Since the UK left the European Union on 31 January 2020, the rules for using UK documents in EU countries have changed. Before Brexit, many UK public documents were accepted across the EU without the need for an apostille, thanks to EU Regulation 2016/1191 which simplified the circulation of public documents between member states. That regulation no longer applies to the UK. Understanding what changed - and what did not - avoids confusion and prevents documents from being rejected.
What changed
Under the EU regulation, certain UK public documents - including birth, death and marriage certificates, criminal record certificates and some educational documents - were accepted by EU authorities without an apostille. That automatic recognition ended when the UK left the EU. EU countries may now require UK documents to be apostilled before they will accept them for immigration, residency, marriage, employment and legal purposes. Some EU member states - including Italy, Spain and Denmark - may additionally require translation on top of the apostille, depending on the document type and its intended use.
What did not change
The UK remains a member of the Hague Apostille Convention. The apostille process itself has not changed - the FCDO still issues apostilles in the same way, authenticating the wet-ink signature, seal or stamp on the document. The apostille is still a physical paper certificate attached to the back of the original document or is obtained in an electronic format where applicable. All Hague Convention member countries - including every EU member state - are required to accept a valid apostille. The change is that UK documents now need an apostille for EU use, where before they often did not.
Which documents are affected
The documents most commonly affected are birth, marriage and death certificates submitted for EU residency or marriage purposes; degree certificates and professional qualifications submitted for EU employment or licensing; criminal record certificates required for EU visa or work applications; and commercial documents such as company certificates and powers of attorney submitted for business purposes in EU jurisdictions.
What this means in practice
If a UK document is being submitted to any EU country authority for official purposes, check whether an apostille is now required. In most cases it will be. The process is straightforward - the FCDO issues the apostille/ e-apostille, and the document is then accepted by the EU authority. Allow time for the apostille processing, and confirm whether a sworn translation is also needed for the destination country.
Get in touch
Call our team on +44 (0) 204 646 9300 to confirm what is required for your specific document and EU destination. The requirements vary by country and document type, and confirming in advance prevents rejection.