A document issued in mainland China is authenticated in China, not by an Australian notary. Most Australian bodies want the Chinese original or a Chinese notarial certificate, a NAATI-certified English translation, and sometimes a certified copy. Since late 2023, China issues apostilles instead of relying only on consular legalisation, which has made the process shorter.
China's accession to the Hague Apostille Convention came into force in November 2023. Before that, a Chinese document used abroad usually needed authentication by Chinese authorities and then legalisation by the receiving country's embassy. Now a single apostille from a Chinese authority is normally enough between member countries, subject to any objections recorded by the HCCH.
Two practical points follow. First, older documents may carry the earlier embassy legalisation stamps, and that is not a reason to redo them if the receiving body is satisfied. Second, whether an Australian body wants an apostille at all is its own decision. Many Australian uses, including most visa applications, rely on translations and copies rather than apostilles. Check the current position on the HCCH status table before you pay for authentication.
A Chinese notarial certificate is a document issued by a notary office in China that formally confirms a fact, such as a birth, a marriage, a relationship or the absence of a criminal record. It is often bound with a translation and is the form many overseas bodies expect, because some Chinese records are not designed for use abroad.
Chinese notary offices are public bodies with a different role from an Australian notary public. An Australian notary witnesses signatures and certifies copies; a Chinese notary office can certify facts drawn from official records. That is why an Australian notary cannot replace a Chinese notarial certificate. If a Chinese record needs to be proved, the proof has to come from China.
A notarial certificate usually comes as a bound booklet, sometimes with an English translation added by the notary office. Keep it bound. Taking the pages apart can make the certificate unusable, because the binding is part of what shows nothing has been added or removed.
The documents that come up most in Australia are notarial certificates of birth, marriage or kinship, marriage certificates, household register records, degree and graduation certificates, and certificates of no criminal record. Each is issued, and proved, by a different Chinese body, so a problem with one is fixed with that body.
| Chinese document | Usually proved by | Common Australian use |
|---|---|---|
| Birth or kinship | Notarial certificate from a Chinese notary office | Visas, citizenship, family claims |
| Marriage certificate | The certificate, often with a notarial certificate | Partner visas, name changes |
| Household register (hukou) | Copy of the relevant pages, sometimes notarised in China | Identity and family details |
| Degree or graduation certificate | Certificate plus an official verification report if asked | Skills assessments, employers, universities |
| No criminal record | Notarial certificate issued in China | Visas and some professional registrations |
Degree documents deserve a note of their own. Some Australian universities, skills assessors and employers ask for an official verification report from China's higher-education verification service rather than a certified copy. Ask the receiving body which form it accepts before you order anything, because a certified copy will not stand in for a verification report it requires.
Yes, when an Australian body relies on them. Anything in Chinese, including stamps and seals, needs an English translation. When the translation is made in Australia, use a NAATI-credentialled translator. A translation bound into a Chinese notarial certificate may be accepted by some bodies, but not by all of them.
Home Affairs accepts translations made outside Australia only when they show the translator's full name, address and credentials. Other Australian bodies can set their own rules. Mainland documents use simplified characters, while documents from Hong Kong, Macau and Taiwan normally use traditional characters, so tell the translator where the document came from. Our NAATI translation guide explains what a certified translation must include.
An Australian notary can certify that a copy matches the Chinese original they have sighted, witness your signature on a statutory declaration or affidavit, and witness a translator's declaration. A notary cannot confirm that the contents of a Chinese record are true, cannot issue a Chinese notarial certificate, and cannot issue an apostille.
For Australian purposes you may not need a notary at all. A Justice of the Peace or another authorised person can usually certify a copy for Home Affairs. A notary becomes useful when the paperwork goes the other way: for example, a power of attorney signed in Australia so a relative can deal with property in China. That document is notarised here and then apostilled by DFAT. Our guide to sending Australian documents to China covers that direction.
Work from the receiving body's own checklist, because Home Affairs, AHPRA, universities and skills assessors each ask for slightly different things. The steps below keep the order right, so that a translation is not made from a document that later has to be replaced.
You usually have to deal with the Chinese authority that holds the record, which may mean applying through a relative in China, through an online service offered by the issuing body, or through the Chinese embassy or consulates in Australia for services they offer to Chinese citizens. Which route is available depends on the document, so check the official source first.
Some documents, such as a certificate of no criminal record, are issued based on where you lived in China, and a recently issued one is often required. Build that into your timing, and ask the Australian body how recent the certificate must be before you order it. An Australian notary can witness any authority letter or declaration the Chinese office asks you to sign, and DFAT can then apostille it if the Chinese side requires that.
Yes. Hong Kong and Macau have their own authorities and their own apostille arrangements, and Taiwan's documents follow a separate process again. A mainland notarial certificate process does not apply to them, and the characters used are usually traditional rather than simplified, which matters for translation.
If your document comes from one of these places, start with the issuing authority there. For Australian documents going the other way, see our guides for Hong Kong and Taiwan. The Australian side, a NAATI translation and a certified copy where asked, works the same way for all of them.
Here is an illustration, not a real case. Wei is in Sydney applying for a skills assessment. The assessor asks for a degree verification report and an employment reference, and Home Affairs later asks for a certificate of no criminal record covering the years Wei lived in China.
Wei orders the verification report online from the official Chinese service instead of certifying a copy of the degree, because that is what the assessor asked for. For the criminal record certificate, Wei signs an authority letter in Australia so a relative can apply in China; a notary witnesses the letter because the Chinese office asked for a notarised signature. The certificate arrives as a bound notarial booklet, which Wei scans without unbinding and sends with a NAATI translation of every page.
Chinese documents are proved in China, usually through a notarial certificate and, since November 2023, an apostille where one is needed. In Australia you add a NAATI translation and, where asked, a certified copy. An Australian notary helps when you sign something here for use in China, not when you need a Chinese record confirmed.
Not sure what your Chinese document needs for Australian use? Send us the document and tell us where it is going, and we will explain each step. For translation with a notarial certificate, see our NAATI translation with notary certification service.
An Australian notary can certify that a copy matches the original they have seen, but cannot confirm the facts in a Chinese record. Where a birth needs to be proved, many Australian bodies expect a notarial certificate issued by a notary office in China, with an English translation.
Yes. China's apostille arrangements came into force in November 2023, so Chinese public documents can be apostilled by Chinese authorities for use in member countries. Objections between particular countries can apply, so check the HCCH status table on the day you need it.
Usually not. Home Affairs generally asks for clear copies and English translations, and sometimes for certified copies. Follow the checklist for your visa stream and only arrange an apostille if the checklist or your case officer asks for one.
Sometimes. Some Australian bodies accept the translation bound into a Chinese notarial certificate, while others insist on a NAATI-credentialled translator. Home Affairs accepts overseas translations only if they show the translator's full name, address and credentials. Ask the receiving body before relying on it.
No. A notarial certificate is bound so that pages cannot be added or removed without it showing. Unbinding it can make it unusable. Scan the booklet as it is, page by page, and keep the bound original safe in case you are asked to produce it.
It depends on the assessor. Some ask for an official verification report from China's higher-education verification service instead of, or as well as, a certified copy. Check the assessor's instructions first, because a certified copy will not replace a report it requires.
Often, but the route depends on the document. You may apply through a relative in China with an authority letter, through the issuing body's online service, or through the Chinese embassy or consulates in Australia where they offer the service. Check the official source for that document.
For Australian purposes, often yes. A Justice of the Peace or other authorised person can usually certify a copy against the original for bodies such as Home Affairs. A JP copy is generally not accepted overseas and cannot be apostilled, so use a notary for copies going abroad.
No. Hong Kong, Macau and Taiwan each have their own authorities and processes, and their documents usually use traditional rather than simplified characters. Start with the issuing authority where the document came from. The Australian steps, translation and certified copies, are the same.
It can be. Family name order and romanisation often differ between Chinese records and passports. Tell your translator how your passport shows your name, and be ready to give a statutory declaration explaining the difference if the receiving body asks for one.