Apostille and legalisation for a property purchase abroad

A foreign land registry, notary or developer will not take your documents on trust. They want proof that a stamp or signature on a paper from your country is real. That proof is called an apostille or, where there is no Hague treaty, legalisation. Getting it wrong is the most common reason for a closing date slipping by weeks. This article explains the two systems, what the EU rules change and do not change, and how to plan the paperwork. It is informational, not legal advice, and rules change, so confirm the list for your destination with the local lawyer before ordering anything.

Apostille and legalisation: the difference

An apostille is a single certificate attached to a public document (a notarial deed, a court or registry extract, a civil-status certificate) by a designated authority of the country that issued it. It confirms the signature, the capacity of the signatory and the seal. It works between countries that are parties to the Hague Convention of 1961. The Hague Conference lists 130 parties on its status table (updated 30 June 2026).

Full legalisation is the older chain used when one of the two countries is not a party. In outline: the document is certified by a national authority (usually the foreign ministry) and then by the embassy or consulate of the destination country. It takes more steps, more time and often more money, and each step has its own rules. Steps vary by country, so ask for the exact chain.

Which destinations accept which

Examples we checked on the Hague status table on 12 October 2026:

• Turkey and Georgia are parties (in force since 1985 and 2007), so an apostille is the normal route. Cyprus, Greece and Bulgaria are parties as well.
• Thailand deposited its accession on 30 June 2026, but the Convention enters into force for it only on 28 February 2027. Until then Thailand-bound documents are expected to follow the older consular route, and Thai authorities may publish transitional rules. Check the current practice with your Thai lawyer.
• The United Arab Emirates was not listed as a party when we checked. Documents for use in the UAE have been handled through a chain that ends with UAE embassy or consulate legalisation and attestation by the UAE foreign ministry. We could not confirm a current official description, so ask the Dubai or Abu Dhabi lawyer for the exact steps and whether the status has changed.

Do not rely on a list from a blog or a forum. The status table is the reference, and it does change.

What the EU rules change

Inside the EU, Regulation (EU) 2016/1191 (applicable since 16 February 2019) removes the apostille and legalisation requirement for certain public documents, for example birth, marriage, death, residence and criminal-record certificates and proof of company representation. It also offers multilingual standard forms that reduce the need for translation. See the regulation text and the European e-Justice portal.

What it does not do: it covers only the listed kinds of documents and only between EU states. As reported by practitioners, a notarial power of attorney or a contract is not on the list, so an apostille may still be required for those even between two EU countries. It also does not help for Turkey, the UAE or Thailand. And exempt documents still may need a translation, because the authority is allowed to ask for one.

Where to get an apostille in your EU country

Authorities differ, and the exact office depends on the document. In general terms:

• Poland: the Ministry of Foreign Affairs issues apostilles for Polish documents. A notarial document is first certified by the competent regional court. A stamp duty is charged; check the current amount on the ministry's page.
• Germany: for notarial deeds the president of the regional court (Landgericht) issues it, federal documents go to the Federal Office for Foreign Affairs, and state documents are handled by state authorities. If you are unsure, ask the body that issued the document.
• Other EU states: usually a ministry of foreign affairs or justice, a court or a notary chamber. Search for "apostille" plus the country name on the government portal.

A common sequence is: get the document (or notarise your own signature), then apostille, then sworn translation into the destination language. Ask the receiving side whether the translation must be done before or after the apostille, because some authorities want the translator's certification apostilled too.

Sworn translations

Most destinations want a translation by a sworn or certified translator, sometimes one registered in that country. Rules differ on whether the translator must be local, whether the translation is attached to the original and apostilled together, and whether a stamped copy is enough. Ask first and keep the translator's contact details.

Validity of documents

There is no single rule. The receiving authority decides how old a certificate may be; extracts and certificates of marital status or clean record are often accepted only if they are recent, and a power of attorney can have its own limit. We found one report that Dubai asks for a foreign power of attorney issued within the previous two years, but we could not confirm it from an official text. Ask the lawyer for the exact period in writing and plan the order so that nothing expires before closing.

Common mistakes

• Apostilling a copy instead of the original or a notarial copy.
• Ordering the apostille from the wrong authority and being sent back.
• Translating first and apostilling later, then finding that the translation also needed a stamp.
• Assuming that EU residence means no formalities: the exemption has limits.
• Leaving it to the last week. Fees vary and we do not quote them; ask each office.

FAQ

Is an apostille the same as notarisation? No. A notary attests a signature or a document, and the apostille then confirms that the notary or official is genuine. Do EU citizens never need an apostille? Not true: it is only waived for the document types in Regulation 2016/1191 and only inside the EU. What if the country is not a Hague party? Then full legalisation applies, usually through the destination country's embassy or consulate. Who pays for translation? The buyer, normally. Does an apostille expire? The stamp itself does not, but the receiving authority may refuse an old underlying document. Can the lawyer arrange this remotely? Usually yes, with a power of attorney; see our guide to the power of attorney.

How we help

We are a trilingual platform that finds properties and coordinates independent local lawyers and tax advisers. We help you build the document list for your country before you pay a reservation fee. See also our pre-purchase checklist and buying remotely. This text is informational and is not legal, tax or investment advice; verify current rules with the authority or a licensed lawyer.