Two British retirees can move to Lisbon and Madrid in the same month with identical paperwork and meet opposite translation rules. Portugal's immigration agency, AIMA, says documents in English "não necessitam de tradução" (need no translation). Spain's consulate in London wants a sworn translation into Spanish of the police certificate and the medical certificate, made by a translator registered in Spain.
That is residency after Brexit: UK nationals arriving now are third-country nationals, and each country sets its own document rules. Below: what changed, the documents, five countries' rules, apostilles, translators and timing.
What changed for UK nationals moving to the EU after Brexit?
You now need a visa or residence permit to stay more than 90 days in any 180-day period, as the German missions in the UK confirm. People who lived in an EU country before 1 January 2021 keep their rights under the Withdrawal Agreement, and their close family members can still join them if the relationship began by 31 December 2020.
New arrivals also lost two shortcuts that EU documents still enjoy:
- The apostille exemption. Spain's consulate exempts "official documents issued by a Member State of the European Union" from legalisation. UK documents need an apostille.
- Multilingual forms. Some EU civil documents can be used elsewhere in the EU untranslated if a multilingual standard form is attached, and Italy's consulate in London accepts Schengen-country certificates "only if multilingual". UK certificates have no such form.
Which UK documents does an EU residence application need?
The lists vary by country and route, but the same UK documents keep appearing:
| Document | Who asks, for example | What to know |
|---|---|---|
| ACRO police certificate | Spain's non-working residence visa; Portugal's residence visas | Paper apostille only; Spain accepts it no more than 6 months old. See DBS and police checks for use abroad |
| Full birth certificate | France's visitor residence card: a copie intégrale; family members in Spain and Italy | Order the version with the parents' details. See apostilles on UK birth certificates |
| Marriage or civil partnership certificate | A spouse coming with you to Spain or Italy | Italy's consulate refuses marriage certificates older than 6 months. See apostilles on UK marriage certificates |
| Medical certificate | Spain: from a registered practitioner, within 3 months, in prescribed wording | Apostille and a sworn translation into Spanish |
| Proof of income or pension | Spain: 400% of the IPREM index a month; France: €1,477.93 net a month (June 2026); Italy: pensions, annuities, property or investment income | Bank and pension letters; ask whether English is accepted |
| Health insurance | Spain and Portugal accept the UK S1 form in place of private insurance for some visas | Private policies must meet each country's rules |
| Proof of accommodation | Italy: a registered lease or deed; France: proof of address under 6 months old | Usually local documents, already in the right language |
What do Spain, France, Portugal, Italy and Germany require?
Spain
Apply before you go, at the Spanish consulate for your area in London, Manchester or Edinburgh, then apply for a foreigner identity card (TIE) within a month of arriving. For the non-working residence visa, the London consulate's page (6 July 2026) lists the criminal record certificate ("For UK Criminal Records submit ACRO Certificate"), the medical certificate and family certificates, all apostilled. It states: "Sworn translation into Spanish is also required." The consulate says a translation for use in Spain should come from a sworn translator-interpreter registered in Spain, and Spain's foreign ministry says translations by the sworn translators it appoints "tendrán carácter oficial" (have official status).
France
Apply for a long-stay visa through France-Visas, then validate it or apply for a residence permit online. The visitor card asks for a full copy of your birth certificate "comportant les mentions les plus récentes" (with the most recent annotations). The Interior Ministry's online checklist for student residence permits, for one, asks for a translation of every document in a foreign language and points to the list of traducteurs agréés: translators on the lists of French courts of appeal and the Cour de cassation. Abroad, service-public.fr points to translators approved by local authorities, with the signature certified by the French consulate.
Portugal
Get a residence visa from the Portuguese consulate in London, which takes applications through VFS Global, or in Manchester; it allows two entries and is valid for 4 months, during which you apply to AIMA for a residence permit. The visa portal asks for a criminal record certificate "with the Hague Apostille". On language, AIMA says documents in English, French and Spanish need no translation, citing the Civil Registry Code; Portugal's registry service applies that waiver when the official handling the file understands the language. Other translations must be certified by a Portuguese notary, registry official, lawyer or solicitador, a recognised chamber of commerce or a consulate.
Italy
Apply at the Italian consulate for your area, such as London for the elective residence visa, which wants proof of substantial private income, a registered lease or deed for property in Italy and, for a spouse, a marriage certificate no more than 6 months old. At that stage only certificates from countries other than the UK must be translated, into English or Italian. Once in Italy you must apply for a residence permit (permesso di soggiorno) within 8 days. For other Italian uses, the consulate says British documents need a sworn translator in Italy, or a prepared translation "sworn before an Italian Court, an Italian Municipality, or a notary".
Germany
British citizens can apply for a residence permit after arriving, without a visa: register your address within 2 weeks and apply to the local immigration office (Ausländerbehörde) within 90 days. German administrative law makes German the official language: section 23 of the Administrative Procedure Act says an authority "soll" (should) ask for a translation of foreign-language documents and, in justified cases, a certified one or one by a publicly appointed or sworn translator. Ask your office what it accepts in English.
Netherlands and Ireland: the Dutch IND accepts documents in Dutch, English, French or German, and the Dutch government says "Documents in English do not have to be translated". British nationals need no visa to live, work or study in Ireland.
Do UK documents need an apostille for EU residency?
Usually, yes: every country above is a party to the Apostille Convention, and UK documents no longer get the EU exemption. GRO certificates and ACRO police certificates can only get a paper apostille from the FCDO Legalisation Office, at £45 per document plus courier or postage, and in October 2026 the service was quoting 15 working days from receipt.
Two rules decide what you send. Spain's consulate wants the apostille to legalise the signature of the person who issued the certificate, "police officers, etc.", not a notary who copied it. And the translation comes after the apostille, so it can cover it where the authority wants it translated. The order of steps is set out in translation and apostille: when you need both.
Who can translate UK documents for EU authorities?
The receiving country decides, and the answers fall into four groups:
| Rule | Countries in this guide | What it means for a UK translation |
|---|---|---|
| A translator from the country's own system | Spain (sworn translators appointed by the foreign ministry); France (traducteurs agréés); Italy (translation sworn in Italy) | A UK certified translation does not meet the rule |
| Translation on request, sometimes sworn | Germany: offices should ask for a translation and, in justified cases, a certified or sworn one | Ask the office what it accepts |
| Certification in the country | Portugal, for languages other than English, French and Spanish | The translation needs a Portuguese notary's, lawyer's or consulate's certification |
| English accepted | The Netherlands; Portugal's AIMA where the official reads English | No translation needed unless asked |
Official Translations does not provide sworn translations under Spanish, French or Italian law, so for those steps use a translator on the destination's list. Where an authority accepts a certified translation, or one notarised and apostilled, we can provide it: with our apostille service, the certified translation is notarised and then apostilled, and that apostille is attached to the translation, not to your original document.
How should I plan the timing?
Work backwards from the appointment, because documents expire on the way:
- Fix the appointment date and list each document's age limit: 6 months for Spain's police certificate, 3 months for its medical certificate, 6 months for Italy's marriage certificate.
- Order certificates in time to apostille them: ACRO allows up to 20 working days, and the FCDO 15 to 25 more, plus postage.
- Translate once the apostilles are attached, with the translator the destination requires.
- After arrival, watch the local deadlines: 8 days for an Italian residence permit, a month for a Spanish TIE, 2 weeks to register an address in Germany. Moving with a car or a UK licence adds its own steps; see exchanging a UK driving licence abroad.
Common mistakes with EU residence documents
- A basic DBS check where Spain asked for the ACRO certificate.
- A short birth certificate where France wants the full copy with annotations.
- An apostille on a solicitor's copy where the issuer's signature was meant to be legalised.
- A UK certified translation for a Spanish or French procedure that requires a sworn or court-approved translator.
- Certificates too old on the day, such as a marriage certificate over 6 months old for Italy.
- Paying for translations the Netherlands does not require, or that Portugal's AIMA may waive.
Checklist: UK documents for an EU residence permit
Questions people ask
Do I need to translate my UK documents to live in the EU?
Usually, if the country's language is not English, but the rule depends on the country. Spain wants sworn translations into Spanish, and France and Italy point to their own approved or sworn translators, while the Dutch IND accepts documents in English and Portugal's AIMA usually does.
Can I use a UK certified translation in Spain?
Not where Spain requires a sworn translation, as its London consulate does for residence visa documents. Official status goes to translations by sworn translators appointed by Spain's foreign ministry, and the consulate lists those registered in Spain who live in the UK.
Does Portugal accept UK documents in English?
AIMA, Portugal's immigration agency, says documents in English, French and Spanish need no translation, citing the Civil Registry Code, which ties the waiver to the official understanding the language. They still need an apostille where one is asked for, such as on the criminal record certificate for a residence visa.
Do I need an apostille on my birth certificate for EU residency?
Usually, yes. Spain's consulate wants family certificates apostilled, Portugal's AIMA recognises documents from Convention countries by apostille, and the Netherlands wants UK civil status records apostilled. A GRO birth certificate can only get a paper apostille from the FCDO, at £45 per document plus courier or postage.
I moved to the EU before 2021. Do these rules apply to me?
Not to your residence rights, which the Withdrawal Agreement protects. Close family members whose relationship with you began by 31 December 2020 can still join you, but they will need their own documents, usually apostilled and translated under the country's rules.
How recent do the documents need to be?
It depends on the authority. Spain's consulate accepts police certificates up to 6 months old and medical certificates up to 3 months old, and Italy's consulate refuses marriage certificates older than 6 months. Plan so that each document is still in date at your appointment.
How much does a translation cost and how long does it take?
Official Translations charges £29.95 per page, a page being up to 300 words, for a complete certified translation. Most single-page documents are delivered as a signed PDF within 24 hours, and longer ones in 1 to 3 business days; check first whether your destination accepts it.
