- Mistake #1 we see every week
- The rule: apostille on the original, BEFORE translation
- Why this rule: the territorial principle
- The exception: an "apostille on a translation" by a French Court of Appeal
- The correct order in 4 steps
- Special cases: China, non-apostille countries, the EU
- Frequently asked questions
Every week, we receive at least one call that starts with: "I had my document translated, and now the prefecture is asking for the apostille — where do I get it?" The answer always comes as a surprise: nowhere, because it will have to be redone. The apostille is not affixed to the translation, it is affixed to the original, and that must happen before translation. Here's why — and the rare exceptions.
Mistake #1 we see every week
The typical scenario: a foreign national arrives in France with their birth certificate. They have it translated into French by the first sworn translator they find. They submit their file to the prefecture. The response at the counter: "the apostille is missing." They then go hunting for the apostille, and run into one of two possible frustrations:
- Frustration #1: they request the apostille on the French translation. The French authority refuses (Court of Appeal or BFM) — a translation is a private document that cannot be apostilled under the general regime.
- Frustration #2: they manage to obtain the apostille from the country of origin on their foreign document. It is issued, but separate from the translation, which makes no mention of it. The prefecture refuses it because the translation no longer reflects the full source document.
Result: 3 to 6 weeks of delay, plus the cost of redoing the translation.
The apostille authenticates the original document in its country of issuance. It must be affixed before translation, and the French certified translation must reproduce both the document and its apostille.
The rule: apostille on the original, BEFORE translation
The apostille, created by the Hague Convention of 5 October 1961, is a formality authenticating the signature, the seal, and the capacity of the authority that issued a public document. Under Article 3 of the Convention, it is affixed "on the document itself or on an 'allonge'."
In other words, the apostille can only apply to a public document — that is, a document issued by a public authority in the country of origin (town hall, court, ministry). The French certified translation, although produced by a court-appointed expert registered with a French Court of Appeal, does not by default fall within the scope of the 1961 Convention — we cover the exception further below.
Why this rule: the territorial principle
Private international law rests on the principle that the authenticity of a document is verified in its country of issuance. In concrete terms, only Algeria can certify that an Algerian birth certificate is authentic; only Ukraine can validate a Ukrainian diploma; and so on. This principle makes sense: no one can authenticate the signature of a foreign civil registrar from within France.
Once the document has been authenticated in its country of issuance (by apostille or legalisation), it enters France with its guarantee of authenticity. It can then be translated by a French court-appointed expert, who in turn certifies the entire document — including the apostille notation — and physically binds it to their copy of the source document.
It is this chain of evidence that makes the translation enforceable before any French administration. Reverse the order, and the chain is broken.
The exception: a French Court of Appeal "apostille on a translation"
There is one — rare — case where a foreign administration (or a foreign country, in the reverse process: a French document to be produced abroad) requires an apostille on the translation itself. This is the case, for example:
- Of a French document to be recognised in China, Brazil, Russia, etc.
- Of a French procedure whose translation must be sent to a foreign authority (international divorce, adoption, etc.).
- Of certain foreign consulates in France that require the apostille on the translation for a visa.
In this case, France — as the country of origin of the translation — can apostille the document through its Courts of Appeal (since the reform of 1 January 2025, introduced by Decree No. 2023-1086 of 24 November 2023, which transferred authority from the public prosecutor's office to the central apostille service attached to the Court of Appeal).
Procedure for obtaining a French apostille on a certified translation:
- Have the French (source) document translated by a sworn translator registered with a French Court of Appeal.
- Submit the translation (or send it) to the central apostille service of the Court of Appeal covering the translator.
- Obtain the apostille on the translation within 3 to 15 working days (depending on the court).
The correct order in 4 steps
Step 1 · Obtain a recent original document
Order a civil status document (birth, marriage, death) less than 3 months old from the town hall or consulate of the country of issuance. Some French procedures (PACS, marriage) accept up to 6 months.
Step 2 · Have it apostilled (or legalised) in the country of origin
Contact the competent authority designated by the country of origin under the Hague Conference: the Ministry of Foreign Affairs (Morocco, Tunisia, most countries), the Ministry of Justice (Algeria since 2024), the Secretary of State (United States, by federal state), the Foreign Office (United Kingdom), etc.
If the country is not party to the Hague Convention, double legalisation is required: the local ministry plus the French consulate on the ground.
Step 3 · Certified translation in France
Send the apostilled document (high-definition colour scan) to a sworn translator registered on a French Court of Appeal list. The translator reproduces the entire document: the main document plus the apostille. See our page on sworn translators.
Step 4 · Submitting the file in France
You present the whole package: apostilled original document + bound certified translation + copy of ID. The administration validates the chain of evidence without requesting any additional documents.
Special cases by country
China: a newly apostille-eligible country
China has been a party to the Convention since 7 November 2023. Chinese documents predating this date were subject to double legalisation; they can remain valid, but for any new procedure, you should now request an apostille from the Chinese Ministry of Foreign Affairs (or an authorised provincial office).
Countries without apostille (outside the Convention)
Some countries are not party to the Hague Convention: Canada (accession planned), Ethiopia, Saudi Arabia, Iran, Iraq, Sudan, Syria, Libya, Yemen, and several sub-Saharan African countries. For these countries, double consular legalisation remains the rule. For Canada, France applies a specific bilateral regime (no apostille or legalisation for certain documents).
European Union: neither apostille nor translation (sometimes)
EU Regulation 2016/1191 of 6 July 2016, applicable since 16 February 2019, removes the apostille requirement for public documents between EU Member States and, for a defined list (birth, marriage, death, marital capacity, absence of criminal record, etc.), allows them to be produced with a multilingual standard form attached — dispensing with any translation.
Note: this regime only covers civil status documents and certain administrative documents. Diplomas, judgments and notarial deeds remain subject to the general rules.
Frequently asked questions
Can I have a translation made in France apostilled?
Yes, but only where the French translation is to be produced abroad (the reverse use case). In that case, the apostille is issued by the Court of Appeal covering the translator. For a procedure in France, it is the foreign original that needs apostilling, not the translation.
Is the apostille mandatory for all countries?
No. EU countries have been exempt from the apostille for civil status documents since 2019. Countries not party to the Hague Convention require double legalisation. Check our country-by-country summary on the apostille & legalisation page.
How long is the apostille valid?
The apostille itself has no expiry date of its own. However, French administrations often require the document to be recent (3 to 6 months). In practice, the apostille doesn't "expire" — but the document bearing it does.
If I had the translation done before getting the apostille, do I need to redo everything?
Generally, yes. Once the apostille is affixed to the original, the initial translation does not include this new notation and will be refused. Some translators offer a "supplementary translation" covering just the apostille, but this practice is often rejected by demanding prefectures. It is better to redo it properly.
Does legalisation follow the same logic as the apostille?
Yes, exactly the same: legalisation on the original in the country of origin, before translation in France. This is, incidentally, the same logic that explains why, before March 2024, Algerian documents required super-legalisation by the French consulate in Algiers before being sent to France for translation.