Not the Turkish office but the foreign institution receiving the document decides. In Türkiye both routes are open: an apostille is issued on the original and on the notarised translation alike, and the two can come from different offices. The only mistake is to choose one without asking the institution, since the two apostilles attest different things.
Two certificates, two different signatures
The apostille on the original attests the signature and seal of the official or judge who issued the document. The apostille on the translation attests the signature and capacity of the noter (a Turkish notary public) who certified it; the Onikişubat District Governor’s Office (a kaymakamlık, a district governor’s office) puts it plainly: the element on which the apostille rests is the notary’s certifying signature, and the apostille attests the notarial certification, not the wording of the translation. When a foreign institution writes “apostilled document”, its list may specify which of the two it means; if it does not, the question has to be put.
Which Turkish office for each route
The Onikişubat page states that the original of a judicial document is apostilled by the presidencies of the judicial commissions, the adli yargı adalet komisyonu başkanlığı at courthouses, and its notarised translation by the provincial or district governor’s office. The Zile District Governor’s Office says that the original of a university diploma is apostilled by the provincial governor and its notarised translation by the district governor. The sequence published by the Turkish Ministry of Foreign Affairs describes only the translation route: obtain the document, have it translated into the target language, have the notary certify the translation, have the governor’s office issue the apostille. On that sequence the apostille does not attest the signature on the original; if the institution wants the original apostilled as well, a second operation is needed. In practice this pairing is called a double apostille, a term explained in the key terms section of this site.
Germany and France: two different set-ups
The German missions in Türkiye recognise the civil registry extract with an apostille and a sworn translator’s translation; here the apostille sits on the original and the translation is a separate item. Whether a translation notarised and apostilled in Türkiye counts as a sworn translator’s translation is not stated on the page; this point remains unverified. The French official guide, on the other hand, requires for a translation to be apostilled that it be made by a sworn translator, that the translator’s signature be certified and that the translation be presented with the original. Two countries, two arrangements: there is no single general rule.
Three questions to put to the institution
- Will the original of the document carry an apostille?
- Where and by whom is the translation to be made: is a notarised translation from Türkiye accepted, or is a sworn translator in the destination country required?
- Is an apostille wanted on the translation too; if so, is the translation to be made before or after the apostille?
These three answers set up the whole chain. Work done before the answers arrive may have to be done twice.
Where the translation enters on each route
If the apostille is wanted on the original, the translation is made after the apostille, and whether it covers the certificate is asked at the same time. If the apostille is wanted on the translation, the order is translation, then notarial certification, then an apostille from the governor of any province or the district governor of any district; since the rule tying the apostille to the notary’s district was removed in 2024, the notary and the apostille counter need not be in the same province. If both are wanted, the order is apostille on the original, translation, notary, second apostille; on that route the second certificate stands behind the translation and is not part of it, while the treatment of the first is for the institution to state. A translation office plans this sequence from the institution’s answer and does not assess the outcome, that is, whether the institution will accept the document.