The most frequent problem in international document procedures is getting the order of apostille and translation wrong. The correct sequence depends on the type of document and the requirements of the destination country. An incorrect order wastes both time and money: if you bring an already translated document to an institution that requires translation after the apostille, you may have to restart the entire process from scratch. In this article, based on official information valid as of the date of publication, we walk step by step through the correct order, the competent authorities, and the most common mistakes.
What exactly does an apostille certify?
An apostille is an international certification mechanism based on the Hague Convention of 5 October 1961 (Convention Abolishing the Requirement of Legalisation for Foreign Public Documents), published in the Official Gazette on 16 September 1984 and entering into force for Turkey on 29 September 1985. There is a critical distinction here: the apostille annotation does not certify the content of the document; it attests to the authenticity of the signature, the capacity of the signing official, and the seal on the document.
This distinction directly affects the translation order. Because an apostille is a "signature and seal verification," the outcome changes depending on which document it is applied to (the original document or the notarized translation). Apostilled documents are recognized as valid in more than 120 countries party to the Hague Conference; however, for non-member countries, consular legalization is required instead of an apostille, which is an entirely different process. If you are unsure which route your document should follow, getting preliminary guidance from a team experienced in official document certification will shorten the process.
The typical correct flow: A step-by-step process
- The original document is prepared.
- If required, a sworn translation + notarization is completed.
- An apostille is obtained for the notarized document at the governor's office (valilik) or district governor's office (kaymakamlık).
Some countries, however, require the apostille on the document first, followed by a translation of the apostilled document (including the annotation). That is why it is essential to confirm the destination institution's expectations in advance. In practice, this second flow is quite common; indeed, if a translation is required for a document to be used abroad, the translation is completed before the apostille in most cases, but some countries and institutions expect exactly the opposite. In short, there is no "single correct order"; the written instructions of the destination institution are what matter.
The first step is more important than it seems: some documents require "pre-approval" before the apostille. For example, for a diploma, pre-approval must first be obtained from the higher authority that issued the document (the provincial directorate of national education or the university rectorate), followed by the apostille annotation from the governor's or district governor's office; especially for university diplomas, not skipping the rectorate step saves time. A document brought without pre-approval will be turned away at the apostille counter, and the sequence falls apart at the very first step.
Which documents require an apostille and translation?
The apostille + translation pairing most commonly arises for the following document groups:
- Educational documents: diplomas, transcripts, student certificates, graduation certificates (for university applications abroad and equivalency procedures).
- Civil status documents: birth, marriage, and death record extracts, civil registry extracts, name change decisions.
- Judicial documents: criminal record certificates, court decisions (divorce, custody, recognition and enforcement proceedings).
- Notarial documents: powers of attorney, letters of consent, letters of undertaking, signature circulars.
- Commercial documents: articles of association, certificates of activity, trade registry records.
For example, when a company in Turkey wants to open a branch or representative office in another country, that country asks the company for its articles of association and incorporation agreement; these documents must be both apostilled and translated into the target language. For educational documents, since universities may have their own translation and certification expectations, working with an agency experienced in academic translation prevents rejections caused by terminology errors.
Which authority issues the apostille? A notary or the governor's office?
This is where the most common confusion arises: notaries do not issue apostilles. Notaries draw up and certify documents or attest translations; notarized documents are then apostilled by the relevant governor's office (valilik) or district governor's office (kaymakamlık). In other words, notarization and the apostille are two separate, sequential procedures that do not substitute for one another. Likewise, the sworn translator's stamp is distinct from notarization: the sworn translator certifies the accuracy of the translation, while the notary attests the translator's oath record and signature.
The allocation of authority varies by document type: in Turkey, the authorities empowered to affix the apostille certification are, for administrative documents, the governor's offices — deputy governors and directors of legal affairs acting on behalf of the governor — and district governor's offices, and for judicial documents, locations with a high criminal court, namely the presidencies of the judicial commissions of first instance courts of the judiciary. As a practical convenience, applications may be made to the governor's or district governor's office of the province of residence; any provincial governor's office can apply an apostille to documents issued anywhere in Turkey.
Translation first, or apostille first? Country-by-country differences
The table below compares the two flows most frequently encountered in practice. Always confirm in writing with the institution to which you will submit the document which flow applies:
| Flow | Order | Typical use |
|---|---|---|
| Translation first, then apostille | Original document → sworn translation → notarization → apostille on the notarized translation | If the destination institution requires an "apostilled notarized translation"; many continental European institutions accept this flow |
| Apostille first, then translation | Original document → apostille → translation of the apostilled document (including the annotation) → re-certification in the destination country if required | If the destination country requires the translation to be done within its own system (e.g., by its own sworn translators) |
In the first flow, the procedure is clear: the translation certified by the notary is taken to the governor's office in provinces or the district governor's office in districts (in the province or district where the notary is located) for the apostille, and the document can then be submitted in the other country. In the second flow, since the apostille annotation is added to the document before the translation, the translation must also cover the annotation. Some countries may require a separate apostille on both documents (both the original and the translation); this "double apostille" requirement can cause serious delays, especially when it is not known in advance. Whatever the target language — including English translation, the most commonly requested — the order must be clarified before starting.
Should the apostille annotation itself be translated?
The apostille template is an international standard (with a French title), but the fields filled in (official's name, date, seal) are in Turkish. Some institutions require a complete translation; an incomplete translation may be grounds for rejection. Indeed, the title of the annotation is the same in every country: "Apostille (Convention de La Haye du 5 octobre 1961)" — but this standard title does not mean the rest of the annotation goes untranslated.
In practice, the safe approach is this: unless the destination institution explicitly states otherwise, have the apostille annotation translated together with the document. The translation of the annotation usually takes less than half a page and costs little; by contrast, the rejection of a file with an untranslated annotation means repeating the entire process (including shipping, appointments, and application deadlines). At Ziya Tercüme, we consider delivering complete translations of apostilled documents — annotation included — our standard practice.
e-Apostille: How does digital application affect the order?
The most significant recent development speeding up the process is the e-Apostille. The system went live on 1 January 2019, and in its first phase, electronic apostille procedures were launched for judicial documents such as criminal record certificates and court decisions. In 2021, applications began to be accepted for civil registry extracts from the General Directorate of Civil Registration and Citizenship Affairs (Nüfus ve Vatandaşlık İşleri Genel Müdürlüğü), and in 2022 the service was integrated into the e-Government Gateway (e-Devlet Kapısı), enabling applications via turkiye.gov.tr as well. As of 18 December 2023, the criminal record certificate can be generated and submitted for an e-Apostille request through a single screen; the electronic apostille service for multilingual birth, marriage, and death record extracts has also been available since 28 December 2023.
On the technical assurance side, a document created electronically by the relevant institution and given an e-Apostille is signed by PTT with a Qualified Electronic Certificate (NES) and delivered to the applicant; this guarantees the document's authenticity and integrity. Two limitations should be kept in mind: e-Apostilles are not issued for countries that are not party to the Hague Convention, and since the system currently covers only certain document types, some documents, such as diplomas, may still require a physical application to the governor's office. Translation of e-Apostilled PDF documents is also possible; by sending us the digital document, you can start the notarized translation process remotely.
How long does it take, and which items affect the cost?
As of the date of publication, the state does not charge a fee for the apostille annotation itself: the apostille is free of charge; no official fee is requested for the annotation issued by the governor's office, district governor's office, or the judicial commission. In terms of timing, the apostille procedure is generally completed the same day or within a few business days, depending on the nature of the document; for e-Apostille applications, approval is usually finalized within 24 hours.
The items that determine the total cost are not the apostille itself but the procedures surrounding it: sworn translator fees (varying by language pair), notary costs (certified copies, attestation procedures), and, if required, institutional/chamber approval fees. Page count, how common the target language is, and delivery time also affect the price. If your application timeline is tight, it is possible to complete the translation step the same day with the urgent express translation option; however, since the working hours and workload of apostille authorities are beyond our control, we recommend leaving a few days' buffer when planning the overall schedule.
Common mistakes
- Trying to get an apostille from a notary (apostilles are issued by the governor's/district governor's office or the judicial commission at the courthouse).
- Using a translator who is not sworn.
- Not translating the annotation.
- Skipping the rectorate/provincial national education pre-approval for documents such as diplomas.
- Taking an administrative document to the courthouse or a judicial document to the governor's office (the wrong authority is grounds for rejection).
- Pursuing an apostille when the destination country is not party to the Hague Convention (consular legalization is required in that case).
- Failing to check the currency of the underlying document, even if the apostille date is recent.
The last item is often overlooked: the apostille annotation has no separate validity period and certifies the document permanently; however, the document it is attached to may be required to be current — for example, institutions may request recently issued documents for criminal records or civil registry extracts. In other words, a criminal record certificate apostilled six months ago may be rejected because the document is considered "old," even though the annotation remains valid.
Another pitfall is failing to cover every element on the document in the translation (seals, barcode descriptions, notes on the reverse side, the annotation). Official institutions generally do not accept a "partial translation"; the translation must therefore match the document exactly. For texts such as court decisions, legal translation expertise is essential, since a terminology error can directly affect the recognition and enforcement process.
Example scenario and next steps
A concrete example: a graduate applying for a master's program in Germany first obtains wet-signed, sealed copies of their diploma and transcript from their university; an official, sealed, and signed copy of the transcript is requested from the university, and the pre-approval signature must be obtained from the relevant unit. Then the document instructions of the university being applied to are read carefully: Does the institution want an "apostilled original + sworn translation," or an "apostille on the notarized translation"? Great care must be taken with the order here, because the wrong sequence can force the entire procedure to be redone from the beginning.
A practical checklist for your next steps: (1) Get the destination institution's document instructions in writing, (2) determine whether the document is administrative or judicial and choose the correct apostille authority, (3) check via e-Government (e-Devlet) whether it falls under the e-Apostille scheme, (4) confirm that the translation will be complete, annotation included. For the correct order and a complete translation, take advantage of our apostille-certified translation service; let's plan the most suitable flow together based on your document type and destination country.
Sources
- PTT — What Is an e-Apostille? How to Obtain One?
- PTT — Electronic Apostille System
- e-Government Gateway (e-Devlet Kapısı) — General e-Apostille Application
- e-Government Gateway (e-Devlet Kapısı) — Criminal Record Certificate e-Apostille Application
- Ministry of Transport and Infrastructure (Ulaştırma ve Altyapı Bakanlığı) — Official Documents Reach the World Digitally with the e-Apostille
- Embassy of the Republic of Turkey in Bucharest — Information Note on e-Apostille Applications for Criminal Record Certificates
- Sapanca District Governorship (T.C. Sapanca Kaymakamlığı) — Apostille Certification and Procedures
- Çekmeköy District Governorship (T.C. Çekmeköy Kaymakamlığı) — Apostille Procedures