When a UK document needs to be used abroad, you may be asked to have it certified, notarised or legalised. These terms are often used together, but they do not mean the same thing.
One of the most common questions is whether a document needs a solicitor or a Notary Public. The answer depends on the document, the destination country and the authority that will receive it.
What a solicitor can do
A UK solicitor can certify copies, witness signatures and confirm certain facts about a document.
Solicitor certification is often used for passport copies, proof of address, company documents, academic records, bank statements, medical letters and other private documents.
If the solicitor’s signature is recognised for legalisation, the document can often be submitted for the next stage.
What a Notary Public does
A Notary Public is a specialist legal professional whose work is commonly used for international documents.
A notary can verify identity, witness signatures, certify copies, prepare notarial certificates and confirm that documents have been executed properly.
Notarisation is often requested for Powers of Attorney, property documents, company records, commercial contracts, bank documents and documents going to countries with stricter notarial requirements.
Why the distinction matters
Some overseas authorities will accept solicitor certification. Others specifically require notarisation.
If a foreign bank, land registry, lawyer or government body asks for a notarised document, a solicitor-certified version may be rejected.
This can cause delays, extra cost and the need to prepare the document again.
Documents often certified by a solicitor
Solicitor certification may be suitable for many straightforward documents.
Examples include passport copies, utility bills, bank statements, academic certificates, medical letters, employment letters, company extracts and certain signed declarations.
However, the final decision depends on the receiving authority’s instructions.
Documents often notarised
Notarisation is commonly requested for documents with legal or commercial consequences abroad.
This can include Powers of Attorney, property sale or purchase documents, company resolutions, director authority documents, international contracts, affidavits and documents for overseas banks.
Notarisation may also be required where the destination country expects a notarial format rather than simple certification.
Legalisation after certification or notarisation
Certification or notarisation is often only the first step.
If the document is going abroad, it may also need legalisation. Legalisation confirms the signature, stamp or seal of the solicitor or Notary Public.
It does not confirm that the document content is correct. It confirms that the UK signature or seal can be recognised for international use.
Translation requirements
If the receiving authority does not accept English, the document may also need a certified or sworn translation.
The order matters. In many cases, the document is certified or notarised first, then legalised, then translated.
Some countries may require the translation to be completed by a local sworn translator or legalised separately.
Embassy attestation for some countries
For countries that are members of the Hague Apostille Convention, UK legalisation is often the main authentication step.
For countries outside the Convention, embassy or consular attestation may also be required after UK legalisation.
This can affect whether solicitor certification is enough or whether notarisation is expected from the start.
Ask the receiving authority first
Before choosing a solicitor or notary, ask the foreign authority exactly what they require.
Check whether they need a certified copy, a notarised document, a witnessed signature, legalisation, translation or embassy attestation.
If you are unsure whether your document needs a solicitor or Notary Public, 12 Apostille can review the requirements and help confirm the correct route before the document is prepared.