Schmidt & Schmidt covers the full spectrum of legalization services for documents issued in China.
China acceded to the Hague Convention Abolishing the Requirement of Legalization for Foreign Public Documents on March 8, 2023, and the convention came into force on November 7, 2023.
The apostille, or the “Hague apostille” is a certificate that authenticates the origin of a public document (e.g., a birth, marriage or death certificate, a judgment, an extract of a register or a notarial attestation). It confirms the authenticity of the signature and the authority of an official who signed the public document.
In China, an apostille takes the form of a sticker with text in French, English, and Chinese, featuring an apostille number and QR code for verification, along with a special silver seal. It can only be affixed within the country where the document was issued.
Prior to 2023, using Chinese documents abroad required consular legalization — a multi-step process involving authorized translation, notarization, certification by China's Ministry of Foreign Affairs, and consulate legalization. This procedure still applies for countries that have not ratified the Hague Convention.
Chinese documents bearing an apostille are recognized in all 125 Hague Convention member states without any additional certification, significantly reducing the time and cost of document authentication.
Restrictions on apostilling documents in China
India officially opposed China’s accession to the Apostille Convention on September 8, 2023. As a result, China and India do not recognize each other’s apostilles. Additionally, upon joining the Convention, Beijing stated that it will only accept apostilles from countries that it officially recognizes. Therefore, the apostille procedure is not applicable between China and Kosovo.
Apostille in Hong Kong and Macau
Hong Kong and Macao have acceded to the Hague Convention Abolishing the Requirement of Legalization for Foreign Public Documents. In 1997, China confirmed the validity of the Convention for Hong Kong, in 1999 - for Macao.
Upon accession to the Convention, official Beijing specified that in the Hong Kong and the Macau, which joined the Apostille Convention before being considered part of China, the previous apostille procedure would remain in effect, different from the procedure applied in mainland China. However, Hong Kong and Macau also accept apostilles only from countries recognized by the central authorities of China.
Mandatory details of an apostille in China
- Inscription in French – "Apostille" and reference to the 1961 Convention;
- Name of the country (PRC);
- Name of the person who signed the official document or notarial certificate;
- Position of the person who signed the official document or notarial certificate;
- Name of the organization that affixed the seal or stamp on the official document or notarial certificate;
- Place of apostilling;
- Date of apostilling;
- Name of the authority that performed the apostille;
- Apostille number;
- Seal of the authority that performed the apostille;
- Signature of the authorized official who performed the apostille.
Apostille register in China
China operates an electronic apostille register, where authenticity can be verified online by apostille number.
Designated competent apostille authorities in China
The authority authorized to apostille documents in China is the Ministry of Foreign Affairs of the PRC.
Within it, documents are certified with an apostille by the Legalization Service of the Ministry of Foreign Affairs, as well as, within the relevant administrative units, by the regional offices of the Foreign Affairs Department in each province.
Types of documents
| Can be certified | Cannot be certified |
|---|---|
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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 your academic certificate to the education department for education certification. The education department will verify your academic certificates and confirm their legal status in the country. This procedure may require the applicant to provide some relevant documentation.
- If necessary, applicants may be required to submit a copy of their academic certificate to the Ministry of Justice of China for notarization.
- Submit academic certificates to the Ministry of Foreign Affairs. The Ministry of Foreign Affairs will stamp your academic certificate with the official seal of Apostille.
- Send the certified academic certificate to the target country’s embassy or consulate in China for final certification.
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.
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.
| Apostille | Consular legalization | |
|---|---|---|
| Legal effect | Can be used in all countries that are party to the Hague Convention on the Simplified Legalization of Documents. | Use between States one or both of which is not a member of the Hague Convention, or where one of the contracting States has protested the accession of the other. |
| Difficulty | Moderate. To obtain an apostille, contact the competent apostille authority of the state of origin of the document. | High. For consular legalization, various inland authorities and a diplomatic mission of the state of destination must be involved. |
| Pre-certification | Usually not required. | Is obligatory. |
| Attestation at the state of destination embassy in the state of origin of the document | No need to contact the Consulate of the country of destination. | Is the final step of legalization. |
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.
