Chinese Notarised Declaration and Apostille Translation for UK Solicitors

A notarised Chinese declaration is not automatically an English court affidavit. For a foreign-language affidavit filed under Civil Procedure Practice Direction 32, paragraph 10.2 , the translator must make their own affidavit verifying the translation and exhibiting both versions. My ordinary signed certification is not that sworn affidavit; discuss the court’s directions and arrangements with your solicitor before ordering. I translate apostilled documents but do not issue or obtain apostilles. GOV.UK legalisation guidance distinguishes legalisation by the issuing authority from translation.

Most of these documents reach me in notarial form. A Chinese 公证书 is a bound booklet issued by a 公证处: a printed cover, the declaration or power of attorney itself, and the notary’s certificate confirming that the person appeared, that the signature is theirs, or that a copy matches an original. It carries a certificate number in the style (2025)京XX证字第XXXX号, the notary’s name and practising details, the office’s red seal, and a 骑缝章 straddling seal printed across the bound edge so that pages cannot be swapped. Some offices attach their own English version inside the same booklet. It may contain errors or lack the certification requested by the recipient, so I translate the Chinese afresh rather than tidy up someone else’s work.

In UK practice these turn up in fairly predictable places. Probate is a common one: an estate here, an heir in China whose entitlement is evidenced by a kinship certificate, and a power of attorney appointing someone in England to act. Family and immigration work is another, where a relationship or a parent’s consent to a child’s travel has to be evidenced. Conveyancing and corporate matters throw up powers of attorney for signatories who cannot attend. Banks, pension providers and insurers ask for declarations of identity or of marital status, and registrars see 单身声明 before a marriage notice. In every case the recipient is not checking your Chinese; they are checking that the English in front of them is complete and that somebody has put their name to it.

The distinctions here are easy to blur and expensive to get wrong. An affidavit sworn in England before a solicitor is a different instrument from a Chinese notarial deed, and 公证 (notarisation), 认证 (authentication or legalisation) and 声明 (declaration) are three separate things that all get loosely rendered as certification. I keep them apart in the translation, and if you are unsure which one you have been asked to produce, the difference between a certified and a notarised translation is worth reading before you order. Kinship documents bring their own trap, because Chinese kinship vocabulary is precise where English is vague: 堂兄 and 表兄 are both cousins, 叔叔, 伯伯 and 舅舅 all collapse into uncle, and in a probate or immigration file that flattening can destroy the very fact the document exists to prove. I translate the exact relationship — father’s younger brother rather than a bare uncle — and keep the Chinese term where a reader may need it. Personal names follow the passport spelling, never a fresh romanisation.

Send the complete booklet, not only the page with the wording on it: cover, Chinese original, notary’s certificate, every page carrying a seal, and the back page, which often holds the registration number even when it looks blank. Scan or photograph in colour, flat, with the edges in frame so the straddling seal is visible. Tell me who is receiving it, give me the passport spelling of every name mentioned, and flag the date you need it by. Changes after delivery are included in the price, with the source scope identified in the certification.

Translating the apostille attachment

The apostille attachment has ten numbered fields identifying the country, signatory, capacity, seal authority, place, date, issuing authority, number, seal and signature. I include its verification details and note the binding between pages, including an eyelet, ribbon or straddling seal where present. Notarial file numbers such as 〔2024〕京长安内民证字第XXXXX号 remain traceable to the Chinese. Where the booklet includes English, I compare it with the Chinese and record material differences rather than assuming it must be replaced. Ask the recipient which final document set it requires.