A notary who seals your translation is not vouching for a single word of it. That is not carelessness; it is the job. The Institute of Translation and Interpreting (ITI) puts it bluntly: "The Notary's signature cannot endorse the quality of the translation," unless the notary is a qualified ITI member in that language.
Knowing that saves money in both directions. People pay for notarisation the Home Office never asked for, and others send a plain certified translation to a Spanish or Italian office that expects a sworn translation.
Below: what each option proves, who notaries are, which UK rules mention them, and what foreign offices want.
What is the difference between a certified and a notarised translation?
The person who vouches for it, and for what.
| Certified translation | Notarised translation | Apostilled translation | |
|---|---|---|---|
| Who signs | The translator or a translation company official | The translator, then a notary public | The above, then the competent authority |
| What it confirms | The translation is accurate and complete | The translator's identity and signature, often an oath | The notary's signature, capacity and seal |
| Limits | Rests on the translator's own word | Says nothing about accuracy | Says nothing about the content |
| Typical use | UK authorities | Documents going abroad | Hague Convention countries |
According to ITI, a notarised translation carries either the translator's declaration signed by the notary or the notary's own declaration "concerning the original document and the translation". Usually the translator signs and takes an oath before the notary, who adds a seal "certifying that the signature is genuine", in the words of joint guidance from ITI, CIOL and the ATC.
What does a notary actually certify?
Signatures, identity and authority. The Faculty Office, which regulates notaries in England and Wales, says their principal role is to "attest the authenticity" of deeds and other documents for use abroad. The Notaries Society describes notaries as "primarily concerned with the authentication and certification of signatures, authority and capacity".
That joint guidance adds that "neither a Notary Public nor a solicitor will be certifying the translation itself." A notary's seal therefore does not repair a weak translation: if the translator's statement lacks a date or contact details, notarising it changes nothing.
The exception is a notary who is qualified in the language, such as a scrivener notary. The Faculty Office says scrivener notaries have "expertise in at least two foreign languages", and they are examined in translation and legal drafting in both.
Who are notaries in England and Wales, Scotland and Northern Ireland?
- England and Wales: notaries are appointed and regulated through the Faculty Office of the Archbishop of Canterbury and follow the Notaries Practice Rules 2019. "Notary" is a protected title. Most notaries are also solicitors, but "Solicitors are not authorised to carry out 'notarial acts' if they are not also notaries."
- Scotland: a qualified solicitor may apply to the Court of Session to be admitted as a notary public and entered on the register kept by the Law Society of Scotland (Solicitors (Scotland) Act 1980, section 57).
- Northern Ireland: notaries are appointed under section 112 of the Judicature (Northern Ireland) Act 1978, and the Department of Justice confirms that a notary "must be a practising solicitor of at least six years standing."
GOV.UK's Find a notary abroad page links to all three official finders.
Do UK authorities ask for notarised translations?
Rarely. Paragraph 39B(f) of the Immigration Rules lists everything a Home Office translation must contain, from the date to the translator's contact details and, in the UK, credentials. A notary appears nowhere. When Home Office guidance wants notarisation, it says so: the Ukraine Permission Extension guidance asks for an official guardianship document "notarised by the issuing country or the Ukrainian Embassy".
Court rules in England and Wales either offer a notary as one option or ask for the translator's own sworn evidence:
- Divorce in England and Wales: a marriage certificate not in English needs "a translation of that document verified by the translator and certified by a notary public or authenticated by a statement of truth" (Family Procedure Rules, Practice Direction 7A, paragraph 3.1).
- Registering a foreign judgment: the translation must be "certified by a notary public or other qualified person" or "accompanied by written evidence confirming that the translation is accurate" (Civil Procedure Rules, rule 74.4).
- A foreign-language affidavit: the translator must make and file their own affidavit "verifying the translation" (Practice Direction 32, paragraph 10.2). It is the closest civil procedure in England and Wales comes to a sworn translation.
For who may sign each of these, see who can certify a translation in the UK.
When do foreign authorities want notarisation, an apostille or a sworn translator?
Often. ITI notes that in civil-law countries such as France, Spain, Germany and Italy, sworn translators are appointed by government authorities, and that only listed sworn translators may produce an official translation in some of them. Two FCDO country pages show this in practice:
- Spain: for a marriage certificate presented to the Spanish Foreigners' Office, translations are "usually accepted" if made by a sworn translator, by the consulate of the country where the marriage took place, or by a translator there with that consulate's certification.
- Italy: to authenticate a translation of an education document, the FCDO tells British residents to ask a translator in Italy for a sworn translation ("traduzione giurata").
Where a UK translation is acceptable, the receiving authority will often want it notarised and apostilled. The reason is the 1961 Hague Apostille Convention: an apostille goes only on a public document, and a translator signs as a private person. A notary's certificate is a "notarial act", which the Convention treats as public, and the apostille then certifies "the authenticity of the signature, the capacity in which the person signing the document has acted" and the seal, not the translation.
Countries outside the Convention, such as the United Arab Emirates, use other legalisation procedures; as the Notaries Society notes, some want the FCDO's apostille and a further certificate from their own embassy. Membership changes (the Convention entered into force for Canada on 11 January 2024), so check the HCCH status table and ask the receiving authority before paying for anything. Our apostille guide explains the certificate itself.
Certified, notarised or apostilled: which do you need?
| Where the translation is going | What to ask for | Rule |
|---|---|---|
| Home Office: visas, leave to remain, ILR | Certified translation; no notary | Immigration Rules, para. 39B(f) |
| Divorce, England and Wales | Translator's verification plus a notary or a statement of truth | FPR PD 7A, para. 3.1 |
| Registering a foreign judgment | Notary or other qualified person, or written evidence of accuracy | CPR 74.4 |
| Authority in a Hague Convention country | Ask first: a local sworn translator, or a notarised translation with an apostille | FCDO country pages, HCCH |
| Authority in a non-Hague country | Notarised translation, apostille and usually the embassy's own legalisation; ask the embassy | Notaries Society |
Official Translations can supply a translation notarised and apostilled for use abroad: the certified translation is notarised and then apostilled, and the apostille is attached to our translation, not to your original document. An apostille on an original UK public document, such as a birth certificate, is a separate step issued by the FCDO Legalisation Office. If you need both, read translation and apostille: when you need both or see our apostille service.
Common mistakes
- Paying a notary for a Home Office application. The Immigration Rules ask for the translator's certificate, not a notary's.
- Notarising a defective translation. A seal does not add a missing date, contact details or credentials.
- Sending a UK translation to an office that wants a local sworn translator, as Spanish and Italian offices may.
- An apostille on the wrong document: the original when the authority wanted the translation apostilled, or the reverse.
Questions people ask
Do I need a notarised translation for a UK visa?
No. Paragraph 39B(f) of the Immigration Rules asks for a dated translation with the translator's confirmation of accuracy, full name, signature and contact details, plus a qualified translator's certification and credentials for applications made in the UK. No notary is involved.
Does the notary check that the translation is accurate?
Normally not. A notary authenticates the translator's identity and signature, and ITI says a notary's signature cannot endorse the quality of a translation unless the notary is a qualified ITI member in that language. Scrivener notaries are also examined in translation in two foreign languages.
Can a solicitor notarise a translation?
Only if the solicitor is also a notary: the Faculty Office says solicitors who are not notaries cannot carry out notarial acts. A solicitor can still certify a copy or witness a signature, and the FCDO will legalise documents certified by a UK solicitor, but a foreign authority that asks for a notarial certificate means a notary.
Is a sworn translation the same as a notarised translation?
No. A sworn translation is made under a foreign state's system, such as Spain's, by a translator appointed or sworn there, and is official in that country on its own. A notarised translation is a certified translation whose translator's signature a notary has authenticated; some foreign offices accept it with an apostille, while others insist on a local sworn translator, so ask first.
Can a notarised translation be electronic?
Sometimes. The Notaries Society says all notaries produce notarial documents on paper and some also issue secure electronic ones, but not every country accepts electronic documents. Ask the receiving authority which form it wants before you order.
Do I need a notary for a divorce in England and Wales?
Not necessarily. For a marriage certificate not in English, the family court rule accepts a translation verified by the translator and either certified by a notary or authenticated by a statement of truth, so a translator's statement of truth is enough.
