Jurat or Acknowledgment: US Notary Forms Signed in Australia

A jurat and an acknowledgment are two kinds of US notarial certificate. With a jurat, you sign before the notary and swear or affirm that the contents are true. With an acknowledgment, you confirm the signature is yours and was made willingly. An Australian notary can usually do either, and the document normally then needs a DFAT apostille.

Key takeaways

• A jurat involves an oath or affirmation about the contents, and you sign in front of the notary.
• An acknowledgment confirms the signature is yours and was made willingly; no oath about the contents.
• The US document usually tells you which one it needs, by its certificate wording.
• An Australian notary can usually complete either, adapting the wording where needed.
• The United States is a Hague member, so the notarised document usually needs a DFAT apostille.
• If you are unsure which you need, ask the US sender; do not guess.

What is a jurat?

A jurat is the certificate a US notary completes when someone swears or affirms that the statements in a document are true. It usually begins with a phrase like "subscribed and sworn to before me" and records the date and the name of the person who took the oath. Affidavits, sworn declarations and many forms used in US courts and government agencies need a jurat.

Two things define it. First, you sign in front of the notary, at the appointment. Second, the notary administers an oath or affirmation, and you confirm that the contents are true. The notary does not check the facts themselves; you are responsible for them, and a false sworn statement is a serious matter. In Australian terms, a jurat is close to swearing an affidavit. Our guide to notarising an affidavit explains how that works here.

What is an acknowledgment?

An acknowledgment is the certificate a US notary completes when someone confirms that a signature on a document is theirs and that they signed it willingly. It usually includes wording like "personally appeared before me" and "acknowledged that he or she executed the same". Deeds, powers of attorney, mortgages and other documents that transfer property or authority often need an acknowledgment rather than a jurat.

The key difference is that there is no oath about the contents. You are not saying that what the document states is true; you are saying that you are the person who signed it and you did so freely. In the US, an acknowledgment is often used for documents a person may have signed before they see the notary, since the point is to confirm the signature, not to witness the act of signing. An Australian notary may still prefer you to sign in front of them, so do not sign before your appointment unless the notary tells you it is fine.

Point	Jurat	Acknowledgment
What you confirm	The contents are true	The signature is yours, made willingly
Oath or affirmation	Yes	No oath about the contents
When you sign	In front of the notary	Often before, but ask the notary
Typical wording	"Subscribed and sworn to before me"	"Personally appeared" and "acknowledged"
Typical documents	Affidavits, sworn declarations, court forms	Deeds, powers of attorney, property forms
Australian equivalent	Swearing an affidavit	A notary witnessing and certifying a signature

How do you tell which one your document needs?

Look at the notarial block, usually at the end of the document, below the signature line. If it says "subscribed and sworn", "sworn to" or "affirmed before me", it is a jurat. If it says "acknowledged before me" or "personally appeared", it is an acknowledgment. Some US forms carry both, one for each signatory or purpose, and some leave the choice to the notary.

If there is no notarial block at all, or the wording is unclear, ask the person or organisation that sent the document. In the US, choosing the type of certificate is often treated as the signer's decision rather than the notary's, because it is a legal choice about what the document needs. An Australian notary will generally not decide it for you either. Get the answer in writing from the US lawyer, title company, bank or court clerk who is expecting the document.

Should you swear or affirm for a jurat?

Either is fine. A jurat covers both an oath, which is sworn on a religious basis, and an affirmation, which is a solemn promise without religious wording. They carry the same weight, and you are equally bound to tell the truth under either. Tell the notary which you prefer at the start of the appointment. If the US form says only "sworn", an affirmation is usually still acceptable, and the notary can record that you affirmed. If the recipient has particular requirements, they will normally say so in the signing instructions.

Are there other US certificate types?

Yes, though jurats and acknowledgments are by far the most common. Some US forms ask for a copy certification, where a notary confirms a copy matches an original, or a signature witnessing, where the notary simply watches you sign without an oath. Rules on these vary between US states. An Australian notary can certify copies and witness signatures, so the same approach applies: read the block, confirm with the sender what is needed, and let the notary adapt the wording to what was actually done in Australia.

Can an Australian notary complete a US jurat or acknowledgment?

Usually, yes. An Australian notary can administer oaths, take affirmations and witness signatures, which covers what both certificates describe. The practical question is the wording. US forms are drafted for US notaries, and they often include a "venue" line, such as "State of ___, County of ___", and a space for a notary commission number and expiry date that an Australian notary does not have.

Australian notaries handle this in different ways. Some complete the US block, adapting the venue to where the document is signed, such as the state and country, and striking out lines that do not apply. Others attach their own notarial certificate, stating what was done, and leave the US block blank. Which approach suits your document depends on what the receiving body will accept, so bring any instructions you have. Our guide to Australian and US notaries explains why the two roles differ.

What happens after the notary signs?

A US recipient cannot easily check an Australian notary's signature, so the document usually needs an apostille. The United States is a member of the Hague Apostille Convention, so DFAT can place an apostille on the Australian notary's certificate. Check the HCCH status table if you want to confirm membership, and see our guide to an apostille for the USA for the steps.

Some US recipients do not ask for an apostille, particularly for informal purposes. Others insist on one. Ask before you lodge anything with DFAT, and allow for delivery time to the US.

What about the US consulate?

US embassies and consulates abroad offer notarial services to people who need US documents signed, including in Australia, usually by appointment. A document notarised by a US consular officer is generally accepted in the US without an apostille, because the officer is a US official. Availability and appointment times vary, and some services are limited, so check the consulate's current information. For many people, an Australian notary followed by a DFAT apostille is the more practical route.

How do you prepare for the appointment?

1. Identify the certificate type. Read the notarial block and confirm with the US sender whether it needs a jurat or an acknowledgment.
2. Do not sign yet. Especially for a jurat, you must sign in front of the notary. For an acknowledgment, ask the notary before signing.
3. Fill in everything else. Names, dates, addresses and any other blanks, so nothing is left open.
4. Bring identification. Current photo identification in the name on the document, such as a passport.
5. Bring the instructions. Any email or letter from the US sender about signing, witnessing and apostilles.
6. Plan the apostille. Allow time for DFAT and for delivery to the US.

Common mistakes to avoid

The most common mistake is signing a jurat at home and bringing it to the notary. Because a jurat records that you swore to the document before the notary, it must be signed in their presence, so a pre-signed jurat usually has to be reprinted. Another is choosing the certificate type yourself because one sounds easier. The type is a legal choice about what the document needs, and the wrong one can see the document rejected in the US.

A third is assuming the US block can simply be left as it is. A venue line reading "State of California" is not accurate for a document signed in Sydney, and a US recipient may notice. Let the notary deal with the wording, and bring the sender's instructions so they know what will be accepted.

Here is an illustration, not a real case.

Hannah, living in Brisbane, is selling a house in Texas. The title company sends her a deed with an acknowledgment block and a separate affidavit about the property with a jurat block. She confirms with the title company that both need an apostille. At the appointment, the notary checks her passport, witnesses her signature on the deed and completes the acknowledgment, then administers an oath and has her sign the affidavit before completing the jurat. Both go to DFAT for apostilles, then by courier to Texas.

In short

A jurat means you sign in front of the notary and swear or affirm that the contents are true; an acknowledgment means you confirm the signature is yours and was made willingly. The US form usually shows which one it needs. An Australian notary can usually complete either, and the document then normally needs a DFAT apostille for the US. Our document notarisation services page explains how this works with us.

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Have a US form with a jurat or acknowledgment to sign? Send us the form and the sender's instructions, and we will explain each step before you book.