Legalisation is the older, longer procedure that the Apostille Convention was written to abolish. In Turkish administrative language it appears as tasdik or konsolosluk tasdiki, consular certification. A document bound for a country that applies the Convention gets an apostille; a document bound for a country outside it gets legalisation. The two words describe alternatives, and a foreign office that asks for “legalisation” of a Turkish document may be using the word loosely.
The definition in Article 2
Article 2 of the Convention gives legalisation a narrow meaning: the formality by which the diplomatic or consular agents of the country in which the document has to be produced certify the authenticity of the signature, the capacity of the signatory and, where appropriate, the identity of the seal or stamp. The elements are the same three that an apostille attests. What differs is who performs the act and how many steps precede it. In legalisation the document passes through the authorities of its own country and then through the mission of the destination country; under the Convention a single competent authority places a single certificate and the chain ends there.
An apostilled document is not legalised on top
The information sheet of the Certification Unit of the Turkish Ministry of Foreign Affairs states that a document bearing an apostille cannot be certified by the Ministry, since an apostilled document is presented directly to the authorities of a contracting state. A request to “add” a consular certification to an apostilled Turkish document leads nowhere in Ankara. The reverse also holds: a document going to a state outside the Convention needs legalisation, and the mission of that state is under no duty to recognise an apostille.
Five links for a country outside the Convention
The Ministry’s own sequence for a Turkish document going to a non-contracting country reads: the document is translated into the language of the destination; the translation is certified by a Turkish notary; the valilik or kaymakamlık, the provincial or district governor’s office of the place where the document was drawn up, applies an ordinary certification; the Ministry’s Certification Unit then certifies the file. This place rule comes from the undated information sheet of the Turkish Ministry of Foreign Affairs; whether the 2024 amendment of article 199 of the Notaries Law also covers this certification was not verified in this site’s survey. The fifth link, the mission of the destination country in Türkiye, is not written on the Ministry’s sheet; it matches the “double legalisation” described by the French foreign ministry. The detailed procedure of the Certification Unit is on the Ministry’s own page.
“Normal tasdik” on Turkish office pages
Pages of district governors’ offices place apostil next to normal tasdik, ordinary certification; the second is the governor’s link in the legalisation chain. The service standard of the Ankara Governor’s Office lists the two procedures as separate rows of one table. In correspondence from abroad, “legalisation” sometimes covers the apostille as well; which of the two is meant becomes clear once it is known whether the destination applies the Convention.
Where the translation sits in a legalisation chain
In the legalisation chain the translation comes first, because the governor’s certification and the Ministry’s certification are placed on the notarised translation. On the apostille route its place depends on where the receiving institution wants the certificate: after the apostille when it goes on the original, before it when it goes on the notarised translation. Starting a translation before the route is known risks building the file in the wrong order.