When a translation needs to be presented to a government authority or is needed in the context of an official or administrative procedure, there will usually be a requirement to present a certified translation.
The concept of ‘certified translation’ often causes confusion, as there are different ways in which a translation can be certified. There are also different terms used for the various ways to certify a translation, such as ‘official translation’, ‘sworn translation’ or ‘notarised translation’, although these are not always used consistently.
The term ‘certified’ is very general and can mean different things to different authorities. For that reason, it is always a good idea to seek confirmation of the type of certification required for a particular translation. Even though some authorities have their own specific requirements, the country where the translation will be used tends to be the main factor determining the type or level of certification required for the translation.
In the United Kingdom, public authorities and other institutions (e.g. universities) are often satisfied with a declaration signed by the translator, confirming his or her qualifications and the fact that, to the best of the translator’s ability, the English text is a true translation of the foreign language document. Although there isn’t such thing as an ‘official translator’ in the UK, it is often advisable to use a translator who is a member of one of the professional institutes (namely, the Chartered Institute of Linguists and the Institute of Translation and Interpreting). Some institutions specifically request that the translator who signs the translator’s certificate belongs to one of these institutes, while other institutions will accept the certification of a translator with other relevant qualifications (e.g. a translator registered as an official translator in another country). Remember, though, that these professional translation institutes are private associations, not government bodies.
Other countries have a system whereby the government appoints official translators. In those countries, when a translation is to be used for official purposes it normally needs to be certified by one of the translators who have been officially appointed by the relevant government body of that country. Different countries use different expressions to refer to government-appointed translators. ‘Sworn translators’ and ‘public translators’ are two of the names these translators receive in various countries who use this system. In Spain, for instance, the Ministry of Foreign Affairs appoints sworn translators, who are only authorised to certify translations in a specific language combination and who have a seal that they must affix to their translations. When an authority in Spain requests a ‘certified translation’, an ‘official translation’ or a ‘sworn translation’, the expectation is normally that the translation has been certified by a translator who is listed in the official list of sworn translators.
Confusion with the terminology often arises when a translation is prepared in the UK but is to be presented to authorities in a different country. In those cases, when a ‘certified translation’ is requested, a simple certificate from the translator may not be sufficient. The foreign authorities will normally expect a translation to be certified by either a sworn translator (when they exist in that country) or by a notary public. A notary can certify a translation in two main ways. If the notary has sufficient knowledge of the language(s) involved, the notary can certify directly the accuracy of the translation. If the notary does not master the relevant language(s), then the translator who carried out the translation is usually asked to sign a translator’s declaration and the notary certifies the signature of the translator.
Additional steps are required in some cases. A certificate from an English notary public often needs to be legalised by the Foreign Office before it can be used abroad and, for some countries, a consular legalisation may also be required. In practice, this means the notarised translation would need to be sent or taken to the Foreign Office first and, when required, to the relevant consulate. Notaries are often able to arrange these steps for you.
A few consulates have their own system for the certification or legalisation of translations. For instance, although consular legalisation of original documents is not usually required for the Dominican Republic, translations undertaken in the UK need to be submitted to the Dominican embassy in London before they can be used for official purposes in the Dominican Republic.
These are a couple of examples of typical situations in which certified translations could be required:
– To study at a UK university, you may need to submit certified translations of your previous qualifications if these were issued abroad in another language. Usually, a UK university will accept a translation certified by a professional translator who has relevant qualifications.
– To get married abroad, you may need to have some documents translated into the language of the country where the wedding will take place. For example, a divorced Englishman getting married in Cuba will need his birth certificate and divorce decree translated into Spanish, and the translations will need to be notarised and submitted to the Foreign Office and to the Cuban Consulate together with the original documents.
– To register a branch of a UK company in another country, the local notary or commercial registry may request certified translations of documents such as the certificate of incorporation or the articles of association of the company into the local language. Italy and Germany are both countries that often require this. Translations organised in the UK for these purpose tend to require the certification of a notary and the legalisation at the Foreign Office.
– Certified translation: A translation that requires some type of certification. This could include a translation certified by a professional translator, by a sworn translator or by a notary. If in doubt, it is advisable to contact the requesting party to confirm the type of certification required.
– Professional translation: A translation carried out by a professional translator. In principle, this only means that the translation should be of a professional quality, as opposed to an amateur translation. However, when an authority requests a ‘professional translation’ the expectation often is that the translation should be certified by the translator.
– Official translation: A translation that is acceptable for official purposes. This usually means that the translation must be carried out by a sworn translator, in countries where these exist, or must otherwise be certified in a way acceptable in the country of destination (e.g. certified by a notary in the case of many countries).
– Sworn translation: A translation certified by a sworn translator, i.e. a translator appointed by a government authority in a country that has a system of officially appointed translators.
– Public translation: An alternative name for ‘sworn translation’ in certain countries (e.g. Argentina).
– Notarised translation: A translation certified by a notary public.
– Apostilled translation: A translation that, after being notarised, needs to be sent to the Foreign Office, who attach the ‘Hague apostille’ confirming the notary’s signature and seal.
– Legalised translation: A translation that, normally after having been notarised, is sent to the Foreign Office and/or to the relevant consulate in order to be apostilled and/or stamped so that it is acceptable in a particular country.
– Legal translation: A translation of a text of a legal nature (e.g. contracts, legislation, court documents, etc.). This expression only indicates that the translation is a specialised translation of a legal text. It may or may not be certified.