Apostille and consular legalization of documents in China

Schmidt & Schmidt provides comprehensive legalization and apostille services for documents issued in China. We assist private individuals and companies with the preparation of Chinese documents for use abroad, including notarial certification, translation, apostille, consular legalization where required, and international courier delivery.

Chinese documents such as birth certificates, marriage certificates, diplomas, academic transcripts, police clearance certificates, business licenses, company documents and powers of attorney often need to be formally certified before they can be submitted to foreign authorities, universities, courts, banks, immigration offices or business partners.

An apostille is a certificate that confirms the authenticity of the signature, seal and authority of the official who signed or certified a public document. It does not certify the content of the document itself, but confirms its formal origin for international use.

In China, an apostille is issued as an additional certificate attached to the document package. It usually contains text in Chinese, English and French, an apostille number, a verification QR code and a special seal. As a rule, the apostille must be issued in the country where the document was originally prepared or notarized.

Consular legalization may still be required if the document is intended for use in a country that is not a party to the Hague Apostille Convention. The correct procedure therefore depends on the destination country, the type and language of the document, the presence of signatures and seals, and the requirements of the receiving authority abroad.

What does a Chinese apostille look like?

A Chinese apostille is issued as an additional certificate attached to the notarial or official document package. It confirms the authenticity of the signature, seal and authority of the official who signed or certified the document. It does not certify the content of the document itself.

A Chinese apostille normally contains the following details:

• the title “Apostille” and reference to the 1961 Hague Convention;
• the country of issuance, namely the People’s Republic of China;
• the name and capacity of the person who signed the public document or notarial certificate;
• the name of the authority or organization whose seal or stamp appears on the document;
• the place and date of apostille issuance;
• the name of the competent authority issuing the apostille;
• the apostille number;
• the seal and signature of the authorized apostille officer.

In mainland China, apostilles are issued by the Ministry of Foreign Affairs of the People’s Republic of China and by authorized local Foreign Affairs Offices within their respective administrative areas.

Which Chinese documents can be apostilled?

A wide range of Chinese documents can be prepared for apostille certification, provided that they can be converted into the proper notarial or official certificate format required for international use.
The most common categories include civil status documents, educational documents, police clearance certificates, and corporate or commercial documents.

The key question is not only whether the document exists, but whether it is suitable for notarisation or official certification in China.
Private documents should normally bear valid signatures and seals, while documents issued by public authorities, schools, registration bodies or other institutions should have a formal official format.
In most cases, the source document used for preparing a Chinese notarial certificate should also be in Chinese.

Procedure for apostilling documents in China

Step 1: Notarization

In China, an apostille is never affixed to original documents — only to notarized copies. There are two types of notarization (single and double), depending on the destination country, so inform the notary of this in advance.

Chinese notaries can only notarize documents issued in Chinese. If the original is in a foreign language (e.g., certificates from international schools or universities), it cannot be notarized — only the Chinese version is accepted.

A translation into the required foreign language is included in the notarial certificate as a mandatory part, so you will receive a single certificate with both the notarized document and translation, to which one apostille will be affixed.

Important: This translation may not be accepted abroad. Always check requirements with the receiving authority in advance, as an additional certified translation in the destination country is often required. Some Chinese documents are only valid for 3 months, so failure to clarify requirements early may result in the entire process needing to be repeated at significant cost.
Notarization typically takes around 5 business days, depending on translation volume.

Notarization of certificates, contracts, invoices, and other commercial documents

The legalization procedure for commercial documents is carried out not through a notary, but through the China Council for the Promotion of International Trade (CCPIT). Each province has its own CCPIT office, and applications must be submitted at the place where the document was issued or where the company to which it was issued is registered. The document must be issued in Chinese; contracts and other commercial documents must bear the company seal and the signature of the company’s legal representative.

To legalize such documents, a business license and the ID card of the founder (legal representative) of the Chinese company will be required. After that, the procedure is similar to notarization through a notary.

Step 2: Apostille issuance by the Ministry of Foreign Affairs

No prior appointment is required to obtain an apostille from the Ministry of Foreign Affairs. To have an apostille affixed, it is sufficient to visit the Foreign Affairs Office of the region where the notarial certificate was issued and submit the document through the electronic queue system.

The standard apostille processing time at the MFA of the PRC is 5 work days; however, if an express service is requested, it can be reduced to 3 work days (excluding delivery time).

When submitting documents for apostille, the applicant must confirm their identity. If the documents are submitted by an organization, the person submitting them is required to provide the original power of attorney and a copy of the valid passport of the document owner.

China’s electronic apostille

As of June 18, 2025, China has launched a pilot electronic apostille system (e-Apostille). The first document that can be apostilled in digital form is the electronic “Certificate of Origin” issued by the China Council for the Promotion of International Trade. Holders of such certificates should submit them to the Legalization Service of the Ministry of Foreign Affairs of the PRC.

In the future, the procedure will be gradually extended to other types of PRC documentation. At present, the system is available only to Chinese citizens who possess a local ID card.

Legalization of Chinese educational documents for use abroad

People studying or working abroad need an apostille to authenticate their academic credentials. Apostilled documents are recognized in all 125 countries party to the Hague Convention.

Chinese educational documents — including school reports, degree certificates, transcripts, and enrollment certificates — are not valid abroad without an apostille. For example, one may be required when applying for a Master's or PhD program.

Steps to obtain an apostille for an academic certificate:

• Apply to the academic certificate issuing institution to obtain an original document or official copy of the academic certificate. Make sure the copy has the institution's official seal and signature and is a true copy of the original.
• Submit the academic certificate to a notary. In China, an apostille is typically not affixed directly to the original document, but to a notarized certificate. The notary verifies the document (often based on a scanned copy), issues a notarization certificate, and, if necessary, attaches a translation.
• If necessary, applicants may be required to submit a copy of their academic certificate to the Ministry of Justice of China for notarization.
• Submit the notarized document to the competent authority (usually the Ministry of Foreign Affairs of China or authorized local authorities) for apostille. The authority will verify the notarization and affix the apostille to the notarial certificate.

It should be noticed that different countries may have different certification requirements for academic certificates, so it is best to consult the professional agencies or embassies of the target country in advance.

Legalization of Chinese Police Clearance Certificate for use abroad

A Chinese Police Clearance Certificate (Certificate of No Criminal Record) must undergo legalization before it can be used in a foreign country. The exact procedure depends on the destination country, but generally includes several mandatory steps.

1. Notarization — the certificate is notarized by a Chinese notary public, typically combined with an official translation. Specify the destination country at this stage, as requirements may vary (single or double notarization).

2. Legalization — depending on the destination country:

• Apostille: If the destination country is a party to the Hague Convention, the notarized certificate is submitted to the Ministry of Foreign Affairs of China or its local offices for issuance of an apostille.
• Consular legalization: If the destination country is not part of the Hague Convention, the document must be further legalized at the consulate of the destination country in China after notarization.

The process typically takes 10–14 days, after which the document can be used for visa applications, employment, or immigration purposes.

Note: Some foreign authorities may require an additional certified translation in the destination country. Since the certificate is usually valid for only three months, careful advance planning is essential.

What can go wrong when applying for an apostille in China on your own?

At first glance, the apostille procedure in China may seem straightforward: prepare the document, submit it to the competent authority and wait for the result. In practice, however, many problems arise before the apostille is even issued — during document preparation, notarisation, translation or submission.

• 1

  Wrong type of notarisation

  The notary or certification body must know that the document is intended for use abroad and in which country it will be submitted. If the wrong type of notarial certificate is prepared, the document may not be accepted for apostille or by the receiving authority abroad.

• 2

  Document not suitable for certification

  Some documents cannot be used as a basis for a Chinese notarial certificate or commercial certificate. Problems may arise if the document is not in Chinese, lacks a proper signature or seal, or was not issued in an official format.

• 3

  Translation may not be accepted abroad

  A translation is often included in the Chinese notarial certificate package. However, this translation may not always replace a certified or sworn translation required by the receiving authority in the destination country.

• 4

  Wrong place of submission

  The apostille route usually depends on where the notarial certificate or commercial certificate was issued. Submitting the document through the wrong regional procedure may lead to delays or rejection.

• 5

  Validity period problems

  Some Chinese documents, such as police clearance certificates or certain official certificates, may be accepted only within a limited period. If the procedure is started incorrectly or too late, the document may expire before it can be used abroad.

• 6

  Requirements of the destination country are overlooked

  Even if the apostille is issued correctly in China, the receiving authority abroad may have its own requirements regarding the language, document format, date of issue, notarisation type or additional certified translation.

Foreign Affairs Offices by Province

The following list provides a compact overview of authorized local Foreign Affairs Offices in mainland China.For apostille procedures, the competent office usually depends on the place where the document or notarial certificate is issued.

Consular legalization of Chinese documents for use abroad

For countries that are not parties to the Hague Convention (e.g., the UAE), consular legalization — also known as "embassy attestation" — applies instead of an apostille. For a complete list of countries that accept and use apostilles, click here.

Consular legalization is the process of authenticating or certifying a legal document so a foreign country's legal system will recognize it as with full legal effect that is carried out by the diplomatic or consular mission of the country in which the document is to be used.

Consular legalization is more complex, time-consuming and costly than the simpler apostille procedure. A document must:

• be translated by an authorized translator into the language of the country where the document will be used;
• have the translation notarized by a notary in China;
• be certified by the office of the Ministry of Foreign Affairs of China;
• be legalized by the consulate of the destination country in China.

Only after completing these procedures will the legalization of the document be considered complete, and the document may be used in the destination country.

It is important to remember that a document will have legal force only in the territory of the country whose consular stamp appears on it and cannot be used in other countries.

The validity period of consular legalization is generally not limited; however, restrictions may apply to the validity period of the documents themselves.

The main differences between an apostille and consular legalization of documents

The common feature between apostille and consular legalization is that they authenticate an official document for presentation to institutions in another country. However, they have many differences.

Procurement of documents from China

If the important documents are lost or damaged, or current copies of the documents are needed, the re-issue of the documents is required. It is not unusual for people outside China to encounter difficulties with obtaining new documents when abroad. Our consultants will help you procure new documents from China remotely, and we can arrange for your documents to be sent by courier anywhere in the world.

Certified translation of documents from China

In China, there is no separate service for notarized translation — a translation acquires legal force only as part of a notarial certificate (公证书). Translations performed by ordinary or “certified” translators in China are not recognized abroad if they are not included in a notarial certificate.

Therefore, if the destination country specifically requires a translation, it is recommended to have the translation done directly in the country where the document will be used, in accordance with local requirements.

Does the translation have to be apostillized?

Any foreign document issued in one country and used in another country must be legalized for use abroad. Therefore, the authenticity of a certified translation from China needs to be certified by an apostille. Consequently, many authorities may not accept certified translations from China if the translation has not been properly authenticated in China for use abroad. To avoid this confusion, translations should better be made in the state of destination of the document.