Apostille or legalisation? It depends on the country that issued the document
An office asks you for a certificate issued abroad and tells you it «must be legalised». Sometimes you need an apostille, a single stamp; sometimes legalisation at the Italian consulate; sometimes nothing at all. It depends on the country where the document was drawn up, not on your nationality. Here is how to tell which of the three cases is yours, and in what order to do things.
7 min read
In this article
- It depends on the country that issued the document, not on your nationality
- What the apostille is
- Italy does not issue the apostille
- The five Bahay Italia communities, as of 4 September 2026
- An apostille works between two countries, not worldwide
- Documents issued by your consulate in Italy are a separate case
- The order matters, and getting it wrong costs twice
- The translation is yet another thing
- How long what you are holding lasts
- Tables go stale: always look at the date
- Where to ask for help
An office asks you for a certificate issued in your country — your birth certificate, your marriage certificate, your criminal record — and then adds a sentence nobody explains: «deve essere legalizzato» (it must be legalised). Or: «ci vuole l'apostille» (you need the apostille).
They are two different things, and there is a third: for some documents from some countries, neither is needed. Taking the wrong road costs weeks, because you usually find out at the counter, with the document already in your hand and the trip already made.
It depends on the country that issued the document, not on your nationality
This is the most common mistake, and it is the one that wrecks everything else. What matters is not where you are from: it is where the document was drawn up. A Philippine birth certificate follows Philippine rules even if the person presenting it has since taken another citizenship.
There are three possible roads.
- Nothing is needed. For some documents drawn up in a European Union country, and for a few States bound to Italy by older agreements.
- You need the apostille: a single stamp, obtained in the country that issued the document.
- You need consular legalisation: the signature on the document is authenticated by the Italian embassy or consulate in that country. This is the road for States that are not party to the Hague Convention.
What the apostille is
The apostille comes from the Hague Convention of 5 October 1961, in force for Italy since 11 February 1978. Before it, a foreign document went through two steps: first the authority of the country of origin, then the Italian consulate. The Convention replaced the two steps with one.
It is an attestation that can take the form of a stamp, a sticker or an attached sheet, as long as it is physically joined to the document; some countries also issue it electronically. It says one thing only, and it matters to know which: it guarantees that the signature on the document is genuine and that the person who signed had the power to do so. It does not say the content is true, and it does not guarantee that the document is right for the procedure you are going through. Those are two different questions, and the apostille answers only the first.
Today 130 States are party to the Convention.
Italy does not issue the apostille
This is the second thing that wastes time. The stamp is placed by the authority of the country that issued the document, and that country chooses which one: in one it is the ministry of foreign affairs, in another a court, in another the civil registry. In Italy there is no office that can apostille a foreign certificate.
Which means that step has to be done before you leave, or asked of someone who is there. For the Philippines, for instance, the competent authority is the Authentication Division of the Office of Consular Affairs, Department of Foreign Affairs (DFA), and the apostilles it issues can be checked online in its public registry.
The official list, country by country, with the name and address of the office that issues the apostille, is on the website of the HCCH, the Hague Conference on Private International Law, which keeps the register of the Convention. That is the place to look, and it beats any list found elsewhere.
The five Bahay Italia communities, as of 4 September 2026
| Country | What is needed | Since |
|---|---|---|
| Philippines | Apostille | 14 May 2019 |
| India | Apostille | 14 July 2005 |
| Peru | Apostille | 30 September 2010 |
| Bangladesh | Apostille | 30 March 2025 |
| Sri Lanka | Consular legalisation | not party to the Convention |
This table is true on the day you read it only if no State has changed position in the meantime, and that happens: Bangladesh joined the Convention on 30 March 2025, and before that date its documents needed consular legalisation. At the bottom of this page you will find the date we last verified it.
An apostille works between two countries, not worldwide
When a State joins the Convention, the States already party to it may object. If one objects, the apostille does not work between those two countries and consular legalisation remains.
This is not theory. Twelve States objected to Bangladesh joining, among them Germany, France, the Netherlands, Austria, Belgium, Denmark and Greece. Italy did not object: so a Bangladeshi apostille is valid here. But if you also need that document in Germany or France, that is a separate check.
Documents issued by your consulate in Italy are a separate case
If the document does not come from your country but was issued to you by your embassy or consulate here in Italy, the apostille has nothing to do with it: it never applies to consular documents. What is needed instead is legalisation by the Prefettura — in full, Prefettura-Ufficio Territoriale del Governo, the one for the province where the consulate is. This is set out in article 33, paragraph 4, of Presidential Decree no. 445 of 28 December 2000. Here too there are exemptions, for the consulates of several European countries.
The order matters, and getting it wrong costs twice
This is the part that sends most people back, and it is all in one rule: the apostille goes on the original, before any copy is made.
If you first make the certified copy and then take the copy to be apostilled, you have the order wrong and must start again. If you make the certified copy in your own country, the signature of whoever certifies the copy must also be apostilled: in that case there are two apostilles, the copy of the first plus the original of the second. The translation, on the other hand, comes afterwards: first the document is apostilled, then it is translated.
The translation is yet another thing
Apostille and translation are two separate requirements: one does not replace the other. A document in a foreign language must be translated into Italian, and the translation can be done in several ways — at the Italian consulate in the country of origin, at your country's consulate in Italy, or in Italy through asseverazione, the translator's sworn statement before the clerk of a judicial office (including the Giudice di Pace) or before a notary. For civil-status documents to be registered at the comune, the oath can be taken directly by the civil registrar.
A rule that surprises almost everyone: the translator cannot be a person named in the document. You cannot translate your own birth certificate, and your father cannot do it if he appears as a parent. A third person is required.
There is a shortcut worth knowing: for birth and marriage extracts many countries issue the multilingual form of the Vienna Convention of 8 September 1976, which, being already in several languages, needs no translation. If your country issues it, ask for that one: you save a step and a cost.
How long what you are holding lasts
Certificates attesting facts that do not change — birth, death — have unlimited validity: this is stated in article 41, paragraph 1, of the same Presidential Decree 445 of 2000. The criminal record is another story: for a citizenship application it cannot have been issued more than six months before the application. It is the document to plan backwards from, starting from the date you will hand everything in.
Tables go stale: always look at the date
Many country-by-country lists circulate, including the Prefettura's so-called supertabella, which is well made and genuinely useful — but the version most often found around carries the date 9 March 2021, and since then at least Bangladesh has changed.
So: use the tables to understand how it works, and check your own country on the HCCH register before you move. It is the only place that updates the same day.
Where to ask for help
If the case is not straightforward — a surname that changes between two certificates, a document issued by a State that no longer exists, a single copy your country does not reprint — do not improvise. The Prefettura of your province answers on legalisations; the civil registry office of the comune answers on registering documents; a patronato or a lawyer will look at the whole case. Half an hour of questions costs far less than a wasted trip.
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