Certified, Notarised, Sworn, Apostilled — what is the difference?
Four terms that are often confused. The UK Home Office requires one. EU embassies require another. International courts require a third. We explain each and provide a comparison table for quick reference.
| Type | What it is | Who issues it | UK Home Office | UK university | EU embassy |
|---|---|---|---|---|---|
| Certified | Translation + Certificate of Accuracy from the translator | Translator (ITI, CIOL, etc.) | ✓ Accepted | ✓ Accepted | Depends on country |
| Notarised | Certified translation + notary witnesses translator's signature | Translator + UK notary | ✓ Accepted | ✓ Accepted | Often ✓ |
| Sworn | Translation from a translator who has sworn an oath to the state (EU system) | Sworn translator (EU) | If it contains a Certificate of Accuracy | Depends on university | ✓ In their countries |
| Apostilled | Apostille on the original document (not on the translation) | The country that issued the document | Sometimes required for the original | Sometimes for the original | Often for the original |
Certified translation — the UK approach
In the UK, "certified translation" means a translation accompanied by a Certificate of Accuracy — a signed statement from the translator confirming that the translation is complete and accurate, with their name, qualifications, and contact details.
This is what gov.uk/certifying-a-document requires: "a statement from the translator confirming it's a true translation of the original document, and their name and contact details."
A certified translation does not require notarisation. The translator personally takes responsibility for the accuracy and signs the certificate. This is the cheapest and fastest form of certification, and is sufficient for the vast majority of UK purposes.
Accepted by: Home Office, UKVI, UK ENIC (Ecctis), NHS, DVLA, HMRC, UK courts, UK universities (UCAS).
Notarised translation
A notarised translation is a certified translation to which a notary has additionally been involved. The notary witnesses the identity of the translator and the authenticity of their signature. The notary does not check the quality of the translation and does not take responsibility for its content.
When is a notarised translation needed in the UK? Rarely. Certain legal proceedings (court proceedings, asset transfers), some foreign embassies in the UK, and some banks for large transactions may require a notarised translation. The Home Office does not require notarisation for standard visa applications.
Important: a notarial stamp from Kazakhstan, Uzbekistan, Kyrgyzstan, Tajikistan, or Russia authenticates the signature of the local translator, but does not meet the UK format for a certified translation. UKVI regularly rejects such translations.
Sworn translator — the European approach
In Germany, France, Spain, Italy, the Netherlands, and several other EU countries, there is an official institution of sworn translators (Beeidigter Übersetzer, traducteur assermenté, traductor jurado). The translator takes an official oath before a court or state authority and gains the right to produce officially recognised translations for state proceedings.
There is no sworn translator system in the UK. Searching for "sworn translator in London" will lead to confusion — some translators use this term to mean simply "certified". The correct UK term is certified translator.
If a UK document needs to be submitted to a French court or a German authority, you will need a sworn translator from that country. If a document from Kazakhstan is needed by the UK Home Office, a certified translation from an ITI translator is sufficient.
A sworn translation from a European translator will be accepted by the Home Office if it contains a Certificate of Accuracy in the UK format. But the oath itself does not replace a Certificate of Accuracy.
Apostille — what it is and when it is needed
An apostille (Hague Apostille) is a stamp or sticker that a country party to the Apostille Convention (Convention of 5 October 1961) affixes to an official document. As of 2026 the Convention covers more than 120 countries.
An apostille authenticates the signature and seal of the official on the original document. It does not certify the content of the document and is not a translation. It is placed on the original document itself (or a separate sheet attached to it) — not on the translation.
For the UK: if you have a Kazakh birth certificate with an apostille, that is good — the document is legalised. But an apostille does not remove the need for a certified translation into English for the UK Home Office or UKVI.
CIS countries and the apostille: Kazakhstan joined the Hague Convention in 1999. Uzbekistan — 1992. Kyrgyzstan — 2016. Tajikistan — 2015. Russia — 1992. Ukraine — 2003.
Source on apostilles: hcch.net — Hague Convention of 1961
What you need — by situation
Certified translation with Certificate of Accuracy. Notarisation, apostille, and sworn oath are not required for standard visa applications. For ILR — check the requirements for specific documents.
Certified translation of degree and transcript. UK ENIC (Ecctis) also accepts certified translations. Notarised and sworn translations are not required.
Sworn translation from a translator accredited in that country, or a notarised translation. Always check with the specific embassy.
Depends on the jurisdiction. Generally, a notarised translation plus an apostille on the original document. Consult the lawyer representing you.
Related guides
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