Translation for Brazil: Brazilian or European Portuguese, apostille and sworn translation

By Keran Chaussard, administrator of the Directory of Sworn Translators of France — updated on 23 October 2026

A document intended for Brazil must be translated into Brazilian Portuguese, not European Portuguese. The 1990 Orthographic Agreement brought the spelling of the two variants closer together, but it did not unify vocabulary, syntax or administrative and legal terminology: “registo” and “conservatória do registo civil” in Portugal become “registro” and “cartório de registro civil” in Brazil. A translation into European Portuguese must therefore be adapted, not just corrected.

As for formalities, the France–Brazil convention of 28 May 1996 exempts many public documents from legalisation, but the French Foreign Ministry table states the apostille for Brazil, and that is what Brazilian authorities most often require. For administrative use in Brazil, the translation is as a rule required from a public translator (“tradutor juramentado”) registered in Brazil: check this before ordering a translation in France.

Brazilian or European Portuguese: why it matters

The Orthographic Agreement of the Portuguese Language, signed on 16 December 1990, aims to unify the spelling of Portuguese across Portuguese-speaking countries. It has been mandatory in Brazil since 1 January 2016 and in Portugal since 2015; Angola and Mozambique have still not ratified it. It removed some spelling differences, but not all: some double spellings remain, and above all the agreement covers spelling only.

Portugal	Brazil	What changes
registo	registro	Vocabulary
conservatória do registo civil	cartório de registro civil	Civil registry institutions
cartão de cidadão	carteira de identidade	Identity documents
carta de condução	carteira nacional de habilitação (CNH)	Driving licence
número de identificação fiscal (NIF)	CPF	Tax identification number
facto	fato	Spelling (double spelling retained)
económico	econômico	Accents
estou a trabalhar	estou trabalhando	Syntax

For an official document, these differences are not cosmetic: a Brazilian civil registrar or notary expects the terms of their own system. When a client asks for a translation made in European Portuguese to be “brought into line”, what is actually needed is a full revision by a translator fluent in Brazilian Portuguese, not a mere application of the Orthographic Agreement.

Apostille or exemption: what the France–Brazil convention provides

The convention on mutual legal assistance in civil matters between France and Brazil of 28 May 1996, in force since 1 October 2000, exempts from legalisation public documents drawn up in the territory of either State (Article 23): documents issued by a court, the public prosecutor’s office, a court clerk or a bailiff, civil status records, notarial deeds and official certificates. In case of serious doubt, information may be requested through the central authorities (Article 24).

The summary table of the French Ministry for Europe and Foreign Affairs does list this convention among the exemption agreements, but it states the apostille for every category of document going to Brazil (Brazil has applied the Hague Convention since 14 August 2016). In practice, Brazilian cartórios and authorities most often ask for the apostille. The safest approach is therefore to have the French document apostilled, unless the Brazilian authority confirms in writing that it applies the exemption.

Who must translate for a Brazilian authority?

In Brazil, a foreign-language document only has effect before administrations, cartórios or courts if accompanied by a tradução juramentada, produced by a public translator (“tradutor público e intérprete comercial”) registered with a Brazilian Junta Comercial. A French sworn translation is not always accepted in its place.

There is one notable exception: for court decisions to be recognised under the 1996 convention, the translation may be certified by a diplomatic or consular agent, or by any person authorised to do so in the territory of either State (Article 20), and therefore by a French court-appointed expert translator.

Before having a document translated in France, ask the receiving Brazilian authority:

whether it accepts a translation made in France by a court-appointed expert translator, apostilled;
or whether it requires a tradução juramentada made in Brazil, in which case only the apostilled original needs to be sent.

In the other direction: a Brazilian document presented in France

Obtain a recent document in Brazil: for civil status, the “certidão de inteiro teor” (full copy) is often preferable to the short-form certidão.
Have it apostilled in Brazil, at a cartório: the Brazilian apostille is electronic, with a QR code and a verification code. For some public documents the 1996 convention may exempt you from this formality, but the apostille avoids any dispute.
Have the document and its apostille translated in France by a court-appointed expert translator in Portuguese who knows Brazilian institutions.

Common mistakes

Providing a translation into European Portuguese to a Brazilian authority.
Believing the Orthographic Agreement makes the two variants interchangeable.
Having a document translated in France that the Brazilian authority will have retranslated by a tradutor juramentado anyway.
Forgetting the apostille, relying on the 1996 convention alone without confirmation from the Brazilian authority.
Translating the document before the apostille: the apostille will then need translating separately.

Finding a Brazilian Portuguese translator

The Directory of Sworn Translators of France lets you search for a court-appointed expert translator in Portuguese by département, region and court of appeal. State when you make your request that the document is for Brazil: not every Portuguese expert works equally comfortably in both variants. The express file submission service lets you entrust the request to the Directory, which passes it to an expert in Brazilian Portuguese.

Frequently asked questions

Is a translation into European Portuguese valid in Brazil?: It may be rejected or misunderstood: vocabulary, syntax and administrative terminology differ. For Brazil, ask for a translation into Brazilian Portuguese.
Did the 1990 Orthographic Agreement unify Portuguese?: It brought spelling closer together, but it did not unify vocabulary, grammar or legal and administrative terminology.
Does a French document for Brazil need an apostille?: The French Foreign Ministry states the apostille. The 1996 France–Brazil convention provides an exemption for certain public documents, but it is rarely applied without confirmation from the Brazilian authority.
Is a French sworn translation accepted in Brazil?: Not always: Brazilian authorities generally require a tradução juramentada made by a public translator registered in Brazil. Exception: court decisions transmitted under the 1996 convention.
How do I have a Brazilian document translated for France?: Have it apostilled in Brazil, then translated in France, together with its apostille, by a court-appointed expert translator in Portuguese.

Directory of Sworn Translators of France