A document has to travel abroad and the owner wants to keep the original at home, so a photocopy is made and taken to the apostille counter. The file stops there, either at the kaymakamlık (the district governor’s office in Türkiye) or later at the foreign authority that receives it. The real fault lies one layer below the apostille, in the paper itself. This page explains the difference between a plain photocopy and a certified copy, and how the file is repaired.
What the counter and the foreign office say about a photocopy
The refusal can come in two different places. The clerk at the valilik (provincial governor’s office) or the district office says that a photocopy carries no signature that can be checked and does not take the document in. The foreign university, employer or registry office may return the file asking for the original or a certified copy. Both refusals describe the same gap. The sheet in hand is an ordinary reproduction with no signature of a public official or notary on it.
An apostille attests a signature, so a photocopy has nothing to attest
Article 5 of the Apostille Convention, as published in the Turkish Official Gazette, says that a duly completed certificate attests the authenticity of the signature, the capacity in which the signatory acted and, where appropriate, the identity of the seal or stamp. On a photocopy every one of these elements is an image. Article 5 of the Convention says the apostille attests a signature, the capacity of the signer and the seal; a photocopied image offers none of these, so there is nothing an apostille could attest. The service standard of the Ankara Governor’s Office reflects this: it takes as its basis administrative documents drawn up in Türkiye with a handwritten signature and a seal, and asks only for the identity card and telephone number of the person presenting them. None of this makes the photocopy worthless; it means the photocopy cannot enter the apostille chain on its own.
How a certified copy differs
A certified copy is a reproduction on which a public official or a notary has written a true-copy note (aslı gibidir in Turkish) and signed it. The Onikişubat District Governor’s Office states on its apostille page that only a copy bearing this certification by a competent authority or a notary can be considered for an apostille; a plain photocopy is not considered. The certification changes the nature of the sheet: it now carries a verifiable signature and a capacity. The apostille then attests that signature, not the signature on the original document. Identity documents show the rule clearly. District offices such as Nilüfer write that an identity card presented for an apostille has to be notarised first; the card itself never enters the chain, the notary’s copy does.
Repairing the file after the refusal
The repair is short. If the original was issued by a Turkish public body, there are two options: ask that body for a fresh signed and sealed copy, or take the original to a noter (a Turkish notary public) and have a certified copy drawn up. The notary’s copy is a notarial act. Under article 199 of the Turkish Notaries Law, as amended in November 2024, its apostille is issued by the governor of any province or the district governor of any district; the earlier rule tying the apostille to the notary’s own district has been removed. A copy certified by the issuing body itself is an administrative document and is apostilled at the provincial or district governor’s office in the same way. Which of the two the file needs depends on the receiving institution: some ask specifically for a notarised copy, others accept the issuing body’s own certification. Where the original can be sent, the shortest route is to apostille the original.
Points on certified copies this site could not confirm
Which foreign institutions treat a notarised copy as equal to the original, and which insist on the original, was not verified country by country; this site’s survey found no official list. The written request of the receiving institution is the only reliable measure. Whether individual district offices set additional conditions for copies certified by the issuing body itself was not measured either; the office should be asked before the applicant travels.
Translating the certified copy, not the photocopy
The translation is made from the certified and apostilled copy; whether the true-copy note and the apostille certificate on it are rendered with the text is for the receiving institution to say. It is prepared by a yeminli tercüman (a sworn translator whose oath is recorded at a Turkish notary) and certified by the notary. If the receiving institution also wants an apostille on the translation, that second certificate is placed on the notarial certification and is again obtained from any provincial or district governor’s office. A translation made from the plain photocopy shows neither the certification note nor the apostille; which version is to be translated is asked of the institution before the translation starts.