Is a certified translation done outside China accepted by Chinese authorities?

It depends on the office receiving it. Chinese authorities set their own translation requirements. The market regulator’s 2026 filing specification asks for a Chinese translation carrying the translation company’s official seal or translation seal (翻译专用章), the words “accurate translation” and a copy of its business licence. Courts require a Chinese translation of foreign-language material. Ask the receiving office before commissioning.

“Certified translation” means different things in different countries: a sworn translator in one, an accredited translator in another, a translation company’s statement in a third. The Chinese rules opened for this page use none of those labels. Each is written by the receiving authority for its own procedure, and each describes what the translation must carry. That is the useful way to read the question: not “is my certification recognised?” but “does my translation carry what this office asks for?”

What do Chinese authorities require of a translation?

Whatever the receiving authority’s own rule says, and two of the most important publish one. Neither asks for a sworn translator. The registry wants a translation company’s proof of status or an individual translator’s qualification certificate; the courts want a Chinese translation and fix no form.

Receiving body	What the translation must carry	Set by
Company registration authority (market regulator)	A Chinese translation filed together with the foreign original. A translation company stamps its company seal or translation seal, writes “accurate translation” (翻译准确), attaches a copy of its business licence or other proof of its status, and names the translator with contact details. An individual translator signs, gives contact details, and attaches copies of a translation qualification certificate and an identity document	SAMR submission specification, 2026 edition, in use from 1 May 2026: explanatory notes (说明), item 6⁠[1,2]
People’s courts	A Chinese translation of any foreign-language documentary evidence, in any case, and of any foreign-language written material in a foreign-related case. No particular form of certification	Civil Procedure Law, Article 73; Supreme People’s Court interpretation, Article 525⁠[3,4]

Does the translation company have to be registered in China?

The market regulator’s specification does not say. It lists what the translation must carry, a seal, the accuracy statement and a copy of the business licence or other proof of status, and says nothing about where the company is registered.^⁠[2] Whether a foreign translation company’s stamp and its home-country registration certificate satisfy it is for the local registration authority to decide, and practice differs by city. Confirm with that authority, or with the agent filing for you, before relying on a foreign equivalent.

Can an individual translator certify it?

For the market regulator, yes. The specification provides for a translator who is a natural person: the translator signs the translation, gives contact details, and attaches a copy of a translation qualification certificate and a copy of an identity document.^⁠[2] It does not name a particular qualification, so which certificate a given registry accepts is again a question for that registry.

What happens if the other side disputes a translation in court?

In a foreign-related case, the parties jointly appoint a translation agency to produce a translation, and if they cannot agree on which, the court chooses one (Supreme People’s Court interpretation of the Civil Procedure Law, Article 525).^⁠[4] The rule fixes no form of certification for the original translation; what it provides is a way to challenge one and a way to settle the challenge. How to present evidence in a case is a question for the lawyer running it.

Does the translation need to be notarised?

Only if the recipient asks for it. Chinese notarial practice has an instrument for this, a notarial certificate that the translation conforms to the original (译本与原本相符公证), which a Beijing Municipal Bureau of Justice guide of December 2021 lists among the notarial matters that can be handled fully online.^⁠[5] A recipient that wants this form is asking for something different from a translator’s or translation company’s certification, so ask which it wants before ordering.

Chinese embassies and consulates abroad can notarise that a translation matches the original (译文与原文相符), but they in principle accept applications only from Chinese citizens living abroad and from the Chinese-national legal representatives or heads of Chinese-funded enterprises and institutions.^⁠[6] It is not ordinarily open to a foreign company.

Does an apostille make the translation acceptable?

No. A common route is to have the translation made and notarised at home, then apostilled with the original, and that can be the right route, but the apostille does not decide it. It confirms only that the last seal or signature on the document is genuine, and takes no responsibility for the truth or legality of the content.^⁠[7] The Chinese consulate in New York puts the practical point directly: a completed apostille does not mean the Chinese receiving body will accept the document, and applicants should first ask that body about its requirements for format, content, time limits and translation.^⁠[8]

What should you ask the receiving office before ordering?

Banks and other recipients do not, as far as we have found, publish one national form, and practice varies by bank, branch and city. Treat what the office in front of you says as the specification, and ask it five things.

1. Does the translation need a translation company’s seal, and must that company be registered in China?
2. Do you need a copy of the translation company’s business licence, or the translator’s qualification certificate and identity document?
3. Is a translator’s or company’s statement of accuracy enough, or do you require a notarial certificate that the translation conforms to the original?
4. Should the apostille or legalisation page be translated as well as the document?
5. Do you need paper originals with a wet seal, or is a scanned copy accepted for online filing?

Get the answer in writing where you can, from the office that will actually receive the document. The same type of authority in two cities can answer differently, and an agent’s memory of last year’s filing is not the requirement.

What if the translation already exists?

It is not necessarily wasted if the recipient wants a different form. Ask whether the existing text can be checked and reissued in the form required before paying for a new one. Whatever the form, keep company names, personal names and dates identical across every translated document in the same filing; which documents need legalising in the first place is set out in which documents to notarise and apostille for China.

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