Legalization
Apostille or legalization? The destination country decides.
One question first. Is the destination country a Contracting Party to the 1961 Apostille Convention? If yes, one apostille is the whole job. If no, an apostille does nothing for you. You need legalization, which is a longer chain and ends at that country’s embassy or consulate.
Verified 2026-08-19
People treat the apostille as a universal stamp. It is not. It is a treaty shortcut, and it works only between the countries that signed up. The treaty body counts 130 Contracting Parties. The rest of the world still runs the old chain.
Step one: check the country
The United States has been a Contracting Party since 15 October 1981, so your end of the test is already met. Only the destination is in question. Check it against the HCCH status table, which is the treaty body’s own list.
The list moves, so check it on the day you need it rather than trusting a blog post. China joined with effect from 7 November 2023. Canada joined with effect from 11 January 2024.
Country is a Contracting Party
You need an apostille. One certificate, issued here, and the destination must accept it without any further step. Then ask step two: who issued the document?
- ·Federal document, such as an FBI report: the U.S. Department of State, Office of Authentications, $20 per document.
- ·State document, such as a birth certificate: the Secretary of State of the issuing state.
Country is not a Contracting Party
You need legalization. Same first question about who issued the document, then more steps, and the last one is not a US office at all.
- ·A US authentication certificate instead of an apostille.
- ·A state certificate may need a further US Department of State certification on top.
- ·Then the destination country’s own embassy or consulate.
What legalization actually is
The word is defined in the treaty itself, and the definition is the reason the chain ends abroad rather than in Washington. Article 2:
“For the purposes of the present Convention, legalisation means only the formality by which the diplomatic or consular agents of the country in which the document has to be produced certify the authenticity of the signature, the capacity in which the person signing the document has acted and, where appropriate, the identity of the seal or stamp which it bears.”
Apostille Convention, Article 2. Read 2026-08-19 at hcch.net.
Read it slowly. The officials who legalize a document are the officials of the country the document is going to. No US office can do that step, and no US courier can either. That is why legalization takes weeks longer and costs more, and why the fee is set by a foreign government rather than by a price list.
The Convention exists to delete that step. The treaty body says so in one sentence: “The purpose of the Convention is to abolish the traditional requirement of legalisation, replacing the often long and costly legalisation process with the issuance of a single Apostille certificate.”
Two lists, and they are not the same list
USAGov tells you to check the “1961 Hague Convention member list”. The link goes to the HCCH Members page. That page lists the 94 states that belong to the organisation. It is not the list of countries bound by this treaty, and the two do not match in either direction.
| Country | HCCH Member | Bound by the Apostille Convention | So you need |
|---|---|---|---|
| Egypt | Yes | No | Legalization |
| Jordan | Yes | No | Legalization |
| Sri Lanka | Yes | No | Legalization |
| Morocco | No | Yes, since 14 August 2016 | An apostille |
Both lists read 2026-08-19: status table and members list.
This one costs money. Egypt, Jordan and Sri Lanka sit on the members list that USAGov points at. None of them is bound by this Convention. Follow that link, buy an apostille for a document going to Cairo, and you have bought a certificate the receiving office has no reason to accept. Check the status table instead.
The US rule, in the government’s own words
USAGov states the split in two sentences. This is the frame to use:
- “The country where you will use the document determines whether you will need an apostille or an authentication certificate.”
- “If the country where you want to use your document is on the 1961 Hague Convention member list, you will need an apostille. Documents such as vital records issued by a U.S. state will need an apostille from that state’s secretary of state. Federal documents will need an apostille from the U.S. Department of State.”
- “If the country where you want to use your document is not on the 1961 Hague Convention member list, you will need an authentication certificate.”
USAGov, Authenticate an official document for use outside the U.S.. Read 2026-08-19 at usa.gov. That page carries a last-updated date of 6 April 2026.
A state office says the same thing from its own side. New York calls the non-Convention document a certificate of authentication, and warns that it is often not the last step: “Certificates of Authentication may also require an additional certification from the United States Department of State prior to submission to the foreign country.”
What we do, and what we do not do
We sell apostilles. We do not do consular legalization. There is no legalization line on our price list and we are not going to add one we cannot run. The embassy leg depends on a foreign mission’s own forms, fees and appointment rules, and those are set per country. We have not read them, so we will not charge for them.
Every destination we publish today is a Contracting Party, so every customer we have is on the apostille side of the split:
- Spain, a Contracting Party since 1978
- Italy, a Contracting Party since 1978
- Germany, a Contracting Party since 1966
- Portugal, a Contracting Party since 1969
- Republic of Korea, a Contracting Party since 2007
- New Zealand, a Contracting Party since 2001
If your destination is not on the status table, here is the honest instruction. Do not order from us. Call or email that country’s embassy or consulate in the United States and ask for its document instructions in writing. Ask three things: what US certification it wants first, what it charges, and how long it takes. Then work backwards from your appointment date.
What we could not source. No US government page we could read sets out the full legalization chain end to end for a named country. USAGov stops at the authentication certificate. New York says a further US Department of State certification may be needed, without saying when. The last step belongs to the foreign mission and only that mission publishes it. We are not going to invent the missing part, so ask the embassy.
Separately, travel.state.gov answered 403 to every request we made on 2026-08-19, so nothing on this page is claimed from a fresh reading of it. The federal facts we publish still carry their 2026-08-04 reading.
Every source on this page
Common questions
What is the difference between an apostille and document legalization?
An apostille is one certificate, issued in the country where the document was made, and the destination country must accept it without anything further. It works only between Contracting Parties to the 1961 Apostille Convention. Legalization is the older chain it replaced. The Convention defines legalization as the formality by which the diplomatic or consular agents of the country where the document has to be produced certify the signature, so a document going to a country outside the Convention still has to reach that country’s embassy or consulate.
How do I know which one my document needs?
Check the destination country against the HCCH status table for the Apostille Convention, which lists 130 Contracting Parties. If it is there, you need an apostille. If it is not, an apostille does not apply and you need legalization. The United States has been a Contracting Party since 15 October 1981, so the United States end of the test is always met.
Who issues an apostille in the United States?
The office that issued the document. USAGov states that vital records issued by a U.S. state need an apostille from that state’s secretary of state, and that federal documents need an apostille from the U.S. Department of State. An FBI Identity History Summary is federal, so no state can apostille it.
Does ExpatPapers handle consular legalization?
No. We sell apostilles only. We do not run the embassy leg for countries outside the Apostille Convention, and we will not take money for it. If your destination is not a Contracting Party, contact that country’s embassy or consulate in the United States and ask for its own document instructions.
Is the list of Apostille Convention countries the same as the list of Hague Conference members?
No, and mixing them up sends documents to the wrong office. The HCCH has 94 Members. The Apostille Convention has 130 Contracting Parties. Egypt, Jordan and Sri Lanka are HCCH Members and are not Contracting Parties to this Convention, so an apostille does not cover a document going to any of them.
Going somewhere on the list?
If your destination is a Contracting Party, an apostille is all you need, and the only remaining question is which office issues it. That is the apostille guide.
We will tell you when your consulate changes the rules
Consulates revise their instructions without announcing it. When one of the posts we track changes a window, a fee, or what it asks for, we send a short note saying what changed and what it means. No more than that, and nothing else.
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