What is an Apostille? | How to Get an Apostille in Turkey?

An Apostille is an international document certification system that authenticates a document, allowing it to be legally used in another country. Its primary purpose is to eliminate the long, costly, and bureaucratic diplomatic approval processes known as the “chain of certification” (consular legalization) required for an official document issued in one country to be valid in another member country.

Crucially, and contrary to common misconception, the function of an Apostille is not to confirm the content of the document. An Apostille only certifies the authenticity of the signature on the document, the capacity in which the person signing the document acted (e.g., notary, court president), and the authenticity of the seal or stamp affixed to the document. In other words, an Apostille on a court decision does not confirm that the decision is legally correct, but rather that it is an official document genuinely issued by the claimed court (that the signature and seal are real).

Legal Basis: The Hague Convention of 5 October 1961

The entire legal framework for the Apostille system was established by the “Hague Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents” (Convention de La Haye du 5 Octobre 1961), prepared by the Hague Conference on Private International Law (HCCH).

This convention was ratified in Turkey in 1984 and entered into force on September 29, 1985. Since that date, Turkey has applied the Apostille system for the exchange of official documents with other countries party to the Convention.

This system brought about a radical simplification in international legal transactions. Previously, a Turkish document (e.g., a power of attorney) to be used in Germany required a chain of certifications (Governor’s Office, Ministry of Foreign Affairs, and the German Consulate). Apostille reduced this process to a single step (Governor’s Office approval).

Countries Party to the Apostille Convention

The following table shows the current list of countries party to the Hague Convention of 5 October 1961 (Apostille Convention). Official documents exchanged between these countries are exempt from consular legalization and are used only with an Apostille certificate.

AlbaniaDenmarkIrelandNorway
AndorraDominicaIsraelOman
Antigua and BarbudaDominican RepublicItalyPalau
ArgentinaEcuadorJamaicaPanama
ArmeniaEl SalvadorJapanParaguay
AustraliaEstoniaKazakhstanPeru
AustriaEswatiniKorea (Republic of)Philippines
AzerbaijanFijiKosovoPoland
BahamasFinlandKyrgyzstanPortugal
BahrainFranceLatviaRomania
BarbadosGeorgiaLesothoRussian Federation
BelarusGermanyLiberiaSaint Kitts and Nevis
BelgiumGreeceLiechtensteinSaint Lucia
BelizeGrenadaLithuaniaSaint Vincent and the Grenadines
BoliviaGuatemalaLuxembourgSamoa
Bosnia and HerzegovinaGuyanaMacao (China)San Marino
BotswanaHondurasMalawiSao Tome and Principe
BrazilHong Kong (China)MaltaSaudi Arabia
Brunei DarussalamHungaryMarshall IslandsSenegal
BulgariaIcelandMauritiusSerbia
BurundiIndiaMexicoSeychelles
Cabo VerdeIndonesiaMoldova (Republic of)Singapore
CanadaMonacoSlovakia
ChileMongoliaSlovenia
ChinaMontenegroSouth Africa
ColombiaMoroccoSpain
Cook IslandsNamibiaSuriname
Costa RicaNetherlandsSweden
CroatiaNew ZealandSwitzerland
CyprusNicaraguaTajikistan
Czech RepublicNiueTonga
North MacedoniaTrinidad and Tobago
Turkey
Tunisia
Ukraine
United Kingdom
United States of America
Uruguay
Uzbekistan
Vanuatu
Venezuela

(Note: List is updated based on HCCH data. The official HCCH website should be checked for the most current status.)

What are the Mandatory Elements of an Apostille?

For an Apostille to be valid, it must adhere to strict standardization. The main heading must be in French: “Apostille (Convention de La Haye du 5 Octobre 1961)”. This allows the foreign authority to immediately recognize the document.

Below this heading, the certificate consists of 10 standardized and numbered fields:

  1. Country of origin (e.g., TURKEY)

  2. Name of the person who signed the document

  3. Capacity of the signatory (e.g., Notary, Deputy Governor)

  4. Name of the authority whose seal is on the document (e.g., Governorship of Istanbul)

  5. Place of certification (e.g., Istanbul)

  6. Date of certification

  7. Authority issuing the Apostille (e.g., Governorship of Istanbul)

  8. Apostille number

  9. Seal or stamp of the issuing authority

  10. Signature of the officer issuing the Apostille

This 10-point structure is a universal format that transcends language barriers.

Which Documents Can Be Apostilled?

The Convention applies to “public documents,” but has two very clear exceptions.

Public Documents Covered by the Convention

According to Article 1 of the Convention, an Apostille can be applied to:

  • Judicial Documents: Documents issued by a court or an official connected to the judiciary.

    • Examples: Court decisions (divorce decrees, debt claims), criminal records.

  • Administrative Documents: Documents issued by an administrative authority.

    • Examples: Civil status documents (birth, marriage, death certificates), diplomas (high school, university), transcripts.

  • Notarial Acts: Documents executed or certified by a notary public.

    • Examples: Powers of attorney, declarations, notarized sworn translations.

  • Official Certifications on Private Documents: Official statements placed on private documents, such as certifying the authenticity of a signature or the date of a document (Notarized copies, company signature circulars).

Documents Excluded from the Convention (Critical Exceptions)

The Convention clearly excludes two categories of documents. These cannot be Apostilled:

  1. Documents executed by diplomatic or consular agents: Documents issued by consulates or embassies (e.g., a marriage certificate issued at a consulate).

  2. Administrative documents dealing directly with commercial or customs operations: This is the most confusing exception. Commercial invoices, certificates of origin, or customs declarations cannot be directly Apostilled.

Practical Workaround (Indirect Apostille):

A commercial invoice itself cannot be Apostilled, but one can obtain a notarized copy of it. This notarized copy is no longer a “commercial document” but a “notarial act,” which is covered by the Convention. The Apostille is then applied not to the invoice, but to the signature and seal of the notary who certified the copy.

Procedure for Non-Party Countries (Consular Legalization)

The Apostille system is only valid between member countries. For a country not party to the Convention (e.g., Canada, Saudi Arabia), an Apostille issued in Turkey has no legal validity.

For these countries, the old “consular legalization” (chain of certification) process is still required:

  1. Certification by the Governor/Sub-Governor.

  2. Certification by the Turkish Ministry of Foreign Affairs.

  3. Certification by the Consulate or Embassy of the destination country in Turkey.

This process is much slower and more expensive.

Which Authorities Issue Apostilles in Turkey?

The authority to issue an Apostille in Turkey is divided between two different public institutions, depending on the type of document.

1. Administrative Documents: Civil Administration (Governorates and Sub-Governorates)

For administrative documents (and notarial acts), the issuing authorities are:

  • In Provinces: Governorates (Valilikler)

  • In Districts: Sub-Governorates (Kaymakamlıklar)

This decentralized authority allows citizens to obtain an Apostille for documents like birth certificates, diplomas, or powers of attorney in their local district without having to travel to the provincial capital.

2. Judicial Documents: Judicial Administration (Justice Commissions)

For judicial documents (court decisions, criminal records), the issuing authority is:

  • Presidencies of the First Instance Court Judicial Justice Commissions located in centers where a Heavy Penal Court is established.

This means a citizen in a small district can go to the local Sub-Governorate for an administrative document, but must travel to the central courthouse in the provincial capital (where the Justice Commission is located) for a judicial document.

Competent Authority Guide

Document TypeIssuing/Approving BodyApostille Authority
Civil Registry Extract (Birth, Marriage)District/Provincial Civil RegistryGovernorate / Sub-Governorate
High School DiplomaDistrict/Provincial Directorate of National EducationGovernorate / Sub-Governorate
University DiplomaUniversity RectorateGovernorate / Sub-Governorate
Power of Attorney / DeclarationNotary PublicGovernorate / Sub-Governorate
Notarized Sworn TranslationNotary PublicGovernorate / Sub-Governorate
Court Decision (Divorce, etc.)Court Clerk’s Office (with finalization stamp)Judicial Justice Commission Presidency
Criminal RecordCourthouse or e-DevletJudicial Justice Commission Presidency

How Does the Physical (Traditional) Apostille Process Work?

Once the competent authority is determined, the physical application process is usually simple and fast.

Required Documents:

  1. The original document to be Apostilled (Apostille is applied to the original, not a photocopy).

  2. One photocopy of the document (usually for the authority’s records).

  3. Photocopy of the applicant’s ID.

Application Steps:

  1. Submission: The documents are submitted to the officer at the competent authority (e.g., Legal Affairs Directorate at the Governorate).

  2. Verification: The officer checks the original document and verifies the authenticity of the signature and seal against their records.

  3. Certification: Once verified, the standard 10-point Apostille stamp is affixed (usually on the back).

  4. Completion: The fields are filled in, the Apostille is signed by the authorized official (e.g., Deputy Governor) and stamped with the authority’s seal.

Cost: Physical Apostille services provided by Governorates and Sub-Governorates for administrative and notarial documents are free of charge.

What is the Electronic Apostille (e-Apostille) System?

Turkey has digitized the Apostille process, creating the “e-Apostille” system. This system eliminates the need for citizens to physically go to an institution for certain documents.

How Does e-Apostille Work?

An e-Apostille is a digital Apostille certificate issued for a completely electronic document. The system operates via the e-Devlet portal (www.turkiye.gov.tr), integrated with databases like the Ministry of Justice (UYAP) and Ministry of Interior (MERNIS).

Which Documents Can Get an e-Apostille? (Current List)

As of 2025, e-Apostille is available for documents that can be instantly and digitally verified from a central database:

  • Criminal Record

  • Court Decisions

  • Civil Registry Extract (Nüfus Kayıt Örneği)

  • Birth Certificate Extract

  • Death Certificate Extract

  • Marriage Certificate Extract

Which Documents Cannot Get an e-Apostille?

e-Apostille is not available for the following documents (as of late 2024), as they cannot be centrally verified:

  • Name Equivalence Certificate

  • Diploma

  • Transcript

  • Company formation documents, powers of attorney, etc.

Users with these documents must follow the physical application process described in Section IV (bringing the original document to the Governorate/Sub-Governorate).

e-Apostille Application and Fees

Unlike the free physical process, the e-Apostille service is paid. A service fee is charged for each document (e.g., 80 TL for a Criminal Record, 160 TL for a Court Decision). This offers users a choice:

  • Physical Path: Spend time to go to the courthouse/governorate and get it for free.

  • Digital Path: Apply instantly via e-Devlet, save time, but pay the service fee.

Special Cases and Practical Considerations

The Apostille Process for Translated Documents (Critical Order of Operations)

The most common mistake in practice involves the correct sequence for documents that require both translation and Apostille (e.g., a Diploma for use in Germany).

The Correct and Legally Valid Sequence:

  1. Step 1: Sworn Translation: The original document (e.g., Diploma) is translated into the target language (e.g., German) by a sworn translator.

  2. Step 2: Notary Certification: This translation is taken to a Notary Public to be certified. The notary confirms the translator is sworn with their office and the signature is authentic.

  3. Step 3: Apostille: This notarized translation, now considered a “notarial act,” is taken to the Governorate or Sub-Governorate to receive the Apostille.

In this correct process, the Apostille is not applied to the German translation, but to the signature and seal of the Turkish notary who certified the translation.

Does an Apostille Certificate Expire?

The Apostille certificate itself does not have an expiration date.

However, its validity is tied to the validity of the document it is attached to:

  • Permanent Documents: An Apostille on a non-expiring document (like a diploma, finalized divorce decree, or birth certificate) is valid indefinitely.

  • Temporary Documents: An Apostille on a document with a natural expiry (like a Criminal Record, often valid for 3 months) effectively loses its value when the underlying document expires.

Apostille Verification (Security)

To ensure security and prevent fraud, issued certificates (especially e-Apostilles) can be verified. “Apostille Document Verification” services on the e-Devlet portal allow confirmation of the Apostille’s authenticity using the number on the certificate.

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