The Apostille for China: business documents, explained (post-2023 rules)

Since 7 November 2023, a public document moving between China and another contracting state needs one apostille (附加证明书) from the country that issued it, instead of consular legalisation. In China the Ministry of Foreign Affairs issues it, as do authorised foreign affairs offices. Most company papers need a notary first. India is the exception: it objected to China’s accession.

This guide is for a company with a file of documents to send across a border, in either direction, for commercial or qualification purposes. The treaty is the same both ways; the offices, the fees and the order of steps are not. Documents going out of China are covered here in full. For documents coming into China, the national rules and the order are set out in which documents a foreign company must notarise and apostille, and the sequence in how to get a document apostilled for China.

What changed on 7 November 2023?

The last step in the chain disappeared. Using a Chinese company document abroad used to mean notarisation, then authentication by the Ministry of Foreign Affairs or a local foreign affairs office, then legalisation by the destination country’s embassy or consulate in China. The Hague Apostille Convention entered into force for China on 7 November 2023,^⁠[1] and between contracting states a single apostille now replaces the consular steps.

China acceded on 8 March 2023; the Convention allows existing parties six months to object, and it takes effect on the sixtieth day after that, which is how the date works out.^⁠[2,3] Where the Convention applies, the apostille is the only formality that may be required to certify a document’s origin (Article 3).^⁠[3]

Which business documents need an apostille?

Whatever the receiving institution asks for, and it decides. The table shows what is typically asked for in the situations that come up most. It is a list of common requests, not a list in any instrument, so confirm yours before commissioning anything.

Situation	Documents commonly requested
A Chinese company registering a subsidiary or branch abroad	Business licence, articles of association, shareholder register, board resolution, director identification
A Chinese company opening a bank account abroad	Business licence, a document showing the company is in existence, beneficial ownership information, signature specimens
A Chinese company bidding for a tender abroad	Business licence, qualification and certification documents, audited accounts, power of attorney
A foreign company registering an entity in China	Proof of the investor’s legal existence, such as a certificate of incorporation, apostilled at home and then translated into Chinese; banks and registries may ask for more
Employment or study with a qualification	Degree, transcript, professional qualification certificate

Who issues an apostille in China?

The Ministry of Foreign Affairs, and the foreign affairs offices it has authorised, each only for documents from its own area. China’s declaration to the Hague Conference designates the Ministry and authorises the foreign affairs offices of provinces, autonomous regions and municipalities.^⁠[5] The Ministry’s own list, published on 4 September 2024, adds some city offices, and marks with ※ the offices that take applications but forward them to the Ministry or the provincial office, which takes longer.^⁠[6]

Office	What it does
Ministry of Foreign Affairs, Beijing	Issues apostilles for documents from anywhere in mainland China
Provincial-level foreign affairs offices	Issue for documents notarised or issued in their own province. Six are marked ※ and forward instead: Tianjin, Tibet, Xinjiang, Qinghai, Ningxia and the Xinjiang Production and Construction Corps
City offices that issue directly	Changchun, Harbin, Ningbo, Jinan, Qingdao and Shenzhen
City offices marked ※	Take applications and forward them: Qinhuangdao, Manzhouli, Wenzhou, Jingdezhen, Wuhan, Yichang, Xiangyang, Zhuhai and Xi’an

For a document from Zhejiang, that means the Zhejiang provincial office in Hangzhou, except that Ningbo’s own office issues for Ningbo documents. The Wenzhou office, where we are, accepts applications and forwards them, so a Wenzhou document is apostilled in Hangzhou or Beijing either way.^⁠[6] A local office will not accept a document notarised or issued outside its area.^⁠[7]

Why do most company documents go to a notary first?

Because the Convention covers public documents, and a notarial act is one (Article 1).^⁠[3] A business licence copy, a board resolution, a power of attorney or a signature specimen starts life as a private document or a copy, and a Chinese notary office (公证处) turns it into a notarial certificate. The apostille then goes on the certificate. The chain out of China is usually two steps: notarise, then apostille.

Some matters must be applied for in person. Powers of attorney, declarations, guarantees and similar matters closely tied to the person must be applied for by that person, not through an agent (Notarial Procedure Rules, Article 11); a company applies through its legal representative (Article 10).^⁠[8] The Rules also cover notarisation handled online, and the Ministry of Justice may set separate requirements for it (Article 70),^⁠[8] so ask the notary office whether it can take your matter that way before booking travel. A notarial certificate for use abroad is written in Chinese and may carry a translation into the foreign language where needed and requested (Article 43).^⁠[8]

An apostille certifies only that the last seal and signature on the document are genuine. It says nothing about whether the content is true or lawful.^⁠[3,7] That is why the notary step, which vouches for the underlying document, cannot be skipped.

How long does it take, and what does it cost?

At the Ministry of Foreign Affairs, four working days and RMB 100 for a commercial document. The Ministry charges RMB 50 for each civil document and RMB 100 for each commercial document, with RMB 50 more per document for express service. A standard application is completed on the fourth working day after acceptance, and an express one on the second, counting the day of acceptance.^⁠[6]

Local offices may differ, and an office marked ※ adds the time it takes to forward the file.^⁠[6] The notary’s fee and time come on top, and so does any translation. Plan backwards from the date the receiving institution needs the file, because some of them also limit how old the underlying document may be.

Can you get an electronic apostille?

Only for one kind of document so far. The Ministry of Foreign Affairs began a pilot on 18 June 2025, issuing electronic apostilles for electronic certificates of origin issued by the China Council for the Promotion of International Trade.^⁠[9] Every other document, including every notarial certificate, still needs the paper original.^⁠[7]

Does an apostille expire?

No. An apostille remains effective as long as it can be identified and stays attached to the document, and it may not be rejected solely because of its age.^⁠[10] The document underneath is another matter. The receiving country or institution may limit how recent it must be: the Ministry’s FAQ gives the example of the Netherlands, which accepts notarial certificates for six months.^⁠[7] In practice many registries and banks want a certificate of good standing or a company extract issued within the last three to six months, so sequence the work close to when you need it.

Does the translation get apostilled too?

It depends on the destination, so ask before you order. The Ministry’s guidance is that a document being apostilled should generally carry a translation into the language the country of use requires, and it advises confirming the requirement with the receiving body.^⁠[7] Some authorities want the translation bound to the notarial certificate before the apostille is added; others accept a separate certified translation. Doing it in the wrong order means doing it twice. For documents coming into China, the translation rules are in whether a translation certified abroad is accepted in China.

When do you still need consular legalisation?

When the other country is not a party, or has objected to China’s accession. For a non-member, the old chain still runs: notarisation, authentication by the Ministry of Foreign Affairs or a foreign affairs office, then legalisation by that country’s embassy or consulate. India is a contracting state but objected, so the Convention is not in force between China and India.^⁠[11] Where an accession is pending, the date matters: Thailand’s takes effect on 28 February 2027.^⁠[2]

Destination	Route for a Chinese document
A contracting state	Notarise where needed, then apostille. No embassy step
India	Notarise, authenticate, then legalise at the Indian embassy or consulate
A state that has not joined	Notarise, authenticate, then legalise at that state’s embassy or consulate
A state whose accession is pending	The consular route until the date the Convention takes effect for it

What about Hong Kong and Macao?

They were inside the Convention before the mainland was. It has applied in Hong Kong since 1965 and in Macao since 1969, and China notified that it continues to apply to both.^⁠[5] A document from Hong Kong or Macao used abroad is apostilled there, by the region’s own competent authority.

Between the mainland and the two regions the Convention does not apply. A mainland notarial certificate for use in Hong Kong needs confirmation (确认) by the Ministry of Foreign Affairs, not an apostille or legalisation; one for use in Macao can be used directly.^⁠[7] Investors from Hong Kong and Macao coming into the mainland follow their own notarial route, set out in the answer on which documents to legalise.

What about documents coming into China?

The mirror image: notarise at home where the document is not already public, obtain the apostille from your own country’s competent authority, and have it translated into Chinese. For company registration, the national rule names one document per foreign investor, its proof of legal existence or the individual’s identity document, notarised and legalised unless a treaty provides otherwise (SAMR Order No. 52, Article 24).^⁠[4] The Convention is that treaty for contracting states. What registries and banks add on top, and the exemptions, are in the answer on which documents to legalise.

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