Apostille and consular legalization of documents in China

Schmidt & Schmidt covers the full spectrum of legalization services for documents issued in China.

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.

Apostille in China takes the form of a sticker labeled "Apostille" with a reference to the 1961 Hague Convention in French (Convention de La Haye du 5 octobre 1961). The text on the apostille is duplicated in English and Chinese and also includes the apostille number and a QR code, which allow for authenticity verification. A special silver seal is attached to the sticker.

An apostille stamp can only be affixed within the territory of the country where the document was issued.

Until 2023, the use of foreign documents in China and Chinese documents abroad required a consular legalization procedure. This is a complex and multi-step process, which includes steps such as: translation of the document by an authorized translator, notarization of the translation, certification of the document at the Chinese Ministry of Foreign Affairs, and subsequent legalization at the consulate of the country where the document is to be used.

For countries that have not ratified the Hague Convention, this procedure for using Chinese documents still applies.

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.

Documents issued in China and certified with an apostille, in accordance with the 1961 Hague Convention, are recognized in all countries that are parties to the Hague Convention and do not require any other form of certification, such as consular legalization. This significantly reduces costs and time spent on document authentication. As of today, 125 countries have acceded to the convention.

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

Procedure for apostilling documents in China

Step 1: Notarization

An important stage of preparation is notarization of the document. In China, an apostille is never affixed to original documents, only to notarized copies. There are two types of notarization: single notarization and double notarization. The type of notarization depends on the country where the document will be used, so it is important to inform the notary in advance of the destination country so that the document can be prepared correctly.

A notary in China can notarize only documents issued in Chinese; they are not authorized to notarize documents in foreign languages. Therefore, it is essential that the original text is in Chinese. This issue most often arises when attempting to notarize powers of attorney or certificates from international schools or universities. Even if a university or school has issued an English-language version of the document, it cannot be notarized; only the original Chinese version can be used.

Translation into a foreign language is a mandatory part of the notarial certificate intended for use abroad and is included in the procedure for preparing the notarial certificate. As a result, you will receive a single notarial certificate containing the notarized document and the notarized translation, on which one apostille will later be affixed.

BUT! Be prepared in advance that this translation may not be accepted abroad! It is very important for you to check the requirements of the receiving authority. Often (if not always), an additional notarized translation by a certified translator or a notary in the destination country is required.

The validity period of some Chinese documents is only 3 months. If you do not clarify the translation requirements with the receiving authority in advance, it may be necessary to re-request, notarize, legalize, and send the document again, which entails significant time and financial costs.

The notarization timeframe largely depends on the volume of the translation and is usually around 5 work days.

Please note: if your document was issued, for example, in the city of Wuxi, Jiangsu Province, you may obtain a notarized copy (certificate) in any other city in China, BUT the apostille can only be affixed by the Ministry of Foreign Affairs office to which the notarial district is assigned.

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.

Apostille in Hong Kong and Macao

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. Therefore, no diplomatic authentication or consular legalization of documents from Hong Kong and Macao is needed for successful legal communication with other member states of the Convention. The documents only need to be attested by an apostille certificate with an "apostille" stamp on it by the issuing state's authorities in order to be valid in the state of destination.

Legalization of Chinese educational documents for use abroad

People who study and work abroad need to apply for apostille certification to ensure that their academic qualifications and other related documents are authenticated. The certified document can be used in 125 countries or regions that have signed the Hague Convention, and it is fully recognized.

Educational documents issued in China, such as school reports, university degree certificates, transcripts of records, enrollment certificates and other certificates from schools or universities are not effective abroad until they are certified with an apostille. For example, an apostille for your foreign degree may be required to apply for a Master's or a PhD degree program.

To obtain an apostille of your academic certificate, you first need to ensure that your academic certificate is legal and valid, issued by a relevant educational institution and obtained through formal procedures. Usually, you may need to follow these steps:

• 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.

Consular legalization of Chinese documents for use abroad

Should a Chinese document be used in a country that does not recognize the Hague Convention, such as the United Arab Emirates or other countries not listed as a contracting party, the procedure of consular legalization, also called “embassy attestation”, applies. For a complete list of countries that accept and use apostilles, click here.

The necessary pre-requisite for the consular legalization of a document originating from China is its issuance by a public notariat of the People's Republic of China explicitly for use abroad. The notary should then issue a notarial document on the basis of the original containing a notarially certified copy of the original as well as a confirmation of its authenticity. The notary certified documents must then be certified by the Office for Foreign Affairs responsible for the notary's official residence. Finally, the document is eligible for the legalization by the Consulate General.

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. Whereas apostille is usually issued within one step, consular legalization requires several pre-certifications before a public document can be certified at the embassy or consulate of the destination country in China.

It is a common requirement that the document has to be translated into the official language of the destination country before submission to the embassy. It is up to the diplomatic mission to decide about the authentication procedure.

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.

Procedure for consular legalization of documents in China

A document issued by state or provincial authorities of China, or executed by a Chinese notary, and intended for use in a country that is not a party to the Hague Convention of 5 October 1961, 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.

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.