Apostille and legalisation between France, Germany, Austria and Switzerland
“Do I need an apostille?” It is one of the first questions people ask before submitting a German, Austrian or Swiss document in France – or the other way round. Between these four countries, the answer is often simpler than expected: for many documents, no formality at all is required. A translation, on the other hand, is almost always needed.
Apostille and legalisation: what is the difference?
Legalisation is the traditional procedure by which an authority confirms the authenticity of the signature and seal on a foreign public document. Between the States party to the Hague Convention of 5 October 1961, it is replaced by the apostille: a single certificate, issued in the country of origin, which confirms where the document comes from and who signed it, but not its content. France, Germany, Austria and Switzerland are all parties to the Convention (HCCH status table).
Other instruments go further and do away with any formality: a Franco-German bilateral convention, conventions of the International Commission on Civil Status (ICCS/CIEC), and Regulation (EU) 2016/1191, in force since 16 February 2019, which exempts public documents exchanged between Member States from the apostille when they concern, among other things, birth, marriage, death, nationality, residence or the absence of a criminal record. The French Foreign Ministry keeps a country-by-country summary table.
What the table says for each country
| Country | Civil status certificates | Other documents |
|---|---|---|
| Germany | Exempt (Franco-German convention of 13 September 1971) | Exempt for every category of public document: judgments, notarial deeds, administrative documents, diplomas, criminal record certificates… |
| Austria | Exempt (ICCS convention of 15 September 1977) | Exempt for documents covered by Regulation 2016/1191 and for documents used in civil and commercial court proceedings (Franco-Austrian convention of 1979); apostille for the rest (diplomas, for example) |
| Switzerland | Exempt (ICCS convention of 26 September 1957) | Exempt for judgments covered by the Lugano Convention; apostille for the rest (diplomas, criminal record extracts, notarial deeds…) |
Germany is therefore a special case: the convention of 13 September 1971, in force since 1 April 1975, exempts all public documents exchanged between the two countries from legalisation and apostille. According to an information sheet from the German Federal Office for Foreign Affairs (BfAA), this exemption also covers translations made by a sworn translator. If in doubt about a specific document, ask the receiving authority.
Who issues the apostille?
The apostille is always issued in the country where the document originates:
- France: since 1 May 2025, French notaries have been issuing apostilles on French public documents, on online application. The apostille is issued electronically, even for a paper document (service-public.gouv.fr);
- Germany: for federal documents, the Federal Office for Foreign Affairs (BfAA); for documents issued by the Länder, responsibility varies from one Land to another – usually the Ministry of Justice or the presidents of the regional or local courts for court and notarial documents, and administrative authorities (Ministry of the Interior, Regierungspräsidium, Bezirksregierung) for others. The German Federal Foreign Office recommends asking the authority that issued the document;
- Austria: depending on the issuing authority, the legalisation office of the Federal Ministry for European and International Affairs, the presidents of the regional courts (Landesgerichte) or the provincial governors and their offices (Amt der Landesregierung);
- Switzerland: the cantonal authority responsible for certifications or, for federal documents, the Federal Chancellery in Bern. Swiss embassies and consulates abroad cannot issue apostilles.
Which comes first: apostille or translation?
- A foreign document to be used in France: the apostille first, in the issuing country; then the translation of the whole document, apostille included. An Austrian diploma or a Swiss criminal record extract is therefore apostilled in Austria or Switzerland before it is translated.
- A French document translated for use abroad: the translation first, then the apostille, issued in France by the notaries. Service-public specifies that a translation can only be apostilled if it was made by a sworn translator whose signature is certified, and that it must be submitted together with the original. For Germany, this step is unnecessary.
Good to know: being exempt from the apostille does not mean being exempt from translation. Only multilingual extracts and the multilingual standard forms of the EU Regulation can, in some cases, avoid a translation – and the receiving authority may still ask for one.
I translate documents issued in Germany, Austria and Switzerland into French, and French documents into German – including any apostille: civil status certificates, degrees and transcripts, official documents. For criminal records, see also German criminal record certificate (Führungszeugnis).
Frequently asked questions
Does my German birth certificate need an apostille for France?
No. German public documents are exempt from apostille and legalisation in France. Only the sworn translation is needed, unless the certificate is a multilingual extract.
What about an Austrian or Swiss diploma?
According to the French Foreign Ministry’s table, it requires an apostille, to be obtained in Austria or Switzerland before translation. Check with the receiving institution whether it actually asks for one.
Does my translation need an apostille to be used in France?
No: a translation by a translator sworn before a French Court of Appeal is used as it is in France. An apostille on a translation is only relevant for a French document going to a country that requires one.
How long does an apostille take in France?
Service-public gives a standard processing time of three working days, or 24 hours with the fast-track option, once the application is complete. Plan for this after the translation.