Home › Guides

Certified, notarised, sworn, apostilled — which one do you actually need

Updated 2026-08-08

These four terms describe different acts by different people solving different problems. Buying the wrong one is the most common avoidable expense in this whole process, and the sales pages are not going to clear it up for you.

The one-line version

Read down the middle column. Only one of these four says anything about whether the translation is any good, and it is the cheapest one.

Certified translation

A certified translation is a translation with a signed statement attached in which the translator declares that the translation is complete and accurate and that they are competent in the language pair. That statement is the certification. Nothing else is added.

There is no US federal licence for translators, so "certified" in the American sense describes the document, not the person. This trips up people from countries where the opposite is true.

• Who can produce it: any competent translator, including one working for you.
• What it costs: typically bundled into a per-page translation price, around US$25 per page from the well-known online services.
• Who asks for it: USCIS, most US universities, most employers, most banks.

Notarised translation

A notarised translation is a certified translation whose certification statement was signed in front of a notary public. The notary checks the signer's identity and stamps the page.

The notary is not evaluating the translation. They typically do not read the source language. A notarised translation of a wrong translation is a wrong translation with a stamp on it. This is worth saying because the notary's seal looks like it means more.

• Who can produce it: the translator, plus a notary.
• What it costs: the translation, plus a notary fee — commonly US$10–50 depending on the state, sometimes bundled by translation services as an add-on.
• Who asks for it: some courts, some foreign consulates, some universities, some state licensing bodies. Not USCIS.

Sworn translation

In many civil-law countries — Spain, France, Germany, Brazil, Poland, Italy and others — the state appoints translators who may produce translations with legal force. A sworn translation (traducción jurada, traduction assermentée, beeidigte Übersetzung) carries that translator's official seal and registration number.

The important asymmetry: a sworn translator's work is accepted more or less automatically in their own jurisdiction, and a translation produced in the US will often not be accepted in a country that uses the sworn system. If your document is going to Spain or France, an American certified translation may simply not qualify.

• Who can produce it: only a translator appointed by that country's authority.
• What it costs: usually more than a certified translation, and priced by the local market.
• Who asks for it: authorities in countries that operate the sworn-translator system.

Apostille

An apostille is a certificate issued by a government authority that authenticates the signature and seal on a public document so it can be used in another country that is party to the Hague Apostille Convention.

It is not about translation at all. It never has been. It certifies that the signature is genuine, that the signer acted in the stated capacity, and that the seal is what it appears to be. It says nothing about the document's content and nothing about any translation attached to it.

Mainland China has issued apostilles since 7 November 2023, replacing consular legalisation for the roughly 125 contracting parties. Canada followed on 11 January 2024.

• Who can produce it: in China, the MFA Department of Consular Affairs or an authorised local foreign affairs office.
• What it costs: a modest official fee, plus whatever the notarisation ahead of it cost.
• Who asks for it: the receiving authority in the destination country, for documents whose authenticity is in question — not their language.

Working out which you need

Ask the questions in this order. They are ordered so that a "no" saves you money.

1. Does the receiving institution's own page state a requirement? If so, that is the answer and nothing on this page overrides it. Print the page and keep it.

2. Is the document in a foreign language? If yes, you need a translation, and at minimum a certified one. This is almost always required.

3. Does the receiving institution question the document's authenticity, or is it a foreign public document being used across a border? If yes, you may need an apostille — on the original or on the notarial certificate, not on the translation.

4. Does the destination operate a sworn-translator system, and is the translation being produced there? If yes, use a sworn translator in that country. A certified translation made elsewhere may not be accepted.

5. Has anyone specifically demanded a notary? Only then pay for notarisation. It is the requirement most often assumed and least often actually imposed.

The combinations that actually occur

FAQ

Is a notarised translation better than a certified one?

Not in terms of translation quality — the notary does not assess the translation. It is only "better" if the receiving institution asked for it. Otherwise it is a certified translation with an extra fee attached.

Can the same document be certified and apostilled?

Yes, and they attach to different things: the certification goes on the translation, the apostille goes on the underlying public document or the notarial certificate. They coexist without interacting.

Does an apostille need to be translated?

Often, yes. It is itself a document, usually in the issuing country's language plus French. Some receiving bodies want it translated along with everything else; some do not care because the apostille has a standardised numbered layout that is readable in any language.

I was told I need a "certified translator". Is that a real thing?

In the US, no — there is no federal translator certification. In Australia there is NAATI; in Canada, provincial associations like ATIO, OTTIAQ and STIBC; in sworn-system countries, court-appointed translators. Ask the person who said it which country's certification they mean.

Which of these does CertTwin produce?

None of them. CertTwin produces a translation draft marked PREVIEW_ONLY for you to review and correct. Certification, notarisation, swearing and apostilling are all acts performed by a person taking legal responsibility, and that person is you or a translator you engage.

Sources

• 8 CFR 103.2(b)(3) — the US translator certification requirement
• HCCH — Apostille Convention enters into force for China
• Global Affairs Canada — Canada joins the Apostille Convention

Related guides

• What USCIS actually requires of a translationThe rule is one sentence long. It asks for a complete English translation plus a translator's certification of accuracy and competence — and it says nothing about layout, notarisation, or agency credentials.
• Apostilles on Chinese documents — and why they do not solve translationSince 7 November 2023 Chinese public documents get an apostille instead of consular legalisation. What the apostille certifies, what it does not, and where the English translation has to come from.
• What certified translation costs in 2026, and what the price is actually buyingAround US$25 a page is the going rate for online certified translation. Here is what that page is defined as, which five separate jobs the fee covers, and which of them you can do yourself.