The China Apostille for business documents, explained (post-2023 rules)
Since November 2023, most Chinese company documents used abroad — and most foreign company documents used in China — no longer need embassy legalisation. Here's what actually changed, and what still trips companies up.
Direct answer: Since 7 November 2023, China is a party to the Hague Apostille Convention. A public document from one member state, used in another, now needs a single Apostille from the issuing country’s competent authority instead of consular legalisation. In China, that authority is the Ministry of Foreign Affairs (MFA) or an authorised local Foreign Affairs Office (FAO).
We do not assist with visa, residence permit, work permit, immigration or emigration applications, in China or in any other country. This guide, and the service behind it, cover documents used for commercial and qualification purposes only.
What changed in November 2023
For decades, using a Chinese company document abroad meant a chain: notarisation, then authentication by the Ministry of Foreign Affairs or a local Foreign Affairs Office, then a final legalisation stamp from the destination country’s embassy or consulate in China. It was slow, and you were at the mercy of one more counter at the end — usually while a registry or a bank on the other side held your application open.
China deposited its accession to the Convention Abolishing the Requirement of Legalisation for Foreign Public Documents and it entered into force for the mainland on 7 November 2023. Between member states, that final embassy step disappears. One Apostille certificate now does the whole job.
Which business documents actually need it
In practice, the Apostille question arrives with one of a handful of documents. The trigger is always the same: an institution on the other side of a border has to be able to trust a stamp it has never seen before.
| Situation | Documents typically required |
|---|---|
| A Chinese company registering a subsidiary or branch overseas | Business licence, articles of association, shareholder register, board resolution, director identification |
| Opening a corporate bank account overseas | Business licence, certificate of good standing, proof of beneficial ownership, signature specimens |
| Bidding for an overseas tender | Business licence, qualification and ISO certificates, audited financials, power of attorney |
| A foreign company registering an entity in China | Certificate of incorporation, constitution, register of directors and members, directors’ resolution — apostilled at home, then translated into Chinese |
| Employment or academic use of a qualification | Degree, transcript, professional qualification certificate |
Who issues an Apostille in China
The Ministry of Foreign Affairs is China’s competent authority for the Apostille. It has also authorised the Foreign Affairs Offices of a number of provincial and municipal governments to issue Apostilles for public documents produced within their own areas. A document issued in Zhejiang is apostilled through the provincial Foreign Affairs Office rather than sent to Beijing.
The Apostille only certifies the origin of the document — the signature, the capacity of the signatory, and the seal. It does not vouch for the content. The destination authority still decides whether to accept it, and can still impose its own requirements on age, translation and format.
Why you still visit a notary first
This is the step most people miss. The Convention covers public documents. Many of the things a company actually needs apostilled — a board resolution, a power of attorney, a signature specimen, a copy of a licence or a degree — start life as private documents. To bring them into scope, a Chinese public notary office (公证处) notarises them into a notarial certificate first. The Apostille is then added to that.
So the modern flow is usually two steps, not three: notarise → apostille. Where a document has to be signed by a named individual — a declaration, a power of attorney — Chinese rules require that person to appear at the notary in person. That part predates the Convention and hasn’t changed.
When you still need full legalisation
The Apostille route only works between Convention members. If your document is going to a country that isn’t a party, you’re still on the traditional path: notarisation, MFA/FAO authentication, then that country’s embassy legalisation. There are also rare cases where a specific member state has objected to China’s accession for bilateral purposes — worth checking for unusual destinations before you build a timeline around it.
| Destination | Route |
|---|---|
| Convention member (Australia, New Zealand, UK, US, most of the EU, Japan, and 120+ others) | Notarise (if needed) → Apostille. Done. |
| Non-member country | Notarise → MFA/FAO authentication → destination embassy legalisation. |
It works both directions
The same logic applies to a foreign document you need to use in China — say a certificate of incorporation and a directors’ resolution for registering a WFOE. Instead of getting them legalised at a Chinese embassy in the home country, you now get an Apostille from that country’s own competent authority and they are recognised in China, subject to certified Chinese translation. That single change removes a whole step, and often two to three weeks, from a China registration timeline.
Quick FAQ
Does an Apostille expire?
The Apostille itself doesn’t carry an expiry, but the underlying document might. Registries and banks routinely refuse a certificate of good standing or a company extract older than three or six months, so sequence the work close to when you need it.
Can you apostille a plain photocopy?
Generally no — it needs to be a public document or a notarised copy. That’s exactly why the notary step comes first for most company papers.
Does the translation get apostilled too?
It depends on the destination. Some authorities want the translation attached to the notarial certificate before the Apostille is applied; others accept a separate certified translation. Confirm this before you order, because doing it in the wrong order means doing it twice.
Is Hong Kong or Macau different?
Both were already covered by the Convention before the mainland joined, through separate long-standing arrangements. This guide is about mainland China.
Need this done, not just understood?
We assemble the document set, arrange notarisation, handle the Apostille and provide the certified translation — for company papers going out of China or coming in. Tell us the destination and the purpose and we’ll confirm the exact route.
Sources
- Ministry of Foreign Affairs — Convention enters into force for China on 7 November 2023
- Notarial Procedure Rules — matters requiring personal appearance
This guide is general information, not legal advice. Requirements vary by city, document and personal circumstances — confirm your specific case before acting. Last checked 6 August 2026.
