Which countries need an Apostille for a China filing — and which still need consular legalisation?
Check nationality, residence, where the marriage was registered, China assets, China evidence, child arrangements, and whether a foreign document must be used in China.
Overseas real estate, offshore equity, foreign judgments, custody orders, service routes and authentication may each require a separate route rather than one combined order.
Documents formed abroad may also need translation, notarisation, Apostille or consular legalisation, and a power of attorney executed in the required form.
The rule in one paragraph
China became a party to the Hague Convention Abolishing the Requirement of Legalisation for Foreign Public Documents (the Apostille Convention), and the Convention has been in force for China since 7 November 2023. For documents issued in another Contracting State, an Apostille issued by that State's competent authority replaces consular legalisation. For documents from a State that is not a party to the Convention, the chain of notarisation and consular legalisation still applies in the usual way.
Practical consequence: a marriage certificate, birth certificate or court document from a Contracting State can often be prepared for use in China more quickly and at lower cost than before 2023 — but the document still needs an accurate Chinese translation, and whether an Apostille is acceptable for a particular court filing is a question the receiving court answers in practice.
Countries that can use an Apostille
For documents issued in the following states or regions that are relevant to China-connected family matters, an Apostille from the competent authority of the issuing state replaces consular legalisation:
| Country / region | Authentication body (typical) | Note |
|---|---|---|
| United States | State Secretary of State (state documents) | Federal documents go through the US Department of State |
| United Kingdom | Foreign, Commonwealth & Development Office | — |
| Australia | Department of Foreign Affairs and Trade | Marriage certificates come from the state registry |
| Japan | Ministry of Foreign Affairs | Family register (koseki) is usually the key document |
| Canada | Provincial / territorial authority; Global Affairs Canada (federal) | In force since 11 January 2024 |
| Singapore | Singapore Academy of Law | Apostille Act 2021 |
| South Korea | Ministry of Foreign Affairs | — |
| New Zealand | Department of Internal Affairs | — |
| Philippines | Department of Foreign Affairs | — |
| Indonesia | Ministry of Law and Human Rights | In force since 4 June 2022 |
| Russia | Ministry of Justice / regional authorities | — |
| South Africa | Department of International Relations and Cooperation | — |
| Brazil | Authorised notaries and registries | — |
| United Arab Emirates | Ministry of Foreign Affairs | In force since 2023 |
| Hong Kong, China | High Court of the Hong Kong SAR | Separate jurisdiction within China |
| Macao, China | Notary / competent authority | — |
| Vietnam | Competent authority in Vietnam | In force since 11 September 2026 |
Countries that still need consular legalisation
For documents issued in the following states, the Apostille route is not available and the longer notarisation-plus-consular-legalisation chain still applies. Consular processing times should be built into any timetable, and the chain is materially slower than an Apostille.
| Country | Why |
|---|---|
| Malaysia | Not a party to the Apostille Convention |
| Myanmar | Not a party to the Apostille Convention |
| Cambodia | Not a party to the Apostille Convention |
| Laos | Not a party to the Apostille Convention |
| Saudi Arabia | Practice commonly requires authentication beyond the Apostille |
| Qatar, Kuwait, Egypt, Iran | Not covered by the Apostille route for China purposes |
| Thailand | Not yet — the Apostille Convention takes effect for Thailand on 28 February 2027; until then consular legalisation applies |
Three exceptions that are easy to get wrong
- India. India is a party to the Apostille Convention, but the Convention is not applicable between China and India. An Indian Apostille is therefore not sufficient for a Chinese filing, and the consular route applies instead.
- Taiwan, China. Taiwan, China is not a party to the Apostille Convention, so the Apostille route is not available for documents issued there. A separate notarisation and verification route applies.
- Hong Kong, China and Macao, China. These are separate jurisdictions within China and are parties to the Convention in their own right, so an Apostille from the relevant Hong Kong or Macao authority applies — but the document is then authenticated as a foreign public document for Mainland filing purposes.
Key dates to remember
| Date | What changed |
|---|---|
| 7 November 2023 | The Apostille Convention entered into force for China |
| 11 January 2024 | Entered into force for Canada |
| 2023 | Entered into force for the United Arab Emirates |
| 4 June 2022 | Entered into force for Indonesia |
| 11 September 2026 | Entered into force for Vietnam |
| 28 February 2027 | Due to enter into force for Thailand |
Guidance written before these dates may state the wrong route. Always check the date on which the country in question acceded before ordering authentication.
Frequently asked questions
Free initial review of jurisdiction, documents and enforceability — before any cost is committed.