Apostilles, notarizations and certified copies

German law separates two acts that American practice tends to run together. Certifying a signature confirms that you signed in front of the officer. A notarization means the officer also explains the legal effect of what you are signing, and takes responsibility for the content.

Who issues an apostille

For a US public document, the apostille comes from the Secretary of State of the state that issued it. A birth certificate from Ohio is apostilled in Ohio.

For a German federal document, it comes from the Federal Office of Administration in Brandenburg an der Havel. For documents from a German state, from that state's own designated authority, and those differ from one Land to the next.

No German mission anywhere in the United States issues apostilles. If a form tells you to get one from the consulate, the form is wrong.

Signature certification, and what it is enough for

A certified signature is enough for a great many things: consenting to a contract signed on your behalf, a simple revocable power of attorney, entries in the trade register, requesting a certificate of conduct, and renouncing an inheritance.

It is not enough for an irrevocable power of attorney or a general one. Those need a full notarization, and German missions in the United States do not perform full notarizations.

Signatures relating to bank accounts are certified only in exceptional cases, and the mission will tell you whether yours qualifies.

Certified copies

Missions can certify that a photocopy matches an original document, which is what German offices usually want rather than the original itself.

Bring the original. A copy of a copy is not certifiable.

This is the service most worth combining with another appointment, because it is quick and the travel is the expensive part.

Where each stamp comes from

Which case applies to you