Half the apostille orders that reach us do not need an apostille at all. Either the document is heading to a country that does not recognise apostilles - in which case full consular legalisation applies - or the opposite: a bilateral treaty between Poland and the destination country means the document is accepted with no certification whatsoever.
The difference in money and time is real. An apostille at the MSZ (Polish Ministry of Foreign Affairs) costs PLN 60 per document and takes a day or two. Consular legalisation runs through two institutions, costs PLN 26 at the MSZ plus a consular fee, and takes at least a week. Here is how to identify your scenario in five minutes.
Three scenarios, not two
| Scenario | What to do | MSZ fee | Timeline |
|---|---|---|---|
| Country is party to the 1961 Hague Convention | Apostille | PLN 60 per document | 1-3 working days |
| Country outside the Convention | MSZ certification + embassy legalisation | PLN 26 + consular fee | 5-15 working days |
| A bilateral legal assistance treaty applies | Usually nothing but a sworn translation | PLN 0 | 0 days |
The third scenario is the one nobody writes about, and it is the one that saves clients the most.
When no apostille is needed at all
Poland is bound by bilateral legal assistance treaties with a number of countries, and those treaties exempt official documents from any legalisation. The ones that matter in practice for our clients:
- Ukraine - treaty of 24 May 1993 (Journal of Laws 1994 no. 96 item 465). Article 15 expressly exempts documents from legalisation.
- Belarus - 1994 treaty, equivalent provision.
- Russia - 1996 treaty, equivalent provision.
The practical consequence: a Ukrainian birth certificate, marriage certificate, divorce judgment or civil registry certificate submitted to a Polish USC (civil registry office) - for transcription, for a wedding, or for a residence case - needs no apostille. A sworn translation into Polish is enough.
The honest caveat: not every office remembers this. Some universities, some notaries and individual registry clerks still ask for an apostille out of habit. The point is settled with a letter citing the article and the Journal of Laws reference, but allow a couple of extra days for it.
Diplomas are harder. Recognition of education (nostryfikacja) is governed separately, and universities may set their own document requirements. We cover that route separately.
Who is in the Hague Convention and who is not
The list of parties keeps growing, and it has shifted noticeably in recent years:
- China acceded in November 2023 - consular legalisation of Chinese documents is no longer required.
- Canada - since January 2024.
- Saudi Arabia - since December 2022.
- Pakistan - since March 2023.
- Indonesia - since 2022; the Philippines - since 2019.
Still outside the Convention as of 2026, and appearing regularly in our cases: UAE, Vietnam, Iraq, Jordan, Libya, Egypt, Algeria, Lebanon, Cuba, Thailand, Malaysia, Myanmar, Taiwan.
One rule worth keeping: the list changes several times a year. Always check the current status on the Hague Conference on Private International Law website before filing - we verify it in every case.
How consular legalisation works
If the country sits outside the Convention, the chain is longer and cannot be shortened:
- Prepare the document. An original with signature and seal. Notarial documents and copies first need certification at the Sąd Okręgowy (regional court).
- MSZ certification. Legalisation Department, ul. Krucza 38/42 in Warsaw. Fee PLN 26 per document - not the PLN 60 charged for an apostille.
- Legalisation at the destination country's embassy. Every mission sets its own rules, timelines and tariff. Some require translation into the official language, others only into English.
- Translation. Sworn or consular, depending on what the receiving side demands.
The most common mistake on this route is translating too early. Many embassies require the translation to follow MSZ certification and to be bound to the already certified original. A translation done "in advance" has to be redone.
The apostille in Poland: who certifies what
The competent authority is the MSZ Legalisation Department. In-person filing at ul. Krucza 38/42 in Warsaw by appointment; postal filing to al. Szucha 23. The fee is PLN 60 per document, paid to the Śródmieście District Office account.
What matters in 2026: the MSZ still works with paper originals only. A printout of an electronic document (e-KRK, a KRS printout, an ePUAP document) is not accepted directly - it must first be notarised and the notary's signature authenticated by the regional court, or a paper original obtained from the issuing body. We cover that trap in our piece on electronic documents and the apostille.
Some documents need prior certification, and some bypass the MSZ entirely:
| Document type | Where it goes before or instead of the MSZ |
|---|---|
| Civil registry certificates (birth, marriage, death) | MSZ directly |
| Notarial deeds, powers of attorney | Sąd Okręgowy (regional court) |
| University diplomas | NAWA - issues the apostille itself |
| School certificates | Kuratorium Oświaty (education authority), matura certificate - OKE; both issue the apostille themselves |
| Criminal record certificate (KRK) | MSZ directly |
| KRS and CEIDG extracts | MSZ directly |
Identifying your scenario in five minutes
Three questions, in order:
- Which country is the document going to? Not where it came from - where it lands. The apostille is issued by the country of origin, but the requirement is set by the destination.
- Is there a bilateral legal assistance treaty between Poland and that country? If yes, most likely nothing is needed.
- If not, is the country in the Hague Convention? Yes - apostille. No - consular legalisation.
And a fourth question that saves money: how many copies will you need? An apostille attaches to one specific copy. If the document goes to three institutions, ordering three originals and certifying all of them at once beats repeating the chain six months later.
What we do
- Route check - destination country, treaties, current Convention status. Free, in one conversation.
- Obtaining originals - from the USC, KRS, a university or the KRK where you do not hold them.
- Other authorities - regional court certification, NAWA, the kuratorium or OKE.
- MSZ - filing, payment and collection under a power of attorney.
- Embassy - for non-Convention countries we run the correspondence and filing ourselves.
- Sworn translation - at the right point in the chain, not before it.
Timelines and pricing sit on the service page. Where several documents head to different countries, we run them as one flow, which costs noticeably less than separate cases.
Frequently asked questions
How long is an apostille valid? The apostille itself does not expire. Any limit comes from the document: a criminal record certificate is usually accepted for three to six months, civil registry certificates have no expiry although receiving bodies often want a recent extract. Details here.
Can an apostille go on a copy? On a notarised copy, yes, after certification at the regional court. On a plain photocopy, no.
The embassy asks for an apostille although the country is not in the Convention. What now? It happens: some missions use "apostille" loosely to mean MSZ certification. Get the requirement in writing - the wording and the practice often diverge.
Can a foreign-issued document be apostilled in Poland? No. Only the issuing country can apostille its own document. A Ukrainian certificate is apostilled in Ukraine, a Turkish one in Turkey. We explain how to arrange this remotely in our article on apostilling foreign documents.
Do company documents need an apostille to open an account abroad? Usually yes, and it is a separate procedure covering the KRS extract and articles of association - covered separately.
The right question is not "where do I get an apostille" but "do I need one at all". In a third of our cases the answer is no, and that saves the client weeks.
Send us the list of documents and the destination country - we will map the route in one conversation and quote the exact cost before starting.
This material is informational. Receiving authorities differ in their requirements - consult a lawyer about your situation.