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· Documents№ 181·MMXXVI

Apostille and Criminal Record Certificates by Country

Why people from different countries order apostille and KRK from us: typical scenarios by country, how we do it remotely, and what makes legalisation hard.

When you look at what people come to us with most often, two documents stay near the top of the list - the apostille and the certificate of no criminal record (zaświadczenie o niekaralności, an extract from the KRK). And the people who bring them are of very different origins: Ukrainians, Belarusians, Turkish citizens, Russians, sometimes Americans and EU citizens. The reason is simple - both documents are almost always needed not "here and now in Poland" but to cross a border: so a Polish document is accepted abroad, or a foreign one works in Poland. And cross-border legalisation is exactly where weeks can be lost for no good reason.

Why these two documents in particular - the short answer

The apostille and the KRK are the most "border-facing" documents. They are rarely made for an internal Polish procedure and almost always to cross a jurisdiction: emigration, a visa, work abroad, a marriage in another country, permanent residence in Poland with documents from one's homeland. Here different bodies, different validity terms and the rigid "apostille first, translation second" order all meet. That is why people from the most varied countries come to us - their task is the same.

Typical scenarios - by country

Over the years a recognisable picture forms. Below are generalised, anonymised scenarios - no real names, only the essence.

Where the client is fromWhat is neededWhere to
UkrainePolish KRK + apostillePR in Canada, express entry
Turkeyapostille on a marriage certificaterecognition of the marriage in Turkey
Belarushome-country certificate + apostillekarta stałego pobytu in Poland
USA (expat in Poland)Polish KRK + apostillework permit in the UAE
Russiaapostille on a diploma and KRKwork and immigration abroad
Georgia / Kazakhstanhome-country certificate + translationa permanent-residence package
EU citizenUSC odpis + multilingual forma procedure in another EU country

A pattern is visible: some carry Polish documents abroad, others carry documents from home into Poland. The legalisation mechanics are similar in both cases, but the direction and the set of bodies differ.

What makes cross-border legalisation hard

At first glance the apostille looks like "one stamp". In practice there are several pitfalls, and they are exactly why people come for help.

  • The apostille is affixed by the issuing country. The Polish MSZ will not legalise a Ukrainian or Kazakh document - its apostille is affixed at home. And vice versa.
  • Different bodies within Poland. On the KRK and on USC certificates the apostille is affixed by the MSZ, on a diploma by NAWA, on a school certificate by the kuratorium. Going to the "wrong" one means losing a day.
  • The EU exception. Within the Union, under Regulation 2016/1191, the apostille is often unnecessary - but not everyone knows that and they pay for nothing.
  • The order of steps. The apostille comes before the translation, otherwise the stamp text is left untranslated.
  • Validity windows. The KRK and many certificates "live" for 3-6 months. Drag your feet and the document ages by the time of filing.

Each point on its own is not hard. The problem is that in a real case they come together, across several countries, and against a deadline.

How we do it remotely

Most clients do not need to be present in person. We work on a power of attorney (a pełnomocnictwo, drawn up before a consul where needed), and that closes almost the whole process remotely:

  1. We clarify the purpose and the destination country - it decides whether an apostille is needed at all and which body affixes it.
  2. We obtain a fresh document - the KRK via e-KRK or on paper, an odpis from the USC, a home-country certificate through a consulate or partner.
  3. We affix the apostille at the right body and do the sworn translation in the right order.
  4. We hand over the finished package - in Poland or sent to the country where it is needed.

For the client this is usually one conversation and a power of attorney, not a series of visits to different offices and countries.

A few anonymised stories

Case A., Ukraine. Preparing to immigrate to Canada, he needed a Polish KRK with apostille and translation. We made a fresh certificate, affixed the apostille at the MSZ and translated it - in the right order, with no re-translation of the stamp. We fit inside the validity window for filing.

Case G., Turkey. Married in Poland, he needed the document to have the marriage recognised at home. We apostilled the marriage certificate at the MSZ (not at the wojewoda - a common misconception), then a sworn translation. One package, no trips between offices.

Case N., Belarus. Filing for the karta stałego pobytu, the wojewoda demanded a certificate of no criminal record from the country of origin with an apostille. We launched the home-country certificate first (the longest element), assembled the Polish part in parallel, and aligned the freshness of both certificates to the filing date.

Names and details are changed - but the logic in every case is the same: the right body, the right order, the right timing.

When you can realistically manage on your own, and when to delegate

Honestly: one simple document to one country, many people arrange themselves. If you have a profil zaufany, the destination is within the EU, or the procedure is transparent - go ahead, that is a normal path.

It is worth delegating when the task stops being "one stamp":

  • several documents for one package (immigration, a family visa);
  • documents from a country where cooperation is difficult (Russia in 2024-2026);
  • a hard deadline where you cannot get the body or the order wrong;
  • you need to align the validity of the certificate, the apostille and the translation;
  • you are abroad and personal visits to Polish offices are impossible.

In these cases the time saved and the absence of redos usually outweigh the fee.

In short

The apostille and the certificate of no criminal record are documents where clients from the most varied countries converge, because both tasks are essentially about crossing a border. Technically everything is solvable, but the details - which body, what order, what timing - decide whether the document passes the first time or comes back. We are precisely about making it pass the first time.

At LegalWin the apostille and legalisation and certificate of no criminal record (KRK) services close both tasks - for Polish documents going abroad and for documents from home coming into Poland.

Get a consultation on apostille and certificates →


This article is an overview. The exact legalisation order depends on the destination country and your situation. For an individual case, consult a lawyer.

Related materials:

/ questions

Frequently asked

  • 01

    Why do people from different countries order exactly the apostille and the KRK?

    Both documents are almost always needed to cross a border: emigration, a visa, work abroad, a marriage in another country, permanent residence in Poland with documents from home. They are the most border-facing documents, so clients from the CIS, Turkey, the EU and the USA come to us with essentially one task.

  • 02

    Can the apostille and certificate be arranged remotely?

    Yes. We work on a power of attorney (a pełnomocnictwo, before a consul where needed), and almost the whole process runs remotely: we obtain the document, affix the apostille at the right body, do the sworn translation and hand over the finished package. Personal visits to offices are usually not needed.

  • 03

    What most often goes wrong in document legalisation?

    The wrong body (MSZ for the KRK and USC certificates, NAWA for a diploma), translation done before the apostille, the apostille ordered in the wrong country, or the document expiring by filing time. Within the EU people often pay for an unnecessary apostille that Regulation 2016/1191 makes redundant.

  • 04

    Which countries most often need these documents?

    The Polish KRK with an apostille - for the USA, Canada, the UK, the UAE, Australia. USC certificates - for marriage and immigration abroad. Home-country certificates with an apostille - the other way round, for Polish procedures like the karta stałego pobytu.

  • 05

    When is it worth delegating, and when can you manage yourself?

    One simple document to one country, especially within the EU, many do themselves. It is worth delegating when there are several documents, the country is difficult (Russia in 2024-2026), a deadline is tight, or you must align the validity of the certificate, apostille and translation.