Apostille or Legalization for Export Documents: Which Countries Accept an Apostille (2026)
An apostille is a single certificate, issued by a competent authority in the country where a public document was made, that replaces the chain of consular legalization when the document is used in another member of the 1961 Hague Apostille Convention. The Convention had 130 contracting parties in October 2026, including China (since 7 November 2023), Canada (11 January 2024), Bangladesh (30 March 2025), Algeria (9 July 2026) and Viet Nam (11 September 2026); Thailand joins on 28 February 2027. For countries outside it, such as the United Arab Emirates, documents still need legalization through the destination country's embassy or consulate. The Convention excludes administrative documents dealing directly with commercial or customs operations, but many members now issue apostilles for them.
Checked against official sources: 2026-10
At a glance
Apostille or consular legalization
Legalization is the chain of certifications that proves a foreign document's signature or seal is genuine: typically a certification by a ministry in the issuing country and then by the destination country's embassy or consulate. Under the 1961 Apostille Convention, when both countries are contracting parties, one apostille from the competent authority of the issuing country replaces that chain, and the destination country may not ask for more.
The Convention applies to public documents: documents from courts and public authorities, administrative documents, notarial acts and official certificates placed on private documents, such as an official certification of a signature. A private document like a commercial invoice or a company letter is therefore usually notarised or officially certified first, and the apostille is attached to that certification.
Commercial and customs documents
Article 1(3)(b) excludes "administrative documents dealing directly with commercial or customs operations". The drafters had in mind documents such as certificates of origin and import and export licences. Since 2009 the HCCH's Special Commissions have said this exclusion should be interpreted narrowly, and later extremely narrowly, and in 2021 they encouraged receiving States to accept apostilles even for excluded documents. Many contracting parties now issue apostilles for such documents, but practice varies, so ask the issuing authority and the importer or authority that will receive the document what they accept. Some countries' guidance on joining the Convention, such as commentary on Viet Nam's accession, still lists trade and customs documents as outside its scope.
Who is a member: check before you send documents
- China (since 7 November 2023), Canada (11 January 2024), Bangladesh (30 March 2025), Algeria (9 July 2026) and Viet Nam (11 September 2026) are among the recent members, together with long-standing members such as the United States, the United Kingdom, Japan, the Republic of Korea, India, Türkiye, Brazil, Mexico and Russia.
- Saudi Arabia (7 December 2022), Indonesia (4 June 2022), Pakistan (9 March 2023), the Philippines (14 May 2019) and Singapore (16 September 2021) also joined in recent years.
- Thailand deposited its accession on 30 June 2026; the Convention enters into force for it on 28 February 2027, so until then Thai legalization rules apply.
- The United Arab Emirates, Malaysia and Egypt were not contracting parties in October 2026, so documents for them still go through legalization or attestation.
- When an existing member objects to a new member's accession, the Convention does not apply between those two countries. Austria, Czechia and Germany, for example, objected to Viet Nam's accession, so documents between them and Viet Nam still need legalization. The HCCH status table marks such accessions; always check it for both countries.
Typical export documents that need an apostille or legalization
- Certificates of free sale and GMP certificates for product registration, for example cosmetics or food in some Asian and Middle Eastern markets.
- Powers of attorney and letters of authorisation appointing an importer or local agent.
- Company registration extracts and certificates of good standing for tenders or distributor contracts.
- Certificates of origin and commercial invoices, when the buyer's country or a letter of credit requires them to be legalized by its consulate.
- Halal, health or analysis certificates, when the receiving authority asks for them.
Step by step
- Ask the importer or receiving authority exactly which documents must be apostilled or legalized, and whether copies or originals are needed.
- Check the HCCH status table: are both countries contracting parties, and has either objected to the other's accession?
- If both are members, get the document certified as a public document if needed (for example by a notary), then obtain the apostille from the competent authority.
- If the destination is not a member, follow its legalization route: certification in your country and then its embassy or consulate.
- Allow time for the process before shipment, and keep scans of the apostilled or legalized originals.
Documents you usually need
- Original public document or notarised copy
- Apostille certificate from the competent authority, or consular legalization stamps
- Translation, if the destination requires one, and its certification
- Importer's or authority's written list of required documents
- Commercial invoice and certificate of origin, if the buyer's country requires them legalized
Common problems and how to avoid them
What to do: Viet Nam has been a member since 11 September 2026, so an apostille should be accepted from other members, except Austria, Czechia and Germany, which objected to its accession. Point to the HCCH status table.
What to do: Commercial and customs documents fall under the Article 1(3)(b) exclusion in some countries; use the destination's legalization route or the chamber's certification instead.
What to do: The UAE was not a contracting party in October 2026, so documents need legalization or attestation instead.
What to do: Private documents usually need a notarial or official certification first; the apostille then certifies that public certification.
Sources
- Status table: Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents Hague Conference on Private International Law (HCCH)
- Background Note on Article 1(3) Exclusions Hague Conference on Private International Law (HCCH)
- Thailand's Accession to the Apostille Convention Ministry of Foreign Affairs of Thailand
- Vietnam accedes to the Apostille Convention, simplifying legalization process from 11 September 2026 EY Vietnam
- Vietnam: Apostille Convention simplifies cross-border public documents Baker McKenzie
Rules change often. This note is practical guidance based on the sources above, not legal advice. Confirm current requirements with the authority, your importer or a licensed customs broker before you ship.
Trade notes
Common questions
What is the difference between an apostille and legalization?
An apostille is one certificate from the issuing country that is enough in any other member of the 1961 Apostille Convention. Legalization is a chain of certifications ending with the destination country's embassy or consulate, still needed for non-members.
Does China accept apostilles?
Yes. The Apostille Convention entered into force for China on 7 November 2023, so documents from other members need an apostille instead of consular legalization, unless an objection applies between the two countries.
Does Vietnam accept apostilles?
Yes, since 11 September 2026, when the Apostille Convention entered into force for Viet Nam, except for documents from Austria, Czechia and Germany, which objected to its accession. Before that, consular legalization was required.
Can a certificate of origin be apostilled?
It depends on the country. The Convention excludes administrative documents dealing directly with commercial or customs operations, but the HCCH reads this narrowly and many members issue apostilles for such documents. Ask the issuing authority and the receiver.
Does the UAE accept apostilles?
The United Arab Emirates was not a party to the Apostille Convention in October 2026, so documents for use there still need legalization or attestation.
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