Updated

GL-N-08

Glossary · Documents and legalization

Notarization

Full glossary
1st stepin the legalisation chain
signaturenot the content of the document
formdepends on the country

01 / In 30 seconds

The short answer

What it is
Certification by a notary of a signature, a copy of a document or a fact
What it confirms
That the signature was made by this particular person, or that the copy matches the original
What it does not confirm
That the content of the document is true — the notary does not check the facts on the merits
Why it is needed
It is often the first step before an apostille and legalisation
What matters
The form of certification must meet the receiving country’s requirements

02 / In plain words

What Notarization means

Notarisation is certification by a notary of a particular fact: that a signature on a document was made by this particular person, that a copy matches the original, or that a document was signed in the notary’s presence. Put simply: the notary vouches for the form and for the person’s identity, not for the content.

This is an important distinction. When certifying a signature on a statement, the notary does not check whether the text is true: the signatory is responsible for its accuracy. When certifying a copy, the notary confirms that it matches the original, not that the document itself is lawful. Understanding this boundary removes many false expectations.

In international procedures a notarial act is usually the first step in a long chain: certification, then an apostille or consular legalisation, then translation. Form requirements differ from country to country, so before visiting a notary you confirm exactly what must be certified and with what wording — redoing it costs more than asking.

A case from practice

A client had copies of documents certified, but the programme required certification of the signature on an application in a specific form. The set was returned. One clarifying question before visiting the notary would have saved a trip and a week.

When a notary is needed

  • Certifying copies of documents
  • A power of attorney for a representative
  • The other parent’s consent for a child to travel
  • Statements and affidavits
  • A company’s constitutional documents
  • Real estate transactions

03 / What it covers

What a notary certifies

01

Identity

  • Who signed the document
  • The signatory’s legal capacity
  • That it was signed in their presence
02

Copies

  • Match with the original
  • Completeness of the copy
  • Certification mark
03

What it does not do

  • Does not check whether the text is true
  • Is not responsible for the content
  • Does not guarantee the document will be accepted
04

Form

  • The receiving country’s requirements
  • The language of the certification wording
  • Government fee

04 / How it works

How it usually works

Step 1

Confirm the authority’s requirements

Step 2

Prepare the document and passport

Step 3

Notarisation

Step 4

Apostille where required

Step 5

Translation and filing

05 / Key facts

What you need to know

01

A notary certifies a signature or a copy, not the truth of the text

02

The form of certification depends on the receiving country’s requirements

03

A notarial act is often the first step before an apostille

04

The original and a passport are usually required

05

Foreign documents may need to be translated before certification

Common mistakes

  • Going to a notary without confirming the authority’s requirements
  • Expecting the notary to check the content of the document
  • Certifying a copy when the original is required
  • Not taking into account the language of the certification wording
  • Assuming that certification automatically gives recognition abroad

06 / Expert advice

Anna Kovalevskaya

How to prepare in advance

Before the visit, find out from the receiving side exactly what must be certified — a signature, a copy or the document itself — and with what wording. Bring the originals and your identity document. If the document is going abroad, plan the next steps straight away — the apostille and translation — so as not to go to the notary twice.

What we do for you. We give the client a precise list: which document, in what form and with what wording to certify. This removes the most common scenario — when a person has done everything conscientiously but not in the form the receiving side expects.

Anna KovalevskayaLead lawyer for EU citizenship and residency, 12 years of practice

07 / Questions

Frequently asked questions

A particular person’s signature, that a copy matches the original, or that an act was performed in the notary’s presence. The notary does not check the content of the document on the merits.

The signatory is responsible for the accuracy of the content. The notary vouches for the form and the person’s identity, and this is important to understand.

For use abroad — as a rule, yes. A notarial act on its own does not make a document recognised in another country.

It depends on the country’s rules and the language of the document. Sometimes a translation is required first. This is confirmed in advance.

The original documents and your identity document. The exact list depends on the type of notarial act.

No. The receiving authority looks at the whole set: the form, the legalisation, the translation and compliance with its own requirements.

Author: Anna Kovalevskaya

Reviewed by: Sergej Evdokimov

Sources: HCCH — the Hague Apostille Convention

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Anna Kovalevskaya, lead lawyer at BRIDGES GLOBAL
Anna KovalevskayaLead lawyer, citizenship and residency, 12 years of practice