Two different errors meet at the same door. In the first, the holder has obtained the apostille and goes to the Ministry of Foreign Affairs so that “the Ministry can confirm it as well”. In the second, the document is going to a country outside the Apostille Convention, an apostille was nevertheless obtained from the kaymakamlık (district governor’s office), and the document is turned back either at the Ministry or at the destination country’s mission. This page explains the common cause of both errors and the chain for a document going to a country outside the Convention.
The Legalisation Unit’s one-sentence answer
The information sheet of the Legalisation Unit of the Turkish Ministry of Foreign Affairs is a single sentence: a document that has been apostilled cannot be legalised by the Ministry. The same text gives the reason: an apostilled document can be placed directly before the authorities of the contracting states, so there is no further stamp to add. If the destination country is outside the Convention, the document does not move forward at its mission either: in the Ministry’s order the link before the mission is the Ministry’s legalisation, and an apostille does not replace it.
Apostille and legalisation are two separate systems
The apostille is the procedure that replaces consular legalisation between contracting states; according to the Ministry’s text, an apostilled document is processed directly by the authorities of a contracting state, while a state outside the Convention does not recognise the apostille. The Ministry therefore does not treat an apostilled document as one on which a legalisation stamp can be added. For a country outside the Convention, the chain of the pre-apostille era continues: the authorities of the issuing country confirm one another’s signatures in turn, and the destination state’s mission in that country recognises the last of them. Apostilles in Türkiye are issued by the governor, the district governor and the adli yargı adalet komisyonu (the judicial commission at courthouses with a high criminal court); the Ministry of Foreign Affairs legalises documents going to countries outside the Convention. The official e-Apostil system draws the same line: no e-Apostil is issued for countries outside the Convention.
The four-step chain to a country outside the Convention
The sequence published by the Ministry has four steps. The document is first translated into the language of the destination country and the translation is certified by a noter (a Turkish notary public). The valilik or kaymakamlık (provincial or district governor’s office) of the place where the document was drawn up then legalises it; this is ordinary legalisation by the provincial administration, not an apostille. 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 Ministry’s Legalisation Unit approves next. The last step is the destination country’s mission in Türkiye; this step is not in the Ministry’s text and comes from the destination country’s own rule. For the detailed procedure, appointments and fee, the Legalisation Unit’s own page is the reference; this site gives no figure. Which countries are outside the Convention is checked in the HCCH status table; several Gulf and Middle Eastern states and Turkmenistan are in that group, and the country pages of this site show the position from this site’s country data.
Which error can still be repaired
If an apostilled document was taken to the Ministry and the destination country is outside the Convention, the document is prepared afresh from a new copy: translation, notary, provincial legalisation, Ministry. That no legalisation is added to an apostilled copy is written in the official text; whether an issued apostille certificate can be withdrawn was not found in any official source in this site’s survey, so the practical solution is a new copy. If the destination country is a contracting state and the document was nevertheless taken to the Ministry, nothing needs doing: the apostilled document is sent directly to the destination. The Ministry’s text says an apostilled document is processed directly by contracting state authorities.
Translation as the first link of the legalisation chain
In the chain to a country outside the Convention, the translation is the first link and the whole chain is built on the notarial certification of the translation: the governor’s office recognises the notary’s signature, the Ministry the governor’s, the mission the Ministry’s. If the translation is made later, the chain breaks, because the stamps were placed on an untranslated document. The document is therefore translated first, the translation is notarised and the file goes to the governor’s office in that form.