After years of preparing immigration and nationality files across five countries, we can say something that surprises most clients: the overwhelming majority of refusals, exigências and six-month delays we are asked to repair have nothing to do with whether the applicant qualified. They qualified. What failed was the paperwork about the paperwork — a certificate issued in short form when the long form was required, an apostille attached to a photocopy rather than the original, a translation done by a bilingual friend rather than a sworn translator, a police certificate that was valid when it was ordered and expired by the time the file was filed.
This is the least glamorous part of an international move and the part that most reliably decides its outcome. Here is how the document chain actually works.
What an apostille is — and what it is not
An apostille is a certificate attached to a public document by a designated authority in the country that issued it, confirming that the signature, seal or stamp on the document is genuine. It exists under the 1961 Hague Convention Abolishing the Requirement of Legalisation for Foreign Public Documents, and it replaces the older, slower chain of consular legalisation between member states.
Two points are constantly misunderstood. First, an apostille says nothing about the content of a document — only that the official who signed it was who they claimed to be. Second, the apostille is always obtained in the country that issued the document, never in the country where you intend to use it. A Brazilian birth certificate is apostilled in Brazil, by a Brazilian cartório authorised to do so; a British certificate is apostilled by the UK's Legalisation Office. The French préfecture cannot apostille your Brazilian document, and the Brazilian consulate in Paris cannot either.
All five of our destinations — Brazil, France, Spain, Ireland and the United Kingdom — are parties to the Convention, as are most of the countries our clients come from. Brazil joined in 2016, which is why documents issued before that date sometimes carry a legalisation stamp rather than an apostille and occasionally need to be reissued.
When there is no apostille: consular legalisation
For documents from countries outside the Convention, the old chain still applies: the document is authenticated by the issuing country's foreign ministry, then legalised by the destination country's embassy or consulate there. It is slower, more expensive, and considerably more sensitive to sequence — each step refuses to act until the previous one is visibly complete. Clients from Iran, parts of the Gulf and several African jurisdictions meet this routinely, and files involving such documents should be started months rather than weeks before they are needed.
Sworn translation: who is allowed to translate
Almost every administration requires foreign-language documents to be translated, and almost every administration is specific about who may do it. The word "certified" means different things in different countries:
- Brazil requires a tradutor público juramentado — a sworn public translator appointed by the state commercial registry (Junta Comercial). A translation by anyone else, however competent, has no legal standing.
- France requires a traducteur assermenté, registered on the list maintained by a court of appeal. The translation carries the translator's seal and registration number.
- Spain requires a traductor jurado appointed by the Ministry of Foreign Affairs, whose sworn translations carry a specific certifying formula.
- The United Kingdom and Ireland have no sworn-translator institution in the continental sense; they accept certified translations from professional translators or agencies accompanied by a statement of accuracy, the translator's credentials and contact details.
A practical consequence worth noting: a sworn translation made in one country is not automatically accepted in another. A file that will be used in France should generally be translated by a French-registered sworn translator, even when the client already holds a perfectly good Brazilian sworn translation of the same document.
The five failures we see again and again
- The apostille on the wrong document. It must be attached to the original or to an authorised certified copy — not to a photocopy you made, and not to the translation instead of the source document.
- Translating before apostilling. The apostille itself is part of the document set and generally needs to be translated too. Translate first and you will often pay twice.
- Expired certificates. Criminal-record certificates and civil-status extracts typically carry a validity window — often around three months — that runs from issue, not from filing. Ordering them at the start of a six-month document hunt is a false economy.
- Short-form certificates where long-form is required. Many nationality procedures, French CNF files above all, require full-form civil-status records showing filiation and marginal annotations. A short-form extract will be returned.
- Name discrepancies. Emigration-era transliteration, married names, accents dropped by one registry and kept by another. Every mismatch across the chain has to be explained or corrected before filing — after a refusal, it costs ten times as much.
The sequence that works
For a typical file the correct order is: identify exactly which documents the receiving authority requires, and in which form; order the originals in that form, checking whether long-form is needed; apostille or legalise them in the issuing country; only then commission the sworn translation, including the apostille; and time the shortest-lived documents — police certificates above all — so that they are ordered last and are still valid on the day of filing. Getting that last point right is a scheduling exercise, and it is the one clients handling their own files almost never win.
How we help
Coordinating this chain is inside the scope of every Concierge engagement we take: we determine what each authority requires for your specific case, obtain or instruct what is missing across countries, commission sworn translations from the right jurisdiction, and sequence the whole set so that nothing expires while something else is being processed. External costs — notary fees, apostille fees, translators — are quoted and approved in advance, never absorbed into a vague estimate. Start with an Initial Consultation, or read about how we work in Brazil, France, Spain, Ireland and the United Kingdom.
Frequently asked questions
Can I translate my own documents if I am bilingual?
No — not for any official procedure in Brazil, France or Spain, where the translator must hold a specific appointment. Even in the UK and Ireland, a translation by an interested party rather than an independent professional is routinely rejected.
How long does an apostille take?
From same-day in some Brazilian cartórios to several weeks in other jurisdictions, depending entirely on the issuing country and the type of document. Because the rest of the chain waits on it, it is the step we schedule first.
Do digital documents and digital apostilles count?
Increasingly yes — several countries now issue electronically verifiable civil-status documents and electronic apostilles, and many receiving authorities accept them. Whether a specific authority accepts a specific electronic format is a question to confirm case by case rather than assume, and it is one of the things we check before ordering anything.
My documents are already apostilled and translated. Can you just file?
Sometimes — and when a set genuinely holds up, we say so and proceed. More often a review finds one or two items in the wrong form. That is precisely what our file audit exists for: a structured verdict on what is usable, what needs reissuing, and what is missing, before anything is submitted.