You need to close a property deal in Ukraine, sell a flat in Kazakhstan, or sign documents before a notary in another country, but you cannot be there in person. The answer is a power of attorney (pełnomocnictwo) drawn up before a Polish notary. For that power of attorney to work abroad, though, the notary's signature is not enough on its own: the document has to be apostilled. And this is where the confusion starts, because the apostille on a notarial document is not stamped straight at MSZ (Ministry of Foreign Affairs) - it passes through two authorities.
Below we break the chain down step by step: why a notarial power of attorney goes to the sąd okręgowy (regional court) first and only then to MSZ, what it costs and how long it takes, and the mistakes on which our clients from the former USSR lose weeks right before a deal.
How a notarial document gets apostilled - the short answer
An apostille on a Polish notarial document (a power of attorney, an akt notarialny, or a certified copy) is issued in two stages. First the notary's signature is certified by the prezes sądu okręgowego (the president of the regional court) to which the notary is assigned. Then the document goes to MSZ, where the apostille is stamped. The opłata skarbowa (stamp duty) for the apostille is 60 PLN per document.
This is the fundamental difference from, say, USC civil registry records, which MSZ apostilles directly. Notarial documents need an intermediate link - the court. You cannot skip it: MSZ simply will not accept a document without the court's certification.
Why a notarial power of attorney goes to court first
An apostille confirms the authenticity of a signature and the authority of the person who signed. The logic is the same as with diplomas: the apostille is issued by the body that holds the signatories' specimen signatures.
MSZ does not keep a register of every Polish notary's signature - there are thousands of them across the country. Each notary, however, is supervised by a specific sąd okręgowy on a territorial basis. The president of that court holds the notary's specimen signature and confirms that yes, the document was signed by a practising notary whose signature is genuine.
After the court's certification the document carries a court official's signature, and the court's authority is something MSZ can confirm - it does hold that register. So the chain looks like this:
- The notary draws up the power of attorney or certifies the document.
- The prezes sądu okręgowego certifies the notary's signature (this is domestic legalisation).
- MSZ stamps the apostille - the final mark for use abroad.
The middle step cannot be skipped: without the court's certification, MSZ has no way of knowing whose signature it is confirming.
The full chain, step by step
Step 1. Drawing up the document before a notary
The power of attorney or other document is drawn up before a Polish notary. Build everything the foreign side will need into the text from the outset: the precise powers granted, the details of the object (for example the property address and its register number), and the validity period. Get the scope of powers wrong at this stage and you will have to redo the whole document from scratch and run the entire chain again.
Step 2. Certification at the sąd okręgowy
The document is filed with the regional court to which the notary is assigned. The prezes sądu okręgowego (or an authorised court official) certifies the notary's signature. You can file in person, through a representative or by post. A separate fee applies here for certifying the notary's signature.
Step 3. Apostille at MSZ
The court-certified document goes to MSZ (Dział Legalizacji, ul. Krucza 38/42, Warsaw). The filing options are standard: in person by appointment, through a representative, or by post. MSZ stamps the apostille onto the paper document with a wet seal and signature. Poland has no full e-apostille in 2026.
Step 4. Sworn translation (if needed)
If the power of attorney is going to a non-Polish-speaking country, a sworn translator (tłumacz przysięgły) translates it after the apostille. The order is the same as with diplomas: apostille first, then translation together with the stamp. More on this in our article on apostille, nostrification and sworn translations.
Timelines and cost
| Stage | Authority | Cost | Timeline |
|---|---|---|---|
| Drawing up the power of attorney | Notary | Notary's tariff (taksa notarialna) | Same day |
| Certifying the notary's signature | Prezes sądu okręgowego | Certification fee | A few days to 1-2 weeks |
| Apostille | MSZ | 60 PLN per document | From same day to 1-3 weeks |
| Sworn translation | Tłumacz przysięgły | By number of pages | 1-5 days |
Realistically, budget 2-4 weeks for the full chain ahead of a deal if you do it sequentially and use postal delivery. When a date with a foreign notary is fixed, start this chain early rather than three days before signing.
Why you need an apostille on a power of attorney - typical cases
Property deals abroad. The most common request. Selling or buying a flat, house or plot in your country of origin without leaving Poland. A foreign notary will only accept the power of attorney with an apostille.
Representation before courts and authorities. Running a case, collecting documents, filing applications on your behalf in another country through a representative acting under an apostilled power of attorney.
Banking and inheritance matters. Managing an account, settling an inheritance, obtaining certificates in a country you cannot travel to in person.
Corporate documents. Apostille on notarised founding documents, minutes, and powers of attorney for registering or supporting a business abroad.
Consents and declarations. A notarial consent for a child to travel, a renunciation of inheritance, various zgody (consents) - when they have to be presented in a Hague Convention country.
In all of these, a document without an apostille has no legal force abroad - it simply will not be accepted.
Common mistakes
- Going straight to MSZ with a power of attorney from the notary. Without certification by the prezes sądu okręgowego, the ministry will not apostille it. Court first, then MSZ.
- The wrong scope of powers. If the power of attorney lacks a specific power (for example the right to sign that particular contract), a foreign notary will reject the document and you will have to run the whole chain again.
- The wrong sąd okręgowy. Certification is done by the court to which your notary is territorially assigned, not just the nearest one.
- Translating before the apostille. As with diplomas, the correct order is apostille first, then sworn translation together with the stamp.
- Too short a validity period. If the deal drags on and the power of attorney expires, you will have to draw it up and apostille it again.
- Ignoring the receiving side's requirements. Some countries want the apostille on the original, others on a notarised copy. Confirm before you start.
A typical story among our clients, initials R.M.: he had a power of attorney drawn up to sell a flat in Ukraine, went straight to MSZ, was refused, lost a week, and the deal fell through on timing. All because of the skipped court step.
Apostille on a power of attorney versus other apostilles
It helps to understand that the apostille procedure depends on the type of document. Notarial documents run through the court. Education documents go through NAWA or a kuratorium. Birth and marriage certificates from the USC, on the other hand, are apostilled by MSZ directly, with no intermediate step - we wrote about this in our piece on the apostille of USC certificates. For the general mechanics of the apostille in Poland - what it is, when you need it and when you do not - see our foundational article on apostille in Poland.
How we handle this end to end
We close the whole chain: we help word the power of attorney before the notary so it will be accepted abroad, then arrange certification at the sąd okręgowy, the apostille at MSZ, and the sworn translation. You do not have to shuttle between notary, court and ministry yourself, or work out which court is "yours." We act by power of attorney, move the document through in sequence, and watch the deadlines - especially when everything hinges on a specific deal date abroad.
We support drawing up the power of attorney with a notary as part of our notary assistance service, and pick up the apostille from there.
An apostille on a power of attorney looks like a formality until a deal collapses over a skipped court step or powers that were worded wrong. We move the document through the whole chain, from the notary to a finished, apostilled and translated set. If you need to draw up and apostille a power of attorney or another notarial document, arrange a full-service apostille with LegalWin.
This is general information and does not replace individual legal advice. The requirements of foreign notaries and authorities differ, so it is best to agree the details for your deal in advance.