Which is the right process for me?
The process depends on the legal system adopted in the country where the translation is needed. There are two main systems regulating certified translations in Europe.
The Civil Law Legal System
Countries following the Civil Law legal system for instance: France, Italy, Germany, Denmark, Greece, Spain, Poland, Bulgaria, Czech Republic etc.
The civil law system has specific rules for each country that we’ll explain later.
The Common Law Legal System
Countries following the Common Law legal system (Ireland, England).
There are 4 types of translation to choose from under common law that we will explain to you in detail:
- Certified translation
- Sworn certified translation
- Notarized translation (Notarization)
- Apostilled or legalized translation
How it works in different countries
Civil Law Countries
In these countries only official sworn translators or translation agencies working with sworn translators can certify translations. Each country has precise legislation regulating the criteria to become a sworn translator. Only sworn translators can issue certified translations. In most cases they have to pass an official national state exam, be registered at the national Ministry of Justice, or be registered at a Courts of Justice to be sworn translators.
You can recognize sworn translators by their job titles. Examples: Traducteur assermenté/traducteur expert judiciaire (France)/traduttore giurato (Italy) / intérprete Jurado (Spain), which is a sworn interpreter and translator authorised to carry out both official translations and interpretations.
Certification is Civil Law countries can take longer as the translator must stamp their documents. Often this means posting original documents to the translator to be signed.
Common law countries UK and Ireland:
Certified translation is an unregulated profession in common law countries so can be is easier and faster.
A certified translation in the UK and Ireland is the translation of a document or certificate (such as birth, marriage, divorce, degree certificate / diploma), which is required for official use. It is translated by an accredited translation professional or by a translation agency collaborating with an accredited translator who attests that the translation is complete and accurate and signs and stamps the translation.
The main difference with the Civil Law countries is that in Common Law countries, there is not an official way or process regulating the status of a certified translator. The certified translator can be for instance a professional having a diploma of the English Chartered Institute of Linguists, or just a professional linguist registered at the ITIA (Irish Translators’ and Interpreters’ Association) in Ireland.
However, they must be able to show they’re a native speaker of the target language having a deep knowledge of the source language and have studied translation. In this case the process of certification involves a declaration of accuracy including the name of the translator which is attached to the stamped certified translation and a copy of the original document (the original document or certified true copy of the original document is also stamped and attached). A translation agency can also sign and seal / stamp the translation on behalf of the translator who carried out the translation.
We will sign and stamp your certified translation on the behalf of the translator, because we have previously and accurately verified the relevant linguistic skills and academic qualifications of all its linguist professionals.
Four Levels of Certification
Translation Certification usually has four levels of certification, depending on how it will be used and to whom it will be submitted:
- Certified by the translation professional or the translation agency acting on their behalf
- Sworn in front of a person of legal standing (usually a solicitor)
- Notarized (by a notary public)
- Legalized (apostilled) at the Foreign and Commonwealth Office (FCO ) in UK or at the Department of Foreign Affairs in Ireland
Before submitting your certified translation request to STAR-TS you should check with the organisation you are submitting the translation to for the level of certification required. You should give this information to STAR-TS.
The cost of your translation will depend on the level of certification required because for some levels of certification STAR-TS will work in collaboration with a solicitor or a notary public to deliver this. Based on the information you give us we will give you a quote before starting your translation.
1. Certified Translation — Common Law Countries
This type of translation certification is usually required for documents from a foreign language to be translated into English for submission to official UK or Irish organisations such as the UK Border Agency (Home Office), Passport Office, Motor Office, Universities, General Register Office etc.
The translator will attach a copy of the original document to the certified translation. In some cases when the translation is presented to the destination office, you may be asked to submit the original document along with the certified translation. A “Certification Letter” including the details of the translator’s or STAR-TS credentials verifying that it is an accurate and complete translation of the original document, has to be attached to the certified translation. This certification letter is also dated and is signed.
2. Sworn Certified Translation – Common Law Countries
This type of translation certification is usually required for official documents issued in the UK/Ireland or some other countries to be translated into a foreign language for submission abroad or for submission to the Courts of Law. Some government agencies require a more official level of accuracy and some consulates. The original document is usually required for a sworn certification of translation along with its translation. A certified true copy of original document* that will be Sworn Certified in front of a solicitor will be accepted as well. In some cases attached is as a Sworn Affidavit Translation Declaration including the translation professional or STAR-TS credentials swearing on oath that it is an accurate translation of the original document. This Sworn Affidavit Translation Declaration is also dated and includes the signature of the professional translator or STAR-TS Director and it is signed and stamped by the Solicitor.
*A Certified True Copy of Original Document means that the Original Document is photocopied, signed & stamped as a True Copy by a Legal person (usually a Solicitor or Notary Public). You can get a Certified True Copy yourself done at any solicitor, or STAR-TS Director can do it for you as part of the Sworn Certification Translation process. Certified True Copies are not applicable to UK Crown Copyright certificates such as General Register Office (GRO) Birth, Marriage, No Impediment to Marry, Death certificates, etc. STAR-TS can only stamp originals or extracts of originals issued by the GRO. You can request extracts direct from the GRO website.
3. Notarized Translation (Notarization) – Common Law Countries
This type of translation certification is usually required for official documents issued in the UK, Ireland or in some other countries to be used in a higher official capacity such as power of attorney; passport for employment abroad; academic qualifications; declaration of single status for marriage abroad; documents for buying property abroad; any other transaction abroad involving commercial activity or for High Court proceedings and some consulates. The original document is usually required for a notarized translation because it is the translation and the original document that will be signed, stamped and sealed in front of a Notary Public. Also attached to this notarized translation is a notarized translation declaration including the details of the translation professional credentials swearing on oath that it is an accurate translation of the original document, or the STAR-TS details acting on the behalf of the translator. This Notarized Translation Declaration is also dated and includes the signature of the professional translator, or STAR-TS director, and it is signed and stamped by the Notary Public.
Usually, when a Notarized Translation is required, the Original document also needs to be Notarized. In either case, you will need to supply STAR-TS or the translator with the original document to have it notarized at the same time as the Translation Notarization stage.
4. Apostilled or Legalized Translation – Common Law Countries
Once the translation has been notarized, the Department of Foreign affairs in Ireland, or the Foreign and Commonwealth Office (FCO ) in UK can Apostille your Notarized translation if required from the organization you will submit the certified translation.