Certified Translation Rules by Country

"Certified translation" is not one thing. It is at least three different legal mechanisms wearing the same English phrase, and which one a given country means depends on whether that country inherited a common-law or a civil-law tradition.

In common-law countries — the United States, the United Kingdom, and to a lesser extent Canada and Australia — a translation becomes "certified" because the translator says so. A qualified person signs a statement attesting to their own competence and to the accuracy of their own work, and that self-attestation is what the receiving authority relies on. There is no government register to check, no prior licensing exam, no court appointment. The system trusts the signature and holds the signer liable if it's wrong. In civil-law countries — France, Germany, Spain, the Netherlands, and (with a variation worth noting) Italy — that trust is front-loaded instead. The state vets the translator before any translation happens: an oath before a court, an appointment by a ministry, entry in a public register. Once appointed, that translator's stamp carries legal weight on its own, and no accuracy statement is needed because the appointment already is the accuracy statement. Confusing the two models is the single most common reason a translation gets rejected — ordering a US-style self-certified translation for a French préfecture, or paying for German-style sworn formality that a UK caseworker never asked for.

This page compares nine countries on the same six questions, sourced to the primary authority for each one (linked inline). Where a rule could not be confirmed against a primary source, that's stated rather than guessed.

Comparison table

United States — USCIS

USCIS runs the purest version of the self-certification model. Under 8 CFR 103.2(b)(3), any foreign-language document submitted with a benefit request needs "a full English language translation which the translator has certified as complete and accurate," plus a statement that the translator is competent in both languages. No government appointment, no notarization, no apostille — competence is asserted and the translator is liable if it's wrong. The most common rejection trigger isn't the translator's qualifications; it's an incomplete rendering (a skipped stamp or illegible seal) or a certification statement missing one of its required elements. Full detail: certified translation for USCIS.

Canada — IRCC

IRCC's model sits between the US and the European court-appointment systems. A translator who's a certified member of a recognized translators' association can certify their own work directly. Anyone else needs a sworn affidavit — typically notarized or commissioned before someone authorized to administer oaths — attached to the translation. Family members are barred from translating for an applicant's own file regardless of qualifications. The affidavit, not the translation quality, is what applicants most often forget. Full detail: IRCC certified translation requirements.

United Kingdom — UKVI

The Immigration Rules require a translation confirming it is accurate, dated, and signed with the translator's name and contact details — a full self-certification model close to the US. Formal "qualified translator" credentials are called for only on leave-to-remain and settlement applications, not on entry-clearance ones. Notarization is not requested anywhere in the published guidance, which is why paying for it is usually wasted money for a UK filing. Full detail: certified translation for UK visas.

France — traduction assermentée

France requires a traducteur assermenté: a translator who has taken an oath before a Cour d'Appel and appears on its published list. Their stamp and registration number carry legal standing on their own; no separate accuracy letter is needed. A translation from a translator sworn in another country generally will not satisfy a French préfecture — the appointment has to trace back to a French court. Full detail: sworn translation in France.

Germany — beglaubigte/beeidigte Übersetzung

Germany's model is the clearest instance of "the state vets first." A translator sits a state (or now, post-2023, a unified federal) examination and is publicly appointed before ever producing a certified translation; every translation that translator produces afterward is presumptively valid because of that prior vetting, checkable in the public justiz-dolmetscher.de register. Notarization on top is almost always unnecessary and a translator appointed only outside Germany generally doesn't satisfy a German authority. Full detail: certified translation in Germany.

Spain — traductor/intérprete jurado

The title of traductor jurado is granted by Spain's Ministry of Foreign Affairs, European Union and Cooperation (MAEC), either by passing its exam or through recognition of an equivalent EU/EEA qualification, per the ministry's own page on Traductores/as – Intérpretes Jurados/as. A jurado's signature and seal give the translation official character on their own — no further legalization step is needed for use inside Spain. Where Spain deviates from France and Germany is on the source document: for many extranjería (immigration) procedures, the original foreign document needs a Hague apostille (or consular legalization if the origin country hasn't signed the Hague Convention) before it's translated, and if that apostille stamp itself is in a foreign language, it has to be translated too. A translation sworn by a jurado appointed by another country's authority generally has to be redone by a MAEC-listed jurado to be accepted in Spain.

Italy — traduzione giurata / asseverazione

Italy runs a third model, distinct from both the self-certification and pre-appointment approaches: there's no single national register of "sworn translators." Instead, a translator who has done the work personally appears before a tribunale's clerk (or a notary, a Giudice di Pace, or an Italian consulate abroad) and swears an oath (giuramento) that the translation matches the original, producing a verbale di giuramento attached to the source and translated text. Many tribunali additionally expect the translator to appear on the court's own technical-consultant roll, a Chamber of Commerce list, or a recognized Law 4/2013 association — but that expectation varies by court, not by national statute. Stamp duty (marca da bollo, roughly €16 per four pages) has to be applied before the oath, not after; applying it retroactively is a documented reason tribunali reject a filing. If the translation needs to be used outside Italy, the Procura della Repubblica can apostille the sworn package afterward — that step is not needed for domestic use.

Netherlands — beëdigde vertaling

A beëdigd vertaler has to be listed in the Rbtv (Register beëdigde tolken en vertalers), maintained by Bureau Wbtv on behalf of the Raad voor Rechtsbijstand under the Wbtv law, and sworn in by a Dutch court on the strength of that registration. The translator's own stamp and signed declaration are what give the translation its status — Bureau Wbtv's own page on the register confirms registration is what authorizes someone to produce certified translations in the Netherlands, and no separate notarization is layered on top. For use abroad, the translator's signature — not the translation content — can be apostilled through the court registry where they're sworn in. A translation certified under a different country's sworn-translator system generally isn't accepted by Dutch authorities without Rbtv registration.

Australia — NAATI

Australia's system is a fourth pattern: a single national accrediting body, NAATI, jointly owned by the Commonwealth and the state and territory governments, rather than a court or a ministry. NAATI's own pages confirm it is the sole certifying authority in Australia and that its "Certified Translator" credential — carrying the translator's stamp, signature, and Certified Practitioner Number — is what's required. NAATI also states plainly that as of 1 July 2018, DFAT accepts only NAATI-certified translations for the documents it handles, and the same standard is applied across Home Affairs, the Australian Passport Office, citizenship applications, and the courts.

One line in the table above couldn't be pinned to a primary source directly: multiple secondary sources describe Home Affairs accepting non-NAATI translations from applicants located outside Australia, provided the translator supplies their name, address, phone number, and qualifications on the translation itself. The relevant Home Affairs guidance page returned an access error on every fetch attempt during research for this article, so that specific claim is reported here as unverified rather than confirmed — check directly with Home Affairs or a migration agent if your documents were translated outside Australia.

Related reading

For the two concepts that come up in almost every row of the table above: apostille vs. notarized translation explains what each one actually authenticates, and certified vs. sworn translation covers the distinction this page relies on throughout.

If your document needs a translator appointed or registered in a specific country — sworn in France or Germany, jurado in Spain, Rbtv in the Netherlands — that's a sworn translation rather than a standard certified translation, and the two aren't interchangeable no matter how accurate either one is. If you're not sure which your receiving authority needs, our FAQ covers the distinction, or ask before ordering — it's a five-minute question that avoids a redone translation later.