Who issues the apostille in each country: a table of authorities

When a foreign document has to be filed in Ukraine, the expensive question is not “what does the translation cost” but “where do I go for the apostille”. The intuitive answer — the foreign ministry, because in Ukraine ministries issue apostilles — is wrong in most of Europe.

Below is a table covering the twelve countries whose documents reach us most often. And one rule that makes the table legible: the signature on the document decides the authority, not the subject matter.

The table: who issues the apostille

Country	Administrative documents	Judicial and notarial	Electronic apostille
Poland	Ministry of Foreign Affairs (MSZ), legalisation section in Warsaw	first certified by the president of the competent regional court, then the MSZ apostille; KRS extracts skip that step	no data
Germany	no single authority: depends on the type of document and the federal state; some documents need prior certification (Vorbeglaubigung)	likewise by state, judicial and notarial usually via a court	no data
Czechia	Ministry of Foreign Affairs	Ministry of Justice (courts, notaries, executors, criminal-record extracts)	no data
Romania	county prefecture	notarial chamber (notarial acts), tribunal (courts, bailiffs, trade registry)	no data
Türkiye	valilik (provincial governorate), kaymakamlık in districts	justice commission at a courthouse with a heavy penal court	yes — e-Apostil via the state services portal
Italy	Prefettura	Procura della Repubblica (notarial, judicial, sworn translations)	no data
Spain	four different bodies depending on the type of document (RD 1497/2011)	dean of the notarial college, government secretary of the TSJ, Ministry of Justice	no data
France	the notariat — since 1 May 2025, applications via apostille.notaires.fr	the same notariat; apostilles issued by courts of appeal before May 2025 remain valid	no data
Netherlands	district court (rechtbank), any of the eleven	the same court	no — paper apostille only
Lithuania	a notary (since 18.01.2016); the foreign ministry only for documents from Lithuanian missions	a notary	yes, since 1 October 2026 — e.Notaras, only for documents with a qualified e-signature
Estonia	a notary (since 01.01.2010), apostille register at notar.ee	a notary	no data
Greece	the region’s decentralised administration; the region for regional services; the Ministry of Digital Governance for gov.gr documents	court of first instance	yes, since 17.07.2023

“No data” means exactly that: at the time of checking we found no official confirmation that the country issues electronic apostilles — not that it does not. For any country, the current list of designated authorities is published by the HCCH.

Four models, and none of them is “the foreign ministry”

The table looks chaotic until you see that the countries fall into four groups.

The ministry model. Central ministries issue the apostille, having divided the documents between them: Czechia (Foreign Affairs versus Justice), Poland (the MSZ as the final step). Convenient in that there is one address for the whole country; inconvenient in timing.

The notarial model. A notary issues the apostille: Estonia since 2010, Lithuania since 2016, France since 1 May 2025. Fast and close to home — but this is where the most outdated information circulates, because the transfer of powers has not caught up with public memory.

The court model. A court issues the apostille: the Netherlands (a district court, and any of the eleven will do), Germany for judicial and notarial documents.

The territorial model. Powers are distributed geographically and by type of body: Italy, Spain, Greece, Türkiye, Romania. This is where it is easiest to go to the wrong address — and most often necessary to travel twice.

France, Lithuania, Greece: why the online instructions contradict each other

Three countries in the table changed their rules in recent years, and that is the main reason commercial pages disagree.

• France transferred the apostille to the notariat with effect from 1 May 2025, after postponing the date three times. Three generations of instructions therefore coexist online, and some still send people to the prosecutor’s office at the court of appeal.
• Lithuania transferred the apostille to notaries back in 2016, and launched electronic apostilles on 1 October 2026.
• Greece has issued electronic apostilles since 17 July 2023, and its powers are split between the decentralised administration, the region, the courts and the Ministry of Digital Governance.

Before you travel, check the HCCH database or the country’s own official portal rather than a blog. One extra look saves a day.

The digital apostille versus the Ukrainian notary

An electronic apostille is a convenience that becomes a problem on the Ukrainian route. A Ukrainian notary binds the translation to the document: physically, with thread and a seal across the binding. There is nothing to bind to a PDF with a QR code.

The trap works in two opposite directions:

• A digital stamp. Greece, Türkiye and Lithuania issue the apostille in digital form — paper for the notary has to be obtained separately, or the printout agreed in advance.
• A digital document. The Netherlands, by contrast, issues no electronic apostilles — but half of Dutch extracts exist as PDFs with an electronic signature, and a court cannot apostille such a file.

The conclusion is the same: resolve the question of the document’s form before you order it, not after.

Is an apostille needed at all

Among the countries in the table, Ukraine has legal-assistance treaties with Poland, Czechia, Romania and Türkiye (and, outside the table, with Hungary, Slovakia, Bulgaria and a number of others). Ukrainian official lists classify such treaties as exempting official documents from legalisation. Layered on top, since 9 February 2023, is Cabinet Resolution No. 107: during martial law and for six months afterwards, documents are accepted without special certification if that practice existed as of 24 February 2022.

So why is an apostille asked for all the same? The Ministry of Justice answers this directly: the wording of these articles differs between treaties, some of them cover only documents exchanged between the parties’ competent authorities, and where a treaty does not reach, reciprocity applies — in which case the document is accepted only with an apostille or consular legalisation.

The rule is therefore simple: ask the authority you are filing with, preferably in writing. No answer — get the apostille. It is never wrong; it is only sometimes unnecessary.

What an apostille does not do

• It does not translate. An apostille certifies a signature and a seal, not a language. A Ukrainian authority still needs a Ukrainian translation with notarization.
• It does not confirm content. It does not say the document is correct or that the fact in it is true — only that the signature on it is genuine.
• It is not issued in Ukraine. Only the issuing state can apostille. Nobody in Ukraine can apostille a foreign document.
• It does not go on anything. Laminated forms, copies of copies and obsolete forms do not get the stamp — each country has its own limits (Romania, for instance, apostilles original certificates issued after 1998).

Country by country

For the countries in the table we have written separate guides, document by document and with the typical grounds for refusal: Türkiye, Romania, Czechia, Italy, France, the Netherlands, Lithuania, Greece, Spain, Poland and Germany.

If the document is corporate — a registry extract, articles of association, a shareholders’ resolution — start with EU corporate documents for Ukraine. If it is a foreign judgment, translation is not enough: there is a separate recognition procedure, described in foreign court decisions in Ukraine.

The US and Canada are deliberately absent from the table: their logic differs — in the US the apostille is split between the Department of State and the Secretaries of State, and Canada only joined the Convention on 11 January 2024. Both are covered separately in US and Canadian police certificates for use in Ukraine, through the document that arrives from there most often.

What to do with the document after the apostille

A Ukrainian authority accepts a foreign document together with a Ukrainian translation whose accuracy, or whose translator’s signature, has been certified in the established manner. In practice, for the civil registry, a notary, a registrar or a court, that means a notarized translation: an agency stamp is enough for internal use and for some banks, but not for a state body.

The whole text of the document is translated — including the text of the apostille and the official annotations on the reverse. Translation of foreign documents into Ukrainian starts at UAH 300 per standard page (1,800 characters with spaces) and depends on the language; notarization is UAH 400 per document and the agency stamp UAH 100. The full price list is on the prices page.

If the documents travel the other way — a Ukrainian document going abroad — you need to obtain an apostille in Ukraine; that page also sets out which Ukrainian authority handles which document.

How we handle it

We start with three questions: which state issued the document, who signed it, and in what form it exists. The answers give you the address of the apostille authority, whether an apostille is needed at all, and whether a Ukrainian notary can work with the document. Then we translate, align the spelling of names with your Ukrainian documents, have the translation notarized and hand over a package ready to file.

Send the scans and the name of the authority asking for them, and you will have a quote in 15 minutes.