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Last updated: 23 September 2026 Sources checked: 23 September 2026
Key terms

Public document (Article 1): four kinds, two exclusions

Four kinds of public document under Article 1, two exclusions, and how a private paper or a translation enters the scope via a notarial certificate.

The Convention applies only to public documents, and Article 1 defines the term itself. The definition is both narrower and wider than the everyday word “official”: some documents issued by the state fall outside it, and some private documents are brought inside by a certification placed on them. Whether a paper can receive an apostille at all begins with this definition.

Four categories in Article 1

Article 1 treats as public documents: documents emanating from an authority or an official connected with the courts or tribunals of the state, including those emanating from a public prosecutor, a clerk of a court or a process server; administrative documents; notarial acts; and official certificates placed on documents signed by persons in their private capacity, such as a record of registration, a visa for a certain date, or an authentication of a signature. The first three categories are identified by the issuing body. The fourth is identified not by the document but by the official act performed on it.

How a private paper enters the scope

A company contract, a report from a private hospital or a statement written in a person’s own hand is not a public document within the Convention. The same paper changes character once a Turkish notary authenticates the signature on it: it now carries an official certificate, and the apostille attaches to that certificate. What the apostille then attests is the notary’s signature and capacity, not the content of the paper. The rule on Turkish district pages that an identity card has to be notarised before it can be apostilled follows from this same logic.

Diplomatic papers and customs papers stay outside

The last paragraph of Article 1 removes two groups. Documents executed by diplomatic or consular agents are the first: a paper issued by a foreign mission in Türkiye does not enter the apostille chain and is handled through legalisation or through the exemption of the European Convention of 1968. Administrative documents dealing directly with commercial or customs operations are the second. The word “directly” is the test: a certificate of origin or a bill of lading, tied to a particular customs operation, is outside and receives an ordinary certification at the provincial governor’s office; a company’s articles of association or a trade registry record, commercial in content, stays inside. The Onikişubat District Governor’s Office states the distinction expressly on its apostille page.

Ownership and subject matter are not the test

The definition looks at who issued the document, not at whom it belongs to. A document belonging to a company is not excluded because a company owns it, and a document belonging to a foreign national is not excluded because of nationality. The subject is not the test either: a criminal judgment and a divorce decree fall in the same category. Some receiving states, France among them, keep separate columns by kind of document in their own acceptance tables; those columns show that state’s additional exemptions, not the Convention’s definition.

Where a translation sits in the definition

A translation is not a public document on its own; it is a private text bearing the translator’s signature. Once a notary authenticates that signature, the fourth category applies and the translation can be apostilled by way of the notarial certificate on it. “An apostille on the translation” is, in strict terms, an apostille on the notary’s certificate, and the definition settles that from the start.

TR: resmî belge (m.1); FR: acte public (article 1er)
Translation in the chain

Where does the translation fit?

  1. Document going abroad The sources describe two routes: an apostille on the original, or a translation certified by a notary with the apostille then confirming the notary’s signature. The receiving authority says which it wants.
  2. Foreign document used in Türkiye The sources describe an apostille in its country first, then a Turkish translation with notary certification; the Turkish institution receiving it confirms its own requirement.
  3. Sometimes none is needed Multilingual civil status extracts and some treaties remove the translation or the apostille. The authority that receives the document decides.

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