a foreign country required multiple steps: notarisation, FCDO authentication, and then legalisation by the embassy or consulate of the destination country. The Hague Convention replaced this with a single apostille certificate that all member countries agree to accept.
Today, over 124 countries are members of the Hague Convention — including most of Europe, the United States, Australia, Japan, South Africa, and many South American countries. If your document is going to a Hague Convention country, an apostille is all you need for international recognition.
What If the Destination Country Is Not in the Hague Convention?
If the country where your document will be used has not signed the Hague Convention, you will need full consular legalisation instead. This is a longer process involving notarisation, FCDO authentication, and then legalisation at the embassy or consulate of the destination country. Common non-Hague countries include the UAE, China, Canada, and several African and Middle Eastern nations.
We handle both routes — apostille for Hague Convention countries and full legalisation for non-Hague destinations. See our apostille and legalisation services →
Types of Documents That Need Apostille or Notary
The type of document determines whether you need notarisation, apostille, or both. Here is a breakdown by category:
📋 Personal Documents
- ✓ Birth certificates — can often be apostilled directly if issued by the GRO
- ✓ Marriage certificates — apostille for use in Hague Convention countries
- ✓ Death certificates — for estate matters in a foreign country
- ✓ Passport copies — must be notarised (certified as a true copy) before apostille
🎓 Educational Documents
- ✓ Degree certificates — commonly needed for overseas job applications and visa processes
- ✓ Academic transcripts — often require notarised copies before apostille
- ✓ Professional qualifications — ACCA, RICS, medical certifications
- ✓ School records and references — for international school transfers
⚖️ Legal Documents
- ✓ Powers of attorney — the most common document we notarise for overseas use
- ✓ Court documents and judgments — require court seal for direct apostille
- ✓ Statutory declarations — sworn before a notary, then apostilled
- ✓ Affidavits — witnessed and authenticated for foreign proceedings
🏢 Business Documents
- ✓ Company registration certificates — Companies House documents can be apostilled directly
- ✓ Board resolutions and contracts — must be notarised first
- ✓ Articles of association — certified copies need notarisation before apostille
- ✓ Commercial invoices and trade documents — for international transactions
Not sure which route your document needs? The simplest approach: if it was issued by a UK government body (GRO, Companies House, HMCTS), it can usually go straight to the FCDO for apostille. If it is a private document, you will need a notary to authenticate it first.
How to Get a Document Notarised — Step by Step
The notarisation process is straightforward when you know what to expect. Here is how it works at our London practice:
Contact Us With Your Documents
Tell us what documents you need notarised and where they are going. We will confirm the process, fees and what to bring to your appointment.
Attend Your Appointment
Bring your original documents and valid photo ID (passport or driving licence). The notary verifies your identity, witnesses any required signatures, and performs the notarial act.
Receive Your Notarial Certificate
The notary attaches a notarial certificate with their signature, seal and a description of the act performed. Your notarised document is ready — or we can submit it for apostille on your behalf.
What to Bring to Your Notarisation Appointment
- ✓ The original document(s) you need notarised — or the document you need to sign in the notary’s presence
- ✓ Valid photo identification — current passport or UK driving licence (the notary must verify the identity of the signers)
- ✓ A second form of ID or proof of address if specifically requested
- ✓ Any instructions from the receiving party or foreign authority about specific requirements
How to Get a Document Apostilled in the UK
The UK apostille process is managed by the FCDO Legalisation Office. You can apply directly, or use an apostille services provider (like us) to handle it for you.
Prepare Your Document
If your document is a private document (not from a UK government body), you will need a notary to notarise it first. GRO certificates and Companies House documents can go directly to the FCDO.
Submit to the FCDO
Send or deliver the document to the FCDO Legalisation Office with the correct fee (currently £40 per document, no VAT). We handle this submission on your behalf as part of our apostille service.
Receive Your Apostille Certificate
The FCDO checks the signature and seal on your document against their records, then attaches the apostille certificate. Turnaround is 2–10 working days depending on the service level chosen.
Apostille Pricing at Edward Young Notaries
Our apostille service fees (in addition to the £40 FCDO government fee per document):
- ✓ Standard service: £60 plus VAT — approximately 10 working days
- ✓ Priority service: £80 plus VAT — approximately 5 working days
- ✓ Express service: £100 plus VAT — next working day
Discounts for multiple documents. The FCDO fee of £40 per document is a government charge with no VAT. See full pricing breakdown →
Real Use Cases: Apostille and Notary in Action
Here are typical situations where our clients need notarisation, apostille or both. These illustrate how the two processes work together in practice for international transactions.
Moving to Spain — Birth Certificate Apostille
A UK citizen relocating to Spain needed their birth certificate apostilled for residency registration. Since it was an original GRO certificate, it went straight to the FCDO for apostille without notarisation — ready in 5 working days with our priority service.
Company Expansion to Germany — Board Resolutions
A London-based company opening a subsidiary in Germany needed board resolutions and powers of attorney authenticated. We notarised the documents, then submitted them to the FCDO for apostille. Both steps completed within one week.
Selling Property in France — Power of Attorney
A client selling their French holiday home needed to grant power of attorney to a French notaire (different from a UK notary). We notarised the power of attorney in English with a French-language certification, then apostilled it for use in France.
Job Offer in the UAE — Degree Certificate
An engineer accepting a role in Dubai needed their degree certificate authenticated. Since the UAE is not a Hague Convention member, an apostille was not sufficient — full consular legalisation was required. We handled notarisation, FCDO legalisation, and UAE Embassy attestation.
Common Mistakes to Avoid
We see these errors regularly. Each one causes delays, extra costs or rejected documents at the destination. Knowing them in advance saves time and money.
❌ Apostilling Documents for a Non-Hague Country
If the destination country has not signed the Hague Convention, an apostille will not be accepted. You need full consular legalisation instead. Always check before you apply — we can confirm the correct route for any country.
❌ Skipping Notarisation Before Apostille
Private documents (contracts, powers of attorney, copies of documents) must be notarised before the FCDO will apostille them. Only documents already bearing a UK public official’s signature can be apostilled directly.
❌ Using Uncertified Copies
An apostille applied to a plain photocopy has no legal value. Copies of documents must be properly certified by a notary public as “true copies of the original” before apostille. The notary’s certification is what gives the copy its legal standing.
❌ Not Checking the Destination Country’s Specific Requirements
Some countries require documents in a specific format, with particular wording, or translated into the local language by a certified translator. Check with the receiving authority before you start the process — or ask us and we will confirm what is needed.
❌ Confusing US and UK Notarisation
A “notarised” document from the United States carries different legal weight than one from the UK. If a foreign authority requests a UK-notarised document, it must be done by a Faculty Office registered notary — not a US-style notary public or a solicitor witnessing a signature.
Why Choose Edward Young Notaries for Apostille & Notarisation?
Both Services Under One Roof
Notarisation and apostille handled together — no need to coordinate between different providers. One point of contact from start to finish.
Faculty Office Registered
Our notary is registered with the Faculty Office and holds full professional indemnity insurance. Your documents carry the authority they need.
Express Turnaround Available
Same-day notarisation appointments and next-working-day FCDO apostille service when you need documents urgently.
Central London Location
19 Wigmore Street, London W1U 1PH — minutes from Bond Street and Baker Street stations. Walk-in or by appointment.
Clear, Fixed-Fee Pricing
No hidden charges. Apostille fees from £60 plus VAT. All costs confirmed before you commit. Discounts for multiple documents.
4.9★ Google Reviews
Over 120 five-star reviews from clients who trusted us with their most important documents. Read what they say below.
What Our Clients Say
Frequently Asked Questions
What is the difference between an apostille and a notary?
Do I need both a notary and an apostille?
Who can apostille a document in the UK?
How long does the apostille process take?
Can a notarised document be used internationally?
What if my document is going to a non-Hague country?
What documents can be apostilled directly without notarisation?
How much does it cost to get a document notarised and apostilled?
Edward Young Notaries & Lawyers · 19 Wigmore Street, London W1U 1PH · +44 20 7499 2605 · notary@notarypubliclondon.co.uk
Faculty Office Registered Notary · STEP Qualified · ACSP Registered · Read our Google Reviews →
Need a Document Notarised or Apostilled?
Tell us what you need and where it’s going. We’ll confirm the process, quote you a fixed fee, and handle everything from notarisation through to apostille delivery.