How do I get a document apostilled for use in China?

For a public document from a contracting state, you notarise it at home if it is not already public, obtain an apostille (附加证明书) from that state’s competent authority, and have it translated into Chinese. Consular legalisation ended between contracting states on 7 November 2023. The Chinese recipient still decides whether your translation is acceptable.

China’s accession to the Apostille Convention removed a step that used to add weeks and an embassy appointment to every cross-border document. The chain is shorter now, and more frequently misunderstood, because “apostilled” is not the same as “accepted”. The certificate settles one question completely and says nothing at all about the others.

When did China join, and what changed?

The Convention entered into force for China on 7 November 2023. From that date a public document travelling between China and another contracting state needs only the apostille (附加证明书) issued in the country the document came from, and no consular legalisation by either country’s embassy or consulate.^⁠[1]

The sequence, from your country into China

1. Establish that the document is a public document, or make it one. The Convention lists notarial acts among public documents, which is the route a private document takes: a board resolution, a power of attorney or a passport copy is not a public document until a notary has acted on it.^⁠[2] Company records issued by a registry usually are one already.
2. Obtain the apostille from the competent authority of the country the document was issued in. Each contracting state designates its own, in most countries the foreign ministry or a department it names.
3. Have the document and the apostille translated into Chinese. The apostille page is part of what is being submitted, so ask whether it is to be translated too.
4. Confirm with the receiving body in China, whether that is a registry, a bank, a court or a platform, what form of translation and certification it will accept, and how recent the underlying document must be. Do this before commissioning anything, because it is the only step that can make the other three worthless.

What an apostille actually certifies

Three things, and no more: the authenticity of the signature on the document, the capacity in which the person signing acted, and where appropriate the identity of the seal or stamp it bears.^⁠[2] It says nothing about whether the content is true, whether the document does what you think it does, or whether the Chinese body receiving it will accept it. The Convention is equally firm in the other direction: where it applies, the apostille is the only formality that may be required to certify those three things, so a Chinese authority asking for consular legalisation as well as an apostille is asking for something the treaty does not permit.

The same chain in reverse, from China outward

A Chinese company registering, banking or bidding abroad follows the mirror image: notarisation at a Chinese notary office, then an apostille, then translation into the destination language. The part most guidance gets wrong is where to apply. The Ministry of Foreign Affairs is the competent authority, but it has authorised the foreign affairs offices of provinces, autonomous regions and municipalities, and of some city governments, to issue apostilles for public documents produced in their own areas.^⁠[1] So a document issued in a provincial city is often handled locally rather than in Beijing, and asking the local foreign affairs office first is usually faster than assuming otherwise.

Where the Convention does not apply

Two situations, and the second surprises people because it involves a country that is a contracting state.

The first is simple: where the other country has not joined, the older chain still runs, meaning notarisation at home and then legalisation by the Chinese embassy or consulate there. The second comes out of the accession mechanism itself. Where a state accedes, every existing contracting state has six months in which to object, and the Convention then comes into force between the acceding state and the states that did not object, on the sixtieth day after that period expires.^⁠[2] China deposited its accession on 8 March 2023,^⁠[3] which is exactly how the date works out at 7 November 2023, and it is also what leaves room for an exception.

Where the document comes from	What it needs
A contracting state	Notarisation where the document is not already public, then that state’s apostille. No consular legalisation
India	Consular legalisation. India objected to China’s accession, so the Convention does not take effect between the two countries, even though both are parties to it
A state that has not joined	The older chain: notarisation, then legalisation by the Chinese embassy or consulate in that country
A state whose accession is still pending	Check the date. The Ministry of Foreign Affairs list carries pending accessions with their expected commencement, and a document sent before that date takes the consular route

The list is maintained by the Ministry of Foreign Affairs and dated on its face, which is the point: check it for your own country on the day you start, rather than relying on a summary written earlier.^⁠[4]

The translation is a separate problem, and it is the one that fails

An apostille authenticates a signature or a seal. It does not make a translation acceptable, and Chinese receiving bodies set their own translation requirements, which differ by authority and sometimes by city. Whether a translation certified in your own country will be accepted is a question with its own answer: see whether a translation certified abroad is accepted in China. Settle it before you commission anything, because a translation redone to a different specification is the most common avoidable cost in this process.

Where documents actually get rejected

Reason	How to avoid it
The translation is not in the form the receiving body wants	Ask that body what it accepts, in writing, before translating
The name is spelled differently across documents	Fix one legal name and one Chinese rendering of it, and use them on everything in the file
The document is too old for the recipient	Many recipients want something issued within three to six months, so sequence the notarisation and the apostille against the filing date
The apostille was obtained on the wrong document	It certifies the signature or seal of whoever issued or notarised the document, so it has to be obtained on the version that carries the right signature
The origin country is outside the Convention with China	Check the list first, and budget for consular legalisation if so

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