The Apostille

The Apostille is an internationally standardised form of certification used to verify the legal validity of public documents issued by one country for use in another. This certification is governed by theHague Conventionof 05/10/1961 Abolishing the Requirement of Legalisation for Foreign Public Documents — commonly known as the Apostille Convention.

On 31/12/2025, Vietnam formally deposited its instrument of accession to the Convention, becoming the 129th country to join. The Convention takes effect in Vietnam from 11/09/2026. This is an important turning point completely changing the document legalisation process between Vietnam and 128 other countries around the world.

What the Apostille is

The Apostille (pronounced “a-po-steel”) is a stamp or certificate in an internationally standard form, affixed by the competent authority of the country issuing the document to confirm the authenticity of the signature, the seal and the authority of the person signing it.

What makes the Apostille distinctive: a single Apostille stamp is valid in all 129 member countries of the Convention — completely replacing the complex multi-step consular legalisation process used previously.

The Apostille applies to 4 main kinds of public document: documents issued by state bodies (birth, death, marriage and divorce certificates, old passports, criminal record certificates), documents issued by courts (judgments, decisions), notarised documents (contracts, powers of attorney, undertakings), and educational documents (diplomas, transcripts).

The history and significance of the Apostille Convention

Before 1961, using public documents across borders was very complex. A document issued in Vietnam for use in France had to go through a long chain of consular legalisation — certification by the issuing body, then by the diplomatic authority of the issuing country, then legalisation by the embassy or consulate of the country of use.

The Apostille Convention was signed on 05/10/1961 at The Hague (the Netherlands) under the auspices of the Hague Conference on Private International Law (HCCH). Its aim: to replace the multi-step legalisation process with a single step — the Apostille stamp.

By December 2025, the Convention had 129 member countries, comprising almost every developed country: the United States, the whole European Union, Britain, Australia, Canada, Japan, South Korea, Singapore, China (since 2023), India, the Philippines, Indonesia, and most recently Vietnam.

Consular legalisation compared with the Apostille

Before 11/09/2026, Vietnamese documents for use abroad (or the reverse) had to go through 3–4 consular legalisation steps: certification of the document by the issuing body, certification by the Vietnamese Ministry of Justice or Ministry of Foreign Affairs, legalisation by the embassy of the country of use in Vietnam, and in some cases additional certified translation.

This process took 4–8 weeks and was costly in service fees, consular fees and travel.

After 11/09/2026, the Apostille process is shortened to a single step: the competent authority of the issuing country affixes the Apostille stamp. That document is then valid for direct use in every other member country — with no need to go through an embassy or consulate. Processing time is estimated to fall by around 90%, with costs falling considerably.

Vietnam’s accession to the Apostille Convention

On 12/12/2025, the Government of Vietnam issued Resolution no. 407/NQ-CP approving accession to the Apostille Convention. On 31/12/2025, the Vietnamese Ministry of Foreign Affairs deposited the instrument of accession with the Ministry of Foreign Affairs of the Kingdom of the Netherlands (the depositary of the Convention).

Under the Convention’s rules, there is a 6-month waiting period during which other member countries may object. Where there is no objection (very rare in the history of the Convention), the Apostille formally takes effect in Vietnam from11 September 2026.

The competent authorities issuing Apostilles in Vietnam: the Ministry of Foreign Affairs, specifically the Consular Department in Hanoi and the Department of External Relations in Ho Chi Minh City.

During the transitional period from now to 11/09/2026, the traditional consular legalisation process continues to apply. People and businesses needing to use documents across borders during this period must still follow the old procedure.

The effect on residence and citizenship by investment and international migration

For residence and citizenship by investment and international migration, the Apostille brings a very large and positive change.

• Shorter document preparation times. Residence by investment applications usually require many kinds of legalised document: birth and marriage certificates, criminal record certificates, bank statements, qualifications, and property title documents. Previously, each document took 4–8 weeks to legalise — with total preparation usually stretching over 2–4 months. After 11/09/2026, this falls to a few weeks.
• Considerably lower costs. Consular legalisation for a complete residence by investment file usually costs VND 15–30 million (depending on the number of documents and the country of use). With the Apostille, this falls by around 70–80%.
• A simpler due diligence process. Citizenship by investment (CBI) and residence by investment (RBI) programmes all require thorough assessment of the source of funds, criminal record and personal documents of the investor. The Apostille makes the assessment process faster and more standardised between Vietnam and the member countries.
• Greater confidence in Vietnamese documents. The Apostille is a widely recognised international standard — Vietnamese documents carrying an Apostille will be processed quickly and will not face the doubts about authenticity they did previously.

The popular residence and citizenship by investment programmes are all in Convention member countries: the United States (EB-5, E-2), Canada (joined 2024), Australia, the EU countries (the Portugal, Greece, Malta, Cyprus and Ireland Golden Visas), the Caribbean CBI countries (Grenada, Saint Kitts and Nevis, Dominica, Antigua and Barbuda, Saint Lucia), Turkey and Nauru.

The kinds of document to which the Apostille does not apply

Certain documents cannot be certified by Apostille under the Convention: documents issued by consular or diplomatic authorities, administrative documents relating directly to commercial or customs transactions, and personal documents not notarised or certified by a state body (for example personal letters, or photocopies that have not been notarised).

In addition, some member countries may object to recognising Apostilles from a particular country — creating “bilateral exceptions”. Users need to check the current position on the official HCCH website before proceeding.

Translating documents after obtaining an Apostille

The Apostille confirms only the authenticity of the original document — it does not replace the requirement to translate it into the language of the country of use. Most countries still require a certified translation into their official language (English, French, Spanish and so on).

Conclusion

The Apostille is an important step forward in simplifying international administrative formalities, particularly significant for Vietnamese people needing to use documents abroad or foreign documents in Vietnam. From 11/09/2026, instead of a 3–4 step consular legalisation process lasting 4–8 weeks, a single Apostille stamp is all that is needed for a document to be recognised in 128 other member countries.

For international investors and those seeking residence or citizenship by investment, studying abroad, marrying a foreign national or working internationally, the Apostille opens a new era with faster processing, lower costs and greater confidence. This is an important step in international integration, reflecting Vietnam’s commitment to building a transparent and convenient legal environment for its citizens and for global investors.