If you’ve been told your UK document needs an “Apostille” or “legalisation” and you’re not sure what the difference is, whether Brexit changed the rules, or which one your destination country actually wants, you’re in the right place.
Here’s the short version most guides won’t give you upfront: Brexit did not change the UK Apostille process itself. The Hague Apostille Convention is a separate international treaty that has nothing to do with EU membership. The UK has been a party to it since 1965, long before joining the EU and well after leaving it.
What changed after Brexit is how some EU member states receive UK documents in practice, the friction at certain consulates, and the volume of people suddenly needing legalisation for things they never had to before (work permits, residency applications, marriage certificates for EU partners, and so on).
This guide covers everything you need to know:
- The difference between an Apostille vs Legalisation
- Which one of your destination countries requires
- The exact FCDO process, current fees, and timelines
- Country-by-country acceptance, with EU-specific notes
- Document-type requirements (certificates, academic, legal, commercial, translated)
By the end, you’ll know exactly what to do and where Translations.co.uk can take it off your hands.
Key Takeaways: Post-Brexit Apostille vs Legalisation
- An Apostille is a simplified, single-step form of authentication, valid in any country that’s part of the Hague Convention 1961.
- Legalisation is a broader, multi-step authentication process used when the destination country isn’t part of the Hague Convention.
- You may need either an Apostille or full legalisation, depending on the destination country; not both.
- Post-Brexit, UK documents now require an Apostille for use in EU countries, a step that wasn’t needed between 2019 and 2020 under EU Regulation 2016/1191.
- FCDO fees start at £35 (e-Apostille) or £45 (paper) per document; turnaround ranges from 1–15 working days.
What Is an Apostille?
An Apostille is a special certificate or stamp that verifies the authenticity of a public document. A UK Apostille confirms the origin of the document and the authenticity of the signature, seal, or stamp of the official who issued or certified it. Thus, the document is legally recognised in any other country that is a part of the Hague Convention 1961. However, it does not verify or authenticate the content of the document.
What Is Legalisation?
Legalisation of documents refers to the process of authenticating a public document that is legally recognised in any country. Like the Apostille, it also confirms that an official authority has issued the document. It further confirms that the issuer’s authentication marks are genuine.
What Is Consular Legalisation?
Consular Legalisation, also called embassy legalisation or consular attestation, is the process by which a foreign embassy or consulate verifies and authenticates the signature, seal, or Apostille stamp of the public document. This is applicable when you deal with countries that are not Signatories to the Hague Convention of 1961.
Is Consular Legalisation the Same as Sworn Translation?
No, consular legalisation is not the same as a sworn translation, although the two can go together on a document‑translation package.
Sworn translation is an official translation made by a government‑recognised (“sworn”) translator who takes an oath before a court or notary that the translation is accurate and complete. Consular legalisation is a separate authentication step by an embassy or consulate that verifies and authenticates the signature and stamp of the translator or document.
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Apostille vs Legalisation vs Notarisation: What’s the Difference?
| Aspect/stage | Notarisation | Apostille | Legalisation |
| Purpose | To confirm the identity of the signatory and that the signature is genuine. | To authenticate the signature, seal, or stamp of a public official for use in another country. | To make a document legally acceptable abroad through one or more official authentication steps. |
| Who does it? | A Notary Public (or similar local notary). | A designated authority in the issuing country (e.g., FCDO in the UK, Ministry of Foreign Affairs). | Multiple authorities, often the issuing‑state authority plus an embassy/consulate of the destination country. |
| When is it used? | Mainly for domestic use or as a first step before going abroad. | For sending documents to Hague Apostille Convention countries (single‑step authentication). | For non‑Hague countries, or when the destination requires “embassy‑stamped” documents, even if an Apostille exists. |
| Scope of check | Confirms the identity of the signer and that the document was signed properly. | Confirms the authenticity of the official’s signature/seal, not the document content. | Confirms the authenticity of the issuing authority’s signature/seal, again, not the truth of the content. |
| Typical sequence | Often, the first step; some documents may go straight to Apostille/legalisation. | After notarisation (if needed), it replaces additional legalisation for Hague-Convention countries. | May follow notarisation and/or Apostille, then embassy/consulate stamp for non‑Hague destinations. |
Has Brexit Changed UK Apostille Requirements?
Yes. Brexit has changed when UK documents may need an Apostille, especially for use in EU countries. However, as already mentioned, it has not changed the UK Apostille process itself. The UK remains a party to the Hague Apostille Convention, and FCDO Apostilles are still issued in the same way.
What Actually Changed Legally?
The real change is not about FCDO, post-Brexit; the real change has been how European rules stopped applying to UK documents on 1st January 2021.
Before Brexit, the UK was covered by EU Regulation 2016/1191, known as the Public Documents Regulation. From 16 February 2019, this regulation abolished the Apostille requirement between EU member states for a defined list of public documents, including birth certificates, Apostille marriage certificate UK, divorce certificates, death certificates, certificates of no impediment, criminal record certificates, and a handful of other civil-status documents.
In practical terms, this meant that between February 2019 and December 2020, a UK birth certificate could be sent to Spain, Germany, France, or any other EU country without an Apostille at all. The receiving authority was legally required to accept it as authentic. The regulation also introduced multilingual standard forms that could replace certified translations in many cases.
What Has Changed After Brexit?
Loss of automatic recognition in some cases:
Before Brexit, many UK documents were accepted more easily in EU countries. After Brexit, some UK public documents may now need an Apostille for use abroad, depending on the destination country and the purpose of the document. Therefore, getting document translation services is essential.
Additional requirements in specific cases:
Some countries or receiving authorities may require a certified translation, notarisation, or further legalisation in addition to an Apostille. This depends on the local rules of the country where the document will be used.
Impact on business, education, and personal documents:
Brexit has increased the need for document legalisation in some cross-border situations. For example, UK birth certificates, degree certificates, and business documents may need an Apostille, and some documents may also require a certified translation, depending on the receiving authority’s requirements.
In short, Brexit has changed when UK documents may need an Apostille, particularly for use in EU countries. Whether a document also needs a certified translation, notarisation, or further UK document legalisation depends on the destination country and the receiving authority’s rules.
When Do You Need an Apostille vs Full Legalisation?
Use an Apostille when the document will be used in a Hague Convention country; use full legalisation when the destination country is not part of the Hague system, or when that country’s authority specifically asks for embassy/consular authentication.
Typical examples
If you need an Apostille degree certificate UK service, the document may need to be certified before it is submitted for Apostille legalisation. In some cases, a certified or sworn academic transcript translation service may also be required, depending on the destination country and the receiving authority’s rules.
For personal documents such as an Apostille birth certificate UK, the original or an official Apostille for a Translated Birth Certificate is usually needed before legalisation can begin.
Country-by-Country: Apostille or Legalisation?
The single most useful thing to know before you start is whether your destination country is part of the Hague Apostille Convention. If it is, an FCDO Apostille is enough. If it isn’t, you’ll need full consular legalisation through the destination country’s embassy or consulate in the UK.
The Hague Convention now has over 125 member countries, and the list has grown significantly between 2022 and 2024 — China, the UAE, Saudi Arabia, Canada, Pakistan, and Rwanda have all joined recently, which means many older online guides still incorrectly list them as non-Hague countries. The table below reflects the situation as of 2026.
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The FCDO Document Legalisation Process after Brexit
The UK Foreign, Commonwealth & Development Office (FCDO) Legalisation Office issues apostilles for public documents like birth certificates, degrees, and powers of attorney to verify signatures, seals, or stamps for overseas use.
Cost & Timeline
What CAN’T Be Apostilled by the FCDO
The FCDO will not apostille:
- Documents issued outside the UK — these must be apostilled in the country of issue
- Photocopies that haven’t been certified by a UK solicitor or notary
- Standalone original passports (only certified copies)
- Documents signed by people not registered with the FCDO
- Documents from Jersey, Guernsey, or the Isle of Man (see below)
Crown Dependencies — Jersey, Guernsey, Isle of Man
For Jersey, Guernsey, and the Isle of Man, the key point is that these are Crown Dependencies, and documents issued there are generally not apostilled by the UK FCDO; they are usually handled by the relevant local authority instead.
- Civil documents issued in Jersey, Guernsey, or the Isle of Man, such as birth, marriage, or death certificates, are typically not processed by FCDO for apostille.
- Public documents originating in those Crown Dependencies usually need an Apostille or legalisation from the local competent authority first.
- If a document is already issued and legalised in a Crown Dependency, the UK FCDO usually does not re-issue an apostille for that same document simply because it will be used abroad.
EU Member State Acceptance of UK Apostilles
All EU member states, as Hague Convention parties, accept UK apostilles from the FCDO for simplified authentication instead of full legalisation. However, post-Brexit, countries like Italy, Spain, and Denmark often require extra consular attestation or official Legal Translation Services UK after the apostille for visas, residency, or work permits.
Always confirm with the destination authority, as acceptance varies by document and purpose; non-EU Hague countries treat them as before.
Apostille and Legalisation by Document Type
|
Document Type |
Examples |
Paper Apostille |
e-Apostille Eligible? |
|
Vital Records |
Birth, marriage, and death certificates |
Yes |
No |
|
Court/Administrative |
Divorce decrees, Companies House certificates |
Yes (originals) |
Varies |
|
Educational |
Degree certificates |
Yes |
Yes (certified copy) |
|
Police/Background |
ACRO, DBS checks |
Yes (originals only) |
No |
|
Private/Copies |
Power of attorney, passport copies, bank statements |
Yes |
Yes (most) |
How to Apostille a Document? — Step by Step
Step 1: Check eligibility
First, confirm the document is eligible for legalisation and whether the recipient needs a paper apostille or an e-Apostille. UK guidance says some documents can be legalised as paper-based or electronic, and the recipient may specify which format they accept.
Step 2: Prepare the document
Make sure you have the correct version of the document. Original civil certificates may be accepted directly, while academic, business, or copied documents often need certification by a solicitor or notary first.
Step 3: Apply to the FCDO
Submit the document through the UK Legalisation Office / FCDO online service. For paper-based apostilles, you send the document by post unless you are an authorised business; for e-Apostilles, you upload a PDF signed by a UK notary or solicitor and fill out a simplified form.
Step 4: Pay the fee
Step 5: Receive the Apostille UK
Once processed, paper documents are returned by courier or post, and e-Apostilles can be downloaded and shared digitally. If the destination country is not a Hague Convention country, the apostilled document may still need embassy legalisation afterwards.
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Frequently Asked Questions
Who can Apostille a document UK?
In the UK, only the Foreign, Commonwealth & Development Office (FCDO) Legalisation Office is authorised to issue an Apostille certificate. They verify the authenticity of signatures, stamps, or seals on UK public documents for use in countries that are part of the 1961 Hague Convention.
How much does it cost to get an Apostille in the UK?
The price of our Apostille services in the UK starts from £82 per document, with solicitor certification included from £94 when your document requires it. All prices cover FCDO Apostille submission and full order tracking; there are no hidden fees.
Is legalisation and authentication the same?
Legalisation is a broad form of verification for documents issued overseas; authentication verifies signatures, but an Apostille provides a single-step process for member countries, unlike a multi-step diplomatic process for non-member states.
Who can authorise a certified translation?
In the UK, a certified translation can be issued in two ways. First, a professional translator or translation company can certify the translation themselves by attaching a signed Statement of Truth confirming the accuracy of the work, which is accepted by UKVI, Home Office, and most domestic UK authorities. Second, for use overseas or for stricter authorities, the translation can be notarised by a UK Notary Public or certified by a solicitor, which adds an additional layer of verification.
How long does an Apostille take in the UK?
The FCDO postal service for paper apostilles typically takes 10–15 working days from receipt. Through a registered next-day service provider, this can be reduced to 1–3 working days. The original document must always be submitted; photocopies are not accepted unless certified by a UK solicitor or notary.
Can I get an Apostille on a translated document?
Yes. The FCDO can apostille a translated document, but only if the translation has been certified or notarised by a UK solicitor, notary, or other recognised UK professional. Foreign-language documents themselves cannot receive a UK Apostille; they must be apostilled in the country where they were issued.
Do I need both an Apostille and a certified translation?
In most cases, yes. The standard process is to apostille the original English document first, then have the apostilled version translated by a certified or sworn translator (depending on the destination country’s requirements). Some receiving authorities accept either order, so always confirm with the recipient before starting.
Is an Apostille valid forever?
An Apostille itself does not have an expiry date; once issued, it remains valid indefinitely. However, the underlying document may have its own validity period, and some foreign authorities require apostilled documents to have been issued within the last 3, 6, or 12 months. Always check the receiving authority’s specific requirements.
Does the UK accept apostilles from other countries?
Usually yes, if the apostille was issued by a Hague Convention country and the document is being used in the UK, the apostille is meant to verify the origin of a public document for international use.
Can I get an apostille on a digital document?
Sometimes yes, but only for eligible documents signed electronically by a UK notary or solicitor. Several common document types are not eligible for the e-Apostille service, including all General Register Office (GRO) certificates (birth, death, marriage, civil partnership, adoption) and certain police certificates such as ACRO and DBS checks. These still require the paper Apostille route.
What’s the difference between an Apostille and embassy attestation?
An apostille is the Hague Convention route used between member countries, while embassy attestation is the extra consular/legalisation route used for countries outside the Hague system.
Do I need to legalise documents going to Ireland?
Irish documents often need an Apostille when they are being used abroad, and Ireland is part of the Hague system, so an Apostille is commonly the right route rather than embassy legalisation.
Can I apostille a Scottish document through the FCDO?
Yes, Scottish public documents are generally handled through the UK legalisation system if they are eligible and properly issued; the UK service legalises documents by attaching an apostille.
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