A previous AMS article covered the distinction between certified and notarized translation. This piece extends that into the international authentication layer that surfaces when a translation is being submitted to a foreign authority. Four terms get used: certified, notarized, sworn, and apostilled. They are not interchangeable.
Certified translation
A translation accompanied by a signed Certificate of Accuracy from the translator. The translator attests that the translation is a true and complete rendering of the source. This is the U.S. standard for most domestic uses, including USCIS filings. The translator stakes their professional reputation on accuracy. No outside official is involved.
Notarized translation
A certified translation whose Certificate of Accuracy has been signed in the presence of a notary public, who attests to the identity of the signer. The notary does not verify the translation itself. They verify the person who signed the certificate. Notarization adds a credentialed identity-verification layer without adding any review of translation accuracy.
Sworn translation
Sworn translation is a credential that exists in civil-law countries (Spain, France, Germany, Italy, Argentina, Mexico, and many others), not in the United States. A sworn translator is officially appointed by a court or government agency in their country and authorized to produce translations that carry legal effect on their own, without separate certification or notarization. The U.S. has no equivalent system; the closest U.S. analog is a certified translation by a state-court-certified or federally-certified translator.
When a U.S. document is being submitted to a foreign authority that requires a "sworn translation," the practical answer is usually one of: (a) a sworn translator in the destination country translates the document, or (b) a U.S. certified translation is produced and then notarized and apostilled (or consular-legalized) for use abroad.
Apostilled translation
A notarized translation that has been authenticated by the Secretary of State of the U.S. state where the notary is commissioned, using a Hague Apostille. The apostille is a standardized international certificate that other Hague Convention countries accept without further authentication. The apostille authenticates the notary's signature, not the translation accuracy. See our separate article on the Hague Apostille for the longer explanation.
Consular legalization
For countries that are not party to the Hague Apostille Convention, the longer authentication chain applies: notarization, state authentication, U.S. Department of State authentication, and finally legalization by the destination country's consulate or embassy. Several major countries have historically required consular legalization; check the destination country's current status.
Which one your filing needs
- USCIS or U.S. immigration filing: certified translation is sufficient.
- U.S. court filing (most jurisdictions): certified translation; some require notarized.
- Foreign embassy in a Hague Convention country: typically certified plus notarized plus apostilled.
- Foreign embassy in a non-Hague country: typically certified plus notarized plus authenticated plus consular-legalized.
- Foreign government requiring a sworn translation: ask whether a U.S. certified-plus-notarized-plus-apostilled translation will be accepted, or whether they require a translator sworn in the destination country.
AMS produces certified translations and coordinates the notarization step. The apostille and consular legalization steps are handled at the relevant Secretary of State and consulates; we can advise on the sequence and connect you with reliable apostille services.