Legalisation or Attestation: What Is the Difference?

Legalisation is the chain of official checks, usually DFAT authentication then embassy legalisation, that lets a foreign country rely on an Australian document. Attestation has two meanings: in Australia it usually means witnessing a signature, but many Gulf and South Asian authorities use it for the same legalisation chain. The destination's own wording decides what you need.

Key takeaways

• Legalisation is a chain of signature checks, typically DFAT authentication followed by the embassy of the destination country.
• In Australian law, attestation usually means witnessing a signature on a document, such as a deed or will.
• In the UAE, Qatar, Kuwait and some other countries, "attestation" is used for the legalisation chain itself.
• For countries in the Hague Apostille Convention, an apostille usually replaces legalisation.
• Read the foreign body's instructions carefully, and ask what each step means in its terms.

What is legalisation?

Legalisation is the process by which one country's officials confirm the signature and seal on a document from another country, so it can be relied on. It does not check the content of the document. Instead, each official in the chain confirms the signature of the one before, until the document reaches an official the destination country recognises.

For an Australian document going to a country outside the Hague Apostille Convention, the usual chain is: a notary notarises the document (or it is a public document signed by an Australian official), DFAT authenticates the notary's or official's signature, and then the embassy or consulate of the destination country in Australia legalises DFAT's signature. Some countries add a further step on arrival, often at their foreign ministry. Our guide to legalisation by consulates explains the embassy stage.

What does attestation mean in Australia?

In Australian legal usage, to attest a document usually means to witness its signing and sign it as a witness. An attestation clause is the part of a deed, will or other document where the witness signs, often with words such as "signed, sealed and delivered in the presence of". A person who witnesses a will is an attesting witness. In this sense, attestation happens before any legalisation, and has nothing to do with DFAT or embassies.

A notary can attest documents, and when a document is going overseas, attestation by a notary is often expected because the notary's signature can later be authenticated or apostilled. Our guide to witnessing signatures with a notary covers this part of the process.

What does attestation mean in Gulf and South Asian countries?

Many authorities in the Gulf and South Asia use "attestation" for what Australia calls legalisation. A UAE employer or ministry that asks for a degree to be "attested" usually wants the full chain: notarisation or certification in Australia, DFAT authentication, legalisation by the UAE embassy or consulate in Australia, and then a further check by the UAE's foreign ministry after arrival. Similar language is used for Qatar, Kuwait and other countries in the region, and by some employers and agencies elsewhere.

This difference in wording causes a lot of confusion. Someone asked for "attestation" may get a document witnessed by a JP, believing that is enough, and then find the foreign body wanted the full legalisation chain. Always ask what the foreign body means by attestation, and which offices it expects to see. Our guide to documents for the UAE from Australia covers that country in more detail.

Term	Usual Australian meaning	Usual Gulf or South Asian meaning
Attestation	Witnessing a signature on a document	The full chain of official checks
Legalisation	DFAT authentication then embassy step	Often the embassy step specifically
Authentication	DFAT's check for non-Hague countries	Sometimes used for any official check
Apostille	DFAT's single certificate for Hague countries	Used where the country is a member
Notarisation	A notary's act on the document	Often the first step in attestation

Where does the apostille fit in?

The Hague Apostille Convention replaced legalisation with a single certificate, the apostille, between member countries. For an Australian document going to a member country, DFAT issues one apostille and no embassy step is needed. Many countries have joined in recent years, including China (in force from November 2023), Canada (January 2024) and Bangladesh (March 2025).

Several countries remain outside the Convention. As at the latest check of the status table, these include the UAE, Qatar, Kuwait, Egypt, Jordan, Lebanon, Malaysia, Nepal, Sri Lanka and Taiwan, among others. For those, the full legalisation chain is still needed. Check the destination on the HCCH status table before you start, and see our guide to the Hague Apostille Convention.

Which documents usually need legalisation?

Almost any Australian document used officially in a non-Hague country may need it. Common examples include university degrees and transcripts for employment, marriage and birth certificates for residence visas or family sponsorship, police checks, powers of attorney, company documents for setting up a branch or opening a bank account, and commercial documents such as certificates of origin and invoices for trade.

The type of document affects the first step. A public document signed by an Australian official, such as a birth certificate issued by a state registry, may be authenticated by DFAT directly, depending on DFAT's list. A private document, such as a power of attorney, or a copy of a degree, usually needs to be notarised first. DFAT does not legalise foreign education documents, so a degree from another country must be dealt with in that country. Our guide to which documents DFAT can process covers the common cases.

Why does the full chain take longer?

An apostille is a single step at DFAT. Legalisation involves at least two offices, and sometimes three or four, each with its own forms, fees, opening hours and processing times. Embassies and consulates set their own rules: some accept documents by post, some only in person, some need an appointment, and some want copies of your passport or a covering letter. A few only legalise documents for their own nationals or residents, or need the document to be translated first.

Because each office works independently, delays add up. It is sensible to check each embassy's current requirements directly, on its own website or by phone, before sending anything, and to allow extra time if the document is needed by a deadline, such as a visa appointment or a job start date.

What about translations?

If the destination uses another language, the foreign body may want a translation. The key question is when it is made and who makes it. Some countries accept a NAATI-certified translation made in Australia, notarised and then legalised along with the original. Others want the translation done after legalisation, by a sworn or court-approved translator in their own country. Arabic translations for Gulf countries are often made in the destination country after the embassy step. Ask the foreign body which order it wants, since translating at the wrong point can mean paying twice. Our guide to certified translations in Australia covers the options here.

How do you get a document legalised?

1. Read the foreign body's instructions and note exactly which steps and offices it names.
2. Check the destination on the HCCH status table: apostille or legalisation.
3. Get the document notarised if it is a private document or a copy.
4. Apply to DFAT for an apostille, or for authentication if the country is not a member.
5. Take it to the embassy or consulate of the destination country for legalisation, if required.
6. Complete any step on arrival, such as the foreign ministry's check.

Common mistakes to avoid

Several mistakes come up again and again. People get a JP to witness a document when the foreign body wanted full attestation, then have to start again with a notary. Others apply for an apostille for a country that is not a Convention member, or skip the embassy step after DFAT authentication. Some send a document to the embassy before DFAT, when embassies usually require DFAT's certificate first. Checking the chain at the start avoids most of these delays. If an embassy does reject a document, see what to do if an embassy rejects your document.

What does this look like in practice?

Here is an illustration, not a real case. Sara has a job offer in Dubai, and the employer asks for her Australian degree to be "attested". Her friend suggests a JP, but Sara checks with the employer, who explains it means the full chain.

A notary prepares a notarial copy of the degree. DFAT authenticates the notary's signature, as the UAE is not a member of the Apostille Convention. The UAE embassy in Canberra then legalises it. On arrival, Sara has it checked by the UAE's foreign ministry, and the employer accepts it. Had she relied on the JP's signature, the embassy would likely have refused it.

In short

Legalisation is the chain of official signature checks that lets a foreign country rely on an Australian document, usually DFAT authentication and then the embassy. In Australia, attestation usually means witnessing a signature; in the Gulf and parts of South Asia, it usually means the whole legalisation chain. For Hague Convention countries, an apostille usually replaces legalisation. Ask what the foreign body means. Our apostille and authentication services page explains how this works with us.

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Not sure whether you need attestation, legalisation or an apostille? Send us the foreign body's instructions, and we will explain each step before you book.