What makes a translation official? Rules in the US, UK, Germany and France

What this guide covers

The word "official" means something different at each office that asks for it. Each link below jumps to one country or one step, and the FAQ at the end has the short answers.

• Official means what the receiving authority's rule says
• Five things people call official
• United States
• United Kingdom
• Germany
• France
• Inside the EU, when no translation is needed
• Apostille, legalization and translation, in which order
• Will a translation made abroad be accepted?
• Which kind does each office usually ask for?
• Preparing a document for an official translation

Official means what the receiving authority's rule says

There is no world standard for an official document translation. The Hague Conference on Private International Law, which runs the Apostille Convention, puts it plainly. The nature of translations differs from state to state, and the law of the state of origin decides who is an official translator and what form the translation takes[1]. So the first question is always who will read the translation, and what that office's rule asks for.

United States (USCIS)

The translator certifies that the translation is complete and accurate and that they are competent in both languages[2]

United Kingdom (Home Office)

A dated full translation with the translator's confirmation of accuracy, name, signature and contact details[5]

Germany (authorities)

A translation, and in justified cases a certified one or one by a publicly appointed or sworn translator[3]

France (authorities)

A traducteur agréé, an expert listed by a cour d'appel or the Cour de cassation[4]

Spain

A traductor-intérprete jurado appointed by the Ministry of Foreign Affairs[6]

Between EU countries

For many civil records, a multilingual standard form instead of a translation[7]

Five things people call official

People say "official" for five different things. Each one has an owner, a thing it proves, and a page on this site that covers it in depth.

These overlap. A Spanish sworn translation is also signed, a German one can later carry an apostille through a court's confirmation, and a US certified translation becomes notarized when the translator signs in front of a notary. The table tells you which word the receiver means.

United States

The US has no official translator status at all. There is no federal or state licensing system for translators, and anyone can certify a translation[10]. What makes a translation acceptable is the certification attached to it. For USCIS, that is the translator's statement that the English text is complete and accurate and that they are competent in both languages[2].

The US government does have translators, but not for the public. The State Department's Translating Division provides translation services to the Department of State, the White House and other U.S. Government agencies[11]. A private person with a birth certificate gets no government translation.

Individual receivers can ask for more. A credential evaluator such as WES wants word-for-word translations by a professional translator and does not accept translations completed by applicants[12], which USCIS does not rule out[2]. Some offices want the translator's signature notarized.

For the full US picture, read the USCIS translation guide, the certificate of translation template, how to get a certified translation, notarized translation and WES translation requirements.

United Kingdom

For immigration, the Home Office sets the rule in paragraph 39B of the Immigration Rules. A document not in English or Welsh comes with the original and a full translation that the officer can verify independently[5]. The translation is dated and includes four things[5]:

• confirmation that it is an accurate translation of the original document
• the full name and signature of the translator or of an authorised official of the translation company
• the translator's or translation company's contact details
• for leave to remain or indefinite leave to remain, certification by a qualified translator and details of the translator's or company's credentials

The last point is where the UK differs from the US. For an extension or settlement application the translator's credentials become part of the translation[5]. The certified translation UK guide explains what counts as qualified and how the professional bodies word the statement.

Do not confuse a certified translation with a certified copy. GOV.UK describes certifying a document as getting a copy signed and dated by a professional person, like a solicitor, to confirm it is a true copy of the original[13]. That says nothing about a translation. A bank that asks for a certified copy of a foreign passport and a Home Office caseworker who asks for a translation want two different things.

Qualifications are compared by UK ENIC, which describes itself as the official organisation for the recognition and comparison of international qualifications and skills, working with the Department for Education[14]. The guide to the UK ENIC Statement of Comparability covers its translation rules.

Germany

German is the official language. Section 23 of the federal Administrative Procedure Act (VwVfG) says so in its first line. When someone files an application or a document in another language, the authority should ask for a translation without delay. In justified cases it can ask for a certified translation, or one made by a publicly appointed or sworn interpreter or translator. If the translation does not arrive promptly, the authority can have one made itself at the applicant's cost[3].

Who is sworn or authorised. The state justice departments run a shared database of the interpreters and translators who are generally sworn, publicly appointed or generally authorised in each federal state. Since January 1, 2023 that status follows the federal Court Interpreters Act or the law of each state. You can search the database by name, place or language, and each entry shows the translator's languages and contact details[9].

A sworn translation is still not a public document. The Federal Foreign Office explains that translations count as expert work, not public documents, and that the confirmation or stamp of a sworn translator does not turn the translation into a public document. The president of the competent court can confirm the translator's status or certify the signature, and that official note can then receive an apostille or legalization[15].

Courts, registry offices and notaries. Three other federal rules use the same idea. A civil court can order a translation made by a translator authorised or publicly appointed under state law, and such a translation counts as correct and complete when the translator certifies it on the translation with the place, the date and their status[16]. A registry office (Standesamt) that receives a foreign-language document should ask for a German translation[17]. A notary can certify a German translation of a deed they drew up in a foreign language, but only if they know the language well enough[18].

Procedures. The German pages cover the common cases: beglaubigte Übersetzung (certified translation), recognition of a foreign degree, Zeugnisbewertung (the statement of comparability for a foreign degree) converting a foreign driving licence and the documents for naturalisation. They are written in German.

France

The traducteur agréé. In France, the official version is made by a traducteur agréé, who is an expert judiciaire on the lists kept by the cours d'appel and the Cour de cassation. You can pick a translator from the national list of the Cour de cassation or from a cour d'appel list, and an online service helps you find one[4]. People also call this a traduction assermentée.

From abroad. For a document translated outside France, Service-Public says the consulate's website may list the translators approved by the local authorities, and that the consulate has to certify the translator's signature[4]. Check that step with the consulate before you pay for a translation abroad.

Translation before légalisation. A foreign public document used in France, such as a birth certificate for a nationality application, often has to be legalised by the French embassy or consulate in the issuing country. Service-Public says a public document in a foreign language must come with a French translation by an authorised translator, and that the translation is done before the légalisation starts. The consulate charged €30 for French nationals on the consular register and €60 for others when we checked, and some documents are exempt by treaty or need only an apostille[19].

Procedures. The French pages cover finding a traducteur assermenté, the attestation de comparabilité for a foreign diploma, exchanging a foreign driving licence and a French criminal record in English. They are written in French.

Inside the EU, when no translation is needed

Between EU countries, a common civil record often needs no translation at all. Regulation (EU) 2016/1191, in force since February 16, 2019, lets citizens ask the issuing country for a multilingual standard form, available in all EU languages, and attach it to the public document. With the form attached, the receiving authority can only require a translation in exceptional circumstances[7].

The regulation covers public documents on birth, being alive, death, name, marriage and marital status, divorce, registered partnership, parenthood, adoption, residence, nationality, the absence of a criminal record and the right to vote in municipal and European elections[7]. It also drops the apostille for these documents between EU countries[7].

When a receiving authority does ask for a certified translation, it has to accept one made in any EU country[7]. A French birth record with its multilingual form, or a German one, can usually go to Spain without a Spanish translation. See the French guide to the acte de naissance plurilingue and the German guide to the internationale Geburtsurkunde.

The regulation deals with authenticity, not legal effect. Whether the receiving country recognises what the document says is still governed by its national law[7].

Apostille, legalization and translation, in which order

An apostille only authenticates where a public document came from, by certifying the signature, the signer's capacity and the seal. It says nothing about the content[1]. So an apostille never makes a translation correct, and a translation never replaces the apostille.

The Handbook describes three ways a translation itself can carry an apostille[1]:

• where the translation is a public document in its own right, because an official translator made it under the law of the state of origin
• where the translator makes a sworn statement of accuracy before a notary, and the notarial certificate is apostilled
• where an official authority certifies the translation, and that certificate is apostilled

Germany uses the third route, with the court president's confirmation as the certificate[15]. If the receiver wants the apostille only on the original, get the apostille first and then have the document and its apostille translated together. If it wants the apostille on the translation, the translation comes first. For légalisation in France the order is fixed, the French translation first and the consulate's légalisation after[19]. The apostille guide walks through the US routes and the German apostille guide the German ones.

Will a translation made abroad be accepted?

The receiving country decides, not the country where the translation was made. The Federal Foreign Office says that whether a translation made in Germany is recognised in another state depends on the law of the state where it will be used[15]. The Hague Handbook adds that an apostille cannot be rejected for its language, but the receiving authority can still reject the underlying document under its own law because it is in another language or has no translation[1].

Consulates give concrete answers. The Consulate General of Spain in London, for example, points people to the Institute of Translation and Interpreting and the Chartered Institute of Linguists when a Spanish document will be used in the UK, and says a document used in Spain needs a traductor-intérprete jurado registered in Spain[20].

For the US, the USCIS rule asks for a translator's certification of accuracy and competence[2]. Our reading is that a sworn translation into English made in Spain or Germany fits when it carries that statement, and that the translator or a reviewer adds one when it does not. USCIS has published no rule on foreign sworn translations that we found. The UK works the same way. Paragraph 39B lists what the translation contains, the translator's confirmation of accuracy, name, signature and contact details[5], so our reading is that a sworn translation from abroad meets the paragraph when it carries all of them, whatever its stamp says. Inside the EU, a certified translation from any member state has to be accepted[7].

Which kind does each office usually ask for?

The same birth certificate can need three different translations depending on where it goes. This table pairs common receivers with what their own rule says. Where a rule leaves room, the office can still ask for more, so treat the right-hand column as the floor.

Preparing a document for an official translation

How to translate official documents comes down to the same five steps everywhere.

1. Ask the receiver what it accepts. Certified, sworn, notarized or apostilled, and whether the translator has to be from its own country. The table above has the words to use.
2. Get a clean, complete copy. Scan every page and the back of each page. Stamps, handwriting and annotations are part of the document.
3. Make an editable draft. Upload the scan to LoreAI and download the Word file in the target language. It keeps the headings, lists and tables in the original order, and names, dates and numbers stay as written.
4. Hand the scan and the draft to the person who signs. In the US, a translator can certify a translation they reviewed rather than made, as long as the statement says so[8]. A sworn translator elsewhere decides under their own rules whether to work from a draft, so ask before you send one.
5. Add the formalities in the order the receiver wants. Signature, notary, apostille or court confirmation, as the earlier sections describe.

Where LoreAI fits

LoreAI makes nothing official. It is not a certified, sworn or notarized translation service, it does not sign or stamp, and no authority has approved it. It reads scanned PDFs and photos with OCR and returns an editable Word file in 105 languages, so the translator who does sign starts from a laid-out draft instead of a blank page.

Your first document is free, up to 3 pages. The upload is deleted right after it is read, and the results about an hour later unless you turn on Keep my translated documents.

Questions people ask