A Portuguese company needing to present official documents in another country almost always encounters the same requirement: the apostille. Without it, certificates, deeds, diplomas, and powers of attorney carry no legal weight outside national territory. Understanding exactly what an apostille is, who issues it, and how it relates to certified translation avoids costly delays.
What an Apostille Is and When It Is Required
An apostille is an international certification created by the Hague Convention of 1961 (Convention Abolishing the Requirement of Legalisation for Foreign Public Documents). It authenticates the signature, seal, and capacity of the signatory on a public document — it does not certify the content itself.
An apostille is required whenever a Portuguese public document must take legal effect in a country that is also a party to the Convention. The list covers more than 125 countries, including the United States, Brazil, Spain, Germany, France, and the United Kingdom. For non-signatory countries — such as Angola and Mozambique — a separate consular legalisation process applies.
- Birth, marriage, and death certificates
- Academic diplomas and certificates
- Notarised powers of attorney and deeds
- Court orders and judicial documents
- Commercial registrations and company articles of association
Who Issues Apostilles in Portugal
In Portugal, the authority responsible for issuing an apostille depends on the nature of the document:
- Notarial and civil registry documents: the relevant Conservatória (registry office) or IRN (Instituto dos Registos e do Notariado) services
- Judicial documents: the issuing court or the Ministry of Justice
- Academic documents: the Directorate-General for Higher Education or the Directorate-General for Education
- Administrative documents: the competent ministry for the relevant area
Requests can be submitted in person or, in many cases, through the ePortugal.gov.pt portal using digital identification. Processing typically takes a few working days, though timeframes vary by service and demand.
Apostille and Certified Translation: How They Work Together
An apostille and a translation are two distinct, complementary steps. The apostille certifies the authenticity of the original document — it does not translate or adapt the content. When the destination country requires documentation in a language other than Portuguese, a certified or sworn translation is also necessary.
The correct sequence is generally:
- Obtain the original document in a valid, up-to-date form
- Have the original apostilled by the competent authority
- Commission a certified translation of the apostilled document
Some countries — and certain receiving institutions — require the translation itself to be apostilled as well. This typically means the translator must be a formally recognised professional, or the translation must be notarially authenticated before the apostille is applied. The specific requirements of the destination country and receiving body should always be confirmed before starting the process.
A common mistake is submitting the document to a foreign authority without an apostille, or apostilling an uncertified copy. Either situation requires restarting the process from the beginning.
For Countries Not Party to the Hague Convention
Angola and Mozambique have not acceded to the Hague Convention, so apostilles are not recognised there. The applicable process is consular legalisation, which follows a chain of authentications:
- Authentication of the document by the issuing authority
- Recognition by the Ministry of Foreign Affairs (or equivalent body)
- Legalisation by the destination country’s consulate in Portugal
This process is more time-consuming and involves additional costs. Certified translation remains necessary and must be coordinated with each stage of the legalisation chain.
Certified Translation of Apostilled Documents with M21Global
M21Global provides certified translations of apostilled documents across more than 50 language pairs, with specific expertise in Lusophone, European, and African markets. For processes involving Angola or Mozambique — where consular legalisation replaces the apostille — the team is familiar with the documentary requirements of each jurisdiction. Holding ISO 17100:2015 certification, M21Global’s translations meet the standards required by public authorities, financial institutions, and judicial bodies.
