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Apostilles and legalisationArticle 3 of 8 · 5 min read

Apostille routes for US, UK, Canadian, Australian and Latin American documents

Shows which office issues the apostille for documents from the US, UK, Canada, Australia and Latin America, and the steps to follow in each country. It is for newcomers who must get foreign papers accepted in Spain.

Key rules

  • US split: State documents go to the state's Secretary of State; federal documents go to the US Department of State.
  • UK copies: A copy of a UK document needs certifying by a solicitor or notary before it can be apostilled.
  • Canada: Canadian documents no longer need consular legalisation since 11 January 2024.
  • Latin America: The issuing office is usually the foreign ministry, but Mexico and Brazil use other bodies.

The basic rule

An apostille is issued in the country where the document was made, by the office that country has named. Find your country below, then check the office's current fees and times before you send anything. The documents list and the questions below cover the detail for each country.

United States

The route depends on who issued the document.

  • State documents (birth and marriage certificates, notarised papers, state court or university records): the Secretary of State of the issuing state apostilles them.
  • Federal documents (FBI background check, federal agency or federal court papers): the US Department of State Authentications Office apostilles them.

Do it in this order:

  1. Get a certified copy, or have the document notarised if it is a private paper. Birth and marriage certificates may need a certified copy from the state registry.
  2. Send state documents to the Secretary of State. Send federal documents to the Department of State.
  3. Some states want a county clerk certification first. Ask before you send.

Requirements and fees vary by state, so check with the state office.

United Kingdom

The Legalisation Office of the UK Foreign Office issues UK apostilles.

  • The document must carry an original signature the office has on record, for example a solicitor, a notary public or an official registrar.
  • A copy, such as a copy of a degree or passport, must first be certified by a solicitor or notary.
  • Birth, marriage and death certificates must be official certified copies.

You apply online. There are postal and premium (faster) options. A fee is charged per document, and the standard service takes several days. Check current fees and times on the UK government website.

Canada

Canada has been part of the apostille system since 11 January 2024, so Canadian documents no longer need consular legalisation.

  • Federal documents: Global Affairs Canada apostilles them.
  • Provincial or territorial documents (vital records, court papers, notarised documents): the province or territory's designated authority apostilles them. This is often the Attorney General or a government services ministry.

Get an original or certified copy. Have a private document notarised. Then send it to the right authority. Procedures differ between provinces, so check with the one that issued your document.

Australia

The Department of Foreign Affairs and Trade (DFAT) apostilles Australian public documents, notarised documents and many state-issued documents.

  • Private documents usually need a notary public first.
  • Certified copies may need a certification.
  • You apply online or through DFAT's lodgement service. DFAT also issues e-apostilles.

DFAT charges a fee per document and processing times vary, so check them with DFAT.

Latin America

Most Latin American countries are in the apostille system. They include Argentina, Bolivia, Brazil, Chile, Colombia, Costa Rica, Cuba, the Dominican Republic, Ecuador, El Salvador, Guatemala, Honduras, Mexico, Nicaragua, Panama, Paraguay, Peru, Uruguay and Venezuela.

  • In most of them the foreign ministry issues the apostille.
  • In Mexico, state governments or the Foreign Ministry issue it, depending on the document.
  • In Brazil, notaries and registries issue it through the national justice council's system.

Confirm your country's membership and its competent authority on the Hague Conference's status table and the country's own list of authorities.

Documents you need

  • US state documents (birth or marriage certificates, notarised papers, state court or university records): a certified copy or notarised original, apostilled by the Secretary of State of the issuing state. Some states need a county clerk certification first.

  • US federal documents (FBI background check, federal agency or federal court papers): apostilled by the US Department of State Authentications Office.

  • UK documents: signed by a solicitor, notary public or official registrar whose signature the Legalisation Office of the FCDO has on record, then apostilled by that office. Copies of a degree or passport need a solicitor or notary to certify them first.

  • UK birth, marriage and death certificates: official certified copies, apostilled by the Legalisation Office of the FCDO.

  • Canadian federal documents: original or certified copy, apostilled by Global Affairs Canada. Private documents must be notarised first.

  • Canadian provincial or territorial documents (vital records, court papers, notarised documents): original or certified copy, apostilled by the province's or territory's designated authority, often the Attorney General or the Ministry of Government Services.

  • Australian documents: apostilled by the Department of Foreign Affairs and Trade (DFAT). Private documents usually need a notary public first, and certified copies may need certification.

  • Latin American documents: apostilled by the issuing country's competent authority, usually the foreign ministry. In Mexico it is the state government or the Foreign Ministry (SRE), and in Brazil a notary or registry.

Frequently asked questions

Which US office apostilles an FBI background check?

The US Department of State Authentications Office apostilles an FBI background check, because it is a federal document. State documents such as birth certificates go to the Secretary of State of the issuing state instead.

Can I apostille a copy of my UK degree or passport?

Yes, but a solicitor or notary public must certify the copy first. The Legalisation Office of the FCDO only apostilles documents with an original signature it has on record.

Do Canadian documents still need consular legalisation?

No, Canadian documents no longer need consular legalisation, because Canada has been part of the apostille system since 11 January 2024. Federal documents go to Global Affairs Canada. Provincial documents go to the province's own authority.

Who issues apostilles in Mexico and Brazil?

In Mexico, state governments or the Foreign Ministry (SRE) issue apostilles, depending on the document. In Brazil, notaries and registries issue them through the National Council of Justice system. In most other Latin American countries, the foreign ministry issues them.

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