Certified Translation vs Notarised Translation vs Apostille

Published by LodgeHQ Editorial Team·

Quick summary: A certified translation says a qualified translator produced it. Notarisation says a notary public witnessed a signature, turning a private document into a public one. Legalisation — an apostille or an authentication certificate from DFAT — says the signature, stamp or seal on an Australian document is genuine, so a foreign government will accept it. They are three separate steps for three separate problems, and most people ordering a translation need only the first.

These three terms get used interchangeably by people selling translation services, and they are not interchangeable at all.

The cost of the confusion runs both ways. Order too little and your document is rejected. Order all three when you needed one and you have paid for a notary and a government service you had no use for.

The deciding question is never what a translation company recommends. It is what the organisation receiving the document requires.

Certified translation

A NAATI-certified translation is one produced by a translator NAATI has certified in the relevant language direction, and identified with their practitioner number and stamp.

This is the step almost every Australian purpose needs, and for lodgements inside Australia it is usually the only step. A visa application, a citizenship application, a police clearance translation — these ask for a certified translation and nothing further.

What certification asserts is narrow and useful: a qualified person produced this translation, and you can verify who they were.

Notarisation

A notary public witnesses a signature and attests to it.

The key thing notarisation does, in the Australian legalisation system, is change a document's category. DFAT explains that it can legalise private documents once they have been notarised by an Australian notary public — because notarisation turns a private document into a public document.

So notarisation is not a quality check on a translation. It is a step that makes certain documents eligible for the next step.

Note what DFAT will legalise without notarisation: originals issued by Australian government agencies or officials, and originals issued by Australian tertiary education institutions. Other Australian documents must be notarised in Australia first.

Legalisation: apostille or authentication

Legalisation is the step that involves the Australian Government, and it exists for one reason — using an Australian document overseas.

DFAT describes legalisation as the process of verifying that a signature, stamp or seal on a document is genuine, and then making a statement on the document to that effect. It issues either:

  • an apostille, or
  • an authentication certificate

Which one you get depends on the destination country's requirements. The government of each country can only legalise documents issued in that country, so Australia legalises Australian documents and nothing else.

The critical qualifier

DFAT is emphatic on a point that saves people a great deal of money: you must ask the receiving authority what they want and which documents must be legalised. DFAT cannot tell you what an authority in another country needs.

And it adds the observation people least expect: many overseas authorities do not ask for legalised documents at all. They may accept your originals or copies as they are.

How translations fit into legalisation

If your translated document is going overseas and does need legalising, DFAT sets specific requirements, and they are stricter than an ordinary certified translation.

A translation submitted for legalisation must include:

  • the translator's name and signature
  • the official NAATI seal or stamp, including their practitioner ID
  • the date of translation

You must also submit a copy of the original document carrying a signature or seal from the translator. And critically, all of that must appear on every page.

DFAT states that the Australian government endorses NAATI for translations, and that it only accepts translations completed by a NAATI certified or recognised translator.

The requirements in NAATI's fuller form

NAATI publishes DFAT's requirements in more detail, and the list is worth checking against a translation before you submit it. The stamp — physical or digital — must clearly show the practitioner ID; the language and type of certification; the translator's name; the date of translation for a physical stamp, or the date the stamp was generated for a digital one; the signature for a physical stamp, or "Digitally Authenticated by NAATI" for a digital one; and, for digital stamps, a clearly legible web address below the QR code.

That last item fails when a digital stamp has been resized too small, which is a good reason not to re-compress a translated PDF before submitting it.

One date rule to know

From 1 July 2018, DFAT accepts only translations completed by translators holding NAATI certification under the current Certification System, including Recognised Practising credentials. It no longer accepts translations done by a translator holding an accreditation under the former system.

Translations dated before 1 July 2018 are not affected and are still accepted.

This is a narrower rule than NAATI's general position, under which old accreditation-era translations remain valid indefinitely. For DFAT legalisation specifically, the date and the credential type both matter.

A note on Australian government stamps

If your document carries an official Australian government seal or stamp, translators are told not to alter its appearance. Stamps and seals should remain in their original format, and where clarification is needed the word "Seal" can be added in brackets alongside.

Which do you actually need?

Work through it in this order:

  1. Where is the document going? Staying in Australia — almost certainly a certified translation only. Going overseas — continue.
  2. Ask the receiving authority overseas exactly what they require, or ask an official at their embassy or consulate in Australia. This is DFAT's own instruction and it is the step people skip.
  3. If they want legalisation, check whether your document is one DFAT can legalise directly, or whether it must be notarised first.
  4. If a translation is involved, make sure it meets the fuller stamp-and-signature requirements on every page, with a signed or stamped copy of the original attached.

What each one does not do

Certification does not guarantee acceptance. It says a qualified translator did the work. Individual organisations still set their own rules.

Notarisation does not verify a translation's accuracy. A notary witnesses a signature; they are not assessing the translation.

An apostille does not validate content. DFAT verifies that a signature, stamp or seal is genuine. It is not endorsing what the document says.

Before you order

The single highest-value action is asking the receiving authority first, in writing. Everything else follows from their answer, and the answer is frequently simpler than expected.

DFAT's guidance on documents it can legalise and NAATI's summary of DFAT requirements for translators are the authoritative references, and both are updated over time.

If you need the certified translation itself, LodgeHQ Translate works only with NAATI-certified translators and supplies the practitioner details with every job.

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