Is a French sworn translation valid abroad?

By Keran Chaussard, administrator of the Directory of Sworn Translators of France — updated on 2 October 2026

The three possible scenarios

The country accepts the French translation with an apostille. This is the most common situation, for countries that are party to the Hague Convention of 5 October 1961. The apostille does not relate to the content of the translation: it authenticates the sworn translator’s signature and stamp.

The country has not signed the Hague Convention. A legalisation is then required, a two-step procedure: authentication in France, then counter-authentication by the diplomatic representation of the recipient country. Timeframes are considerably longer.

The country requires a local translator. Several States only accept translations produced by a translator sworn before their own courts, or by their consulate. In that case, no French apostille will solve the problem: the document must be translated locally.

Apostille and legalisation: what changed in 2025

Since 1 May 2025, apostilles in France have been issued by fifteen regional councils and inter-departmental chambers of notaries, instead of the public prosecutor’s offices at the courts of appeal. Territorial jurisdiction has disappeared: any of these centres can handle your request, and the procedure is online.

Since 1 September 2025, the same notarial bodies have also issued legalisations, previously handled by the Ministry for Europe and Foreign Affairs. Most pages on the subject still describe the old system.

Key point — the apostille and legalisation are now handled by notaries. The courts of appeal no longer issue them.

The special case of the European Union

Between EU Member States, Regulation (EU) 2016/1191, applicable since 16 February 2019, abolished the apostille requirement for a series of public documents, including birth, death, marriage, registered partnership, residence and absence of a criminal record. The same regulation created multilingual standard forms that are attached to the original document and, in many cases, remove the need for any translation.

Before ordering a sworn translation for an EU country, ask whether a multilingual form is enough. It may save you the expense entirely.

In what order should you proceed?

The sequence of formalities matters as much as the formalities themselves, and the most common mistake is to do them the wrong way round.

If the document is French and is going abroad: obtain a recent original document, have it translated by a sworn translator, then have the translator’s signature apostilled. Some countries also require an apostille on the original document itself, in addition to the one on the translation.

If the document is foreign and intended for France, the order is reversed: the apostille or legalisation is obtained in the country that issued the document, before translation. A translation made before the apostille will often have to be redone, as the apostille will not appear in the translated text.

The golden rule

Contact the receiving body before placing your order. A German university, a Moroccan consulate and a Brazilian court do not have the same requirements, and these requirements cannot be guessed. Ask three questions: do you accept a translation made in France, is an apostille needed, and do you accept a digital version? This check takes one email and avoids the main reason for rejected files.

Should you apostille the original or the translation?

This is by far the question that causes the most difficulty in files intended for use abroad, and the most costly source of errors. Depending on the country and the type of document, you sometimes have to apostille the original document and then have it translated, and sometimes have it translated and then apostille the translator’s signature. Both orders exist, and getting it wrong means starting all over again.

There is, however, a simple rule that settles the matter every time. An apostille does not authenticate a document: it authenticates a signature. It certifies that the person who signed is who they claim to be, and that they were authorised to sign. So the right question is never “should the translation or the original be apostilled?”, but: which signature does the receiving authority need to verify?

A concrete example: an estate in Spain

A Spanish notary handling an estate asks for an apostille on the French estate deed. Many applicants assume the translation must be apostilled. It is the other way round: the apostille must be placed on the original deed, and it is the apostilled document that is then translated.

The reason lies in the rule set out above. What the Spanish notary wants to verify is the authenticity of the signature of the French notary who drew up the deed. The translator’s signature is of no interest to them: they simply require the translation to have been produced by a sworn expert.

The same reasoning works the other way. In Spain, sworn translators sign electronically, and their signature can be verified directly using a QR code on the translation. An apostille would serve no purpose there: the Spanish authority checks authenticity by scanning the code, without going through a third party. The apostille is only useful where the signature cannot be verified in any other way.

Key point — the apostille authenticates a signature, not a document. Ask the recipient which signature it needs to be able to verify: the answer tells you which document to apostille, and in what order to proceed.

How to put the question to the recipient

Rather than asking “is an apostille needed?”, a question that will be answered with a vague yes, ask: which document should the apostille be placed on, the original or the translation? And do you require the translation to be made by a sworn expert from your country, or do you accept a French expert?

These two questions, asked in writing before placing any order, resolve almost all the files that come back rejected.

Frequently asked questions

Should the original document or the translation be apostilled?

It depends on which signature the receiving authority needs to be able to verify, because an apostille authenticates a signature, not a document. If the recipient wants to make sure the document itself is authentic — as with a foreign notary handling an estate — the apostille goes on the original, which is then translated. If it is the translator’s status that needs to be authenticated, the apostille relates to the translator’s signature, after translation. Ask the recipient explicitly before placing your order.

Does the apostille relate to the translation or to the original?

To the signature of the expert who signed the translation. It is an authentication of a signature, not a validation of the content. Some countries also require an apostille on the original document itself.

Who issues the apostille in France in 2026?

Notaries, through fifteen regional councils and inter-departmental chambers of notaries, since 1 May 2025. The public prosecutor’s offices at the courts of appeal no longer issue the apostille. There is no longer any territorial jurisdiction and the procedure is online.

Does a second copy need a new apostille?

Yes. Each copy bears an original signature of the sworn translator, so each copy must be apostilled separately.

Is a French sworn translation accepted throughout the European Union?

Not always. Regulation (EU) 2016/1191 abolishes the apostille for certain public documents and provides for multilingual standard forms that often remove the need for translation. For other documents, requirements remain specific to each State.

Sources

• Lists of court-appointed experts of the courts of appeal, centralised by the Court of Cassation
• Decree No. 2004-1463 of 23 December 2004 on court-appointed experts
• Decree No. 2021-1205 of 17 September 2021, amended by Decree No. 2024-1200 of 23 December 2024, on legalisation and the apostille
• Regulation (EU) 2016/1191 of 6 July 2016 on the circulation of certain public documents