Brazil Apostille: How Documents Enter Brazil, How Brazilian Documents Leave — and the Steps the Apostille Does Not Replace
Published October 8, 2026.
A birth certificate from Ohio for a Federal Police registration in São Paulo. A divorce decree from Florida for a Brazilian registry office. A Brazilian university diploma for a job in Toronto, or a Brazilian birth certificate for a citizenship file in Lisbon. Every one of these papers crosses a border, and every search about it ends at the same word: apostille. This article explains how the Brazil apostille works in both directions — documents for Brazil and documents from Brazil — from the texts in force as I read them on October 8, 2026: the Hague Convention as promulgated in Brazil (Decree 8,660/2016), the National Council of Justice's Resolution 228/2016 in its consolidated text, the chapter on apostilles of the Council's National Code of Rules for registry offices, the chapter on sworn public translators of Law 14,195/2021, the Public Registries Law, the Hague Conference's status table, and the pages of the Brazilian consulates and of the U.S. Department of State that I checked on the same day.
Brazil apostille in one answer
Brazil has applied the Apostille Convention since August 14, 2016. A document from another Convention country is apostilled where issued, translated by a Brazilian sworn translator if not in Portuguese and, for use before public bodies and courts, registered at a Registry of Titles and Documents. Brazilian documents are apostilled at any registered Brazilian notary or registry office, wherever located.
| Your document | Who apostilles it | What comes after the apostille | Where it is written |
|---|---|---|---|
| Issued in a Convention country, for use in Brazil | The competent authority of the country where it was issued — in the United States, the Secretary of State of the issuing state, or the U.S. Department of State for federal documents | Translation by a Brazilian sworn public translator if it is not in Portuguese; registration at a Registry of Titles and Documents (RTD) to have effect before public bodies, courts and third parties | Convention, art. 3; CNJ Resolution 228/2016, art. 2; Law 14,195/2021, arts. 22 and 27; Law 6,015/1973, arts. 129(6) and 148 |
| Issued in Brazil, for use in a Convention country | Any Brazilian notary or registry office registered in the Council's apostille system, wherever it is and whichever office issued the document | Whatever the destination requires; if a Brazilian sworn translation goes too, it receives its own, second apostille | CNJ Resolution 228/2016, art. 6; National Code of Rules, arts. 4, § 1, and 15 |
| Coming from, or going to, a country outside the Convention | No apostille: consular legalization under the rules of Brazil's Ministry of Foreign Affairs | The same translation and registration steps once it is in Brazil | CNJ Resolution 228/2016, art. 5 |
| Drawn up by a Brazilian consular officer, for use in Brazil | None — it is a Brazilian act, not a foreign document (for use abroad, the Convention excludes consular documents and Resolution 228, art. 5, sends them to legalization) | Nothing for that reason; which acts each post performs is set post by post | Vienna Convention on Consular Relations, art. 5(f) (Decree 61,078/1967); Hague Convention, art. 1 |
The rest of this article is the why behind each line, and the places where the answers you find online stop one step short. The most common short stop: the apostille proves that a signature is genuine. It does not translate the document, and on its own it does not make a foreign paper effective before a Brazilian public body.
What an apostille is — and what it certifies
Before 1961, a document crossing a border needed a chain of signatures ending at the consulate of the destination country — the process called legalization. The Hague Convention of October 5, 1961, replaced that chain, between the countries that join it, with one certificate issued in the country of origin. Article 3 says so in its first paragraph:
A única formalidade que poderá ser exigida para atestar a autenticidade da assinatura, a função ou cargo exercido pelo signatário do documento e, quando cabível, a autenticidade do selo ou carimbo aposto no documento, consiste na aposição da apostila definida no Artigo 4º, emitida pela autoridade competente do Estado no qual o documento é originado.
The only formality that may be required to certify the authenticity of the signature, the capacity in which the signer of the document acted and, where appropriate, the authenticity of the seal or stamp on the document, is the affixing of the apostille defined in Article 4, issued by the competent authority of the State in which the document originates.
Three consequences follow from that text, and each one answers a question people search for. First, the apostille certifies the signature, the capacity of the signer and the seal — not the content. An apostilled birth certificate carries a genuine signature and seal; whether it is the right certificate for your file is a different question. Second, it is issued where the document originates, never where it will be used: a Brazilian office cannot apostille an American document, and an American office cannot apostille a Brazilian one. Third, the apostille is the only formality of this kind that the destination may demand — which is why, since 2016, Brazilian consulates no longer legalize documents from Convention countries, save the exceptions discussed below.
The Convention also says what a public document is, for this purpose (article 1): documents from an authority or official connected with a court or tribunal, administrative documents, notarial acts, and official certificates placed on private documents — such as reconhecimentos de assinatura, notarial certifications of signatures. That last item is how a private document, like a power of attorney signed by an individual, enters the system: a notary certifies the signature, and the apostille then certifies the notary.
The instrument. For each document, write down two facts before you do anything else: the country that issued it, and the country — and the office — that will receive it. Every rule in this article is chosen by those two facts.
Is Brazil part of the Hague Apostille Convention?
Yes. Brazil acceded to the Convention — the Hague Conference's table shows no signature for Brazil, although the Decree's heading speaks of the Convention “firmada” (signed) by Brazil — by depositing its instrument of accession with the Netherlands' Ministry of Foreign Affairs on December 2, 2015, and the Convention entered into force for Brazil on August 14, 2016. Both dates are in the recitals of Decree 8,660/2016, which promulgated it, and in the Hague Conference's status table, where Brazil appears with an "A", for accession, and entry into force on 14-VIII-2016. You will see it described elsewhere as a ratification on that date; the Decree and the Hague Conference record an accession deposited on December 2, 2015, and August 14, 2016 is the entry into force.
On the receiving side, the National Council of Justice — Brazil's instrument of accession named the Judiciary as the body competent to implement the Convention, and the Council regulates it — wrote the rule that every Brazilian office applies:
Art. 2º As apostilas emitidas por países partes da Convenção da Apostila, inclusive as emitidas em data anterior à vigência da referida Convenção no Brasil, serão aceitas em todo o território nacional a partir de 14 de agosto de 2016, em substituição à legalização diplomática ou consular.
Article 2. Apostilles issued by countries party to the Apostille Convention, including those issued before the Convention entered into force in Brazil, shall be accepted throughout the national territory from August 14, 2016, in place of diplomatic or consular legalization.
The list of countries keeps moving, and the answers you find online often date from before the latest changes. On the Hague Conference's status table, last updated June 30, 2026, the Convention has 130 contracting parties. Some entries matter to readers of this blog: the United States since October 15, 1981; Canada only since January 11, 2024; China (the People's Republic) since November 7, 2023; Bangladesh since March 30, 2025; Algeria since July 9, 2026; Viet Nam since September 11, 2026. Thailand has deposited its accession, but the Convention enters into force for it only on February 28, 2027 — until then, a Thai document for Brazil still goes through consular legalization.
One more column of that table deserves a look. An accession marked "A**" drew an objection, and under article 12 of the Convention an accession somente produzirá efeitos no âmbito das relações entre o Estado aderente e os Estados Contratantes que não apresentem objeção à adesão nos seis meses posteriores ao recebimento da notificação […] — it takes effect only between the acceding State and the contracting States that did not object within six months of the notification, and enters into force between them on the sixtieth day after that period. China, Viet Nam, Algeria and Bangladesh are among the accessions marked that way. Whether a given objection involves Brazil is on that accession's notification page; check it before assuming that an apostille from that country will work in Brazil, or a Brazilian one there.
Apostille documents for Brazil: the chain
For a document issued abroad and headed for a Brazilian office, the apostille is the first link of a chain, and the online answers usually describe one or two links out of three.
Link one — the apostille, in the country of origin. In the United States, the pages of the Brazilian consulates in Washington and Chicago send you to the state. The Consulate General in Washington, in a page published June 15, 2023, writes that Public documents issued by a U.S. state (birth/marriage/death certificates, court documents, etc.) must be sent to the Secretary of State of the issuing state to receive an Apostille certification; the Consulate General in Chicago, in a page updated May 30, 2023, says documents from its ten states will be accepted in Brazil only with an apostille issued by the competent authority in these states. For federal documents, the U.S. Department of State's page, updated December 13, 2024, says that if your document is signed by a U.S. federal official, a U.S. consular officer, a foreign consul registered with its Office of Protocol, or a military notary or judge advocate, the apostille comes from its Office of Authentications (that is how the United States treats its own officials’ documents; it says nothing about Brazilian consular acts, discussed below). By that test, a record signed by an official of a federal agency — an FBI background check is the usual example — takes the federal route, not the state one.
A private document — a power of attorney, a sworn statement, a travel consent for a child — first needs a notary (the Washington and Chicago pages let a Brazilian, or a holder of a Brazilian residence card, have the signature on a travel authorization recognized in person at the consulate instead — see below). The Washington consulate's page on legalization, updated December 14, 2023, writes that All foreign nationals (except those holding a valid RNE) must have their signatures notarized by a local notary public and apostilled by the Secretary of State (please see list below) that issued the public commission to such a notary. That page lists private documents previously certified by a Notary Public and a County Clerk, and Chicago's lists Private documents previously certified by Notary Public and County Clerk; the exact chain is set state by state, so check the issuing state's page. The apostille, in that case, certifies the signature of the last official in the chain, which is what article 1 of the Convention allows.
Link two — the sworn translation, in Brazil's system. The Civil Code, article 224, is short: Os documentos redigidos em língua estrangeira serão traduzidos para o português para ter efeitos legais no País. — documents written in a foreign language must be translated into Portuguese to have legal effect in Brazil. Who may translate is the subject of the next section, and it is where the most expensive mistake happens.
Link three — registration. For the document to produce effects before Brazilian public bodies, courts and third parties, the Public Registries Law requires it to be registered, with its translation, at a Registry of Titles and Documents. That is the link almost nobody mentions, and it has its own section below.
The order is apostille first, then translation, so that the translation covers the apostille too. I state that as practice, not as a rule: no text I read fixes the order for a document entering Brazil. For a Brazilian document leaving Brazil with a translation, a text does fix it, and it adds a second apostille — see the section on Brazilian documents.
The instrument. Ask the Brazilian office that will receive the document — the registry, the Federal Police, the Junta Comercial, the bank — what it wants to see, in writing, before you order the apostille. Recipients may hold their own requirements on top of the general rules; the Cape Town consulate's page, updated October 11, 2024, warns that Certified copies of South African diplomas, certificates and other documents might not be accepted by some public or private Brazilian institutions, even if an apostille certificate was issued.
Sworn translation in Brazil: who may translate
The answers online say the translation must be "done in Brazil", and an official page says it too: the Embassy in Helsinki writes that a foreign document must still be translated, in Brazil, by a sworn public translator. The law says something more precise, and more useful to someone who is abroad: what matters is who translates. Law 14,195/2021 sets the requirements to work as a tradutor e intérprete público — a sworn public translator — and two of them decide the question: to ser brasileiro ou estrangeiro residente no País (be Brazilian or a foreigner resident in Brazil) and to ter registro na junta comercial do local de seu domicílio ou de atuação mais frequente (be registered with the Junta Comercial, the state commercial registry, of their domicile or main place of work) — article 22, items III and VI. Article 24 lets a translator so qualified work in any state. Article 27 gives the consequence:
Art. 27. Presumem-se fiéis e exatas as traduções realizadas por tradutor e intérprete público. § 1º Nenhuma tradução terá fé pública se não for realizada por tradutor e intérprete público, exceto as traduções: […]
Article 27. Translations made by a sworn public translator are presumed faithful and accurate. § 1. No translation shall have public faith unless made by a sworn public translator, except translations: […]
The exceptions that follow are for ship brokers, customs manifests of foreign vessels, public servants whose job is translation, and cases listed by federal executive act, which I did not survey; none of the listed categories is a private person's certificate or decree. Where no public translator is available for a language, the authority may appoint one ad hoc (article 26, sole paragraph, I). So a "certified translation" made by a translator abroad, however reputable, is not a sworn translation for Brazilian purposes. This is where a well-meant instruction misleads. The U.S. Department of State's page tells readers that If the country where you are using the document requires it to be translated from English, get a professional translator and have it notarized — sound advice for some countries, and the wrong path for Brazil, where the translation that counts is the Brazilian public translator's.
What the law does not require is that you be in Brazil. Article 33 allows the public translator to perform their acts electronically, under the electronic-signature law, Law 14,063/2020. In practice that means you can commission a Brazilian sworn translation from abroad: read with article 22, what puts the translation "in Brazil" is the translator's Brazilian registration, not where you are. The Washington consulate's page adds where to find them: the Junta Comercial (Board of Trade) of each Brazilian state maintains an up-to-date list of accredited public translators on their website.
For court proceedings the Code of Civil Procedure has its own line, article 192, sole paragraph, which speaks only of the translation — how it combines with the RTD rule of article 129(6) in a given case is not something I resolve here: a document in a foreign language may be filed quando acompanhado de versão para a língua portuguesa tramitada por via diplomática ou pela autoridade central, ou firmada por tradutor juramentado — with a Portuguese version sent through diplomatic channels or by the central authority, or signed by a sworn translator.
The step after translation: the Registry of Titles and Documents
Here is the link that almost every English-language page on the Brazil apostille leaves out. Article 129 of the Public Registries Law lists what must be registered at the Registry of Titles and Documents (Registro de Títulos e Documentos, RTD) para surtir efeitos em relação a terceiros — to have effect against third parties — and item 6 is precisely the foreign document:
6º) todos os documentos de procedência estrangeira, acompanhados das respectivas traduções, para produzirem efeitos em repartições da União, dos Estados, do Distrito Federal, dos Territórios e dos Municípios ou em qualquer instância, juízo ou tribunal;
6) all documents of foreign origin, accompanied by their translations, to produce effects before offices of the Union, the States, the Federal District, the Territories and the Municipalities, or before any instance, court or tribunal;
Article 148 repeats the rule for documents in a foreign language — to have legal effect in Brazil and against third parties they must be vertidos em vernáculo e registrada a tradução, rendered into Portuguese with the translation registered — and adds, in its last clause, that the same applies to powers of attorney drawn up in a foreign language. One consulate page I read says it plainly: Cape Town writes that Documents in a foreign language, duly apostilled and translated, must be registered at a Cartório de Registro de Títulos e Escrituras e Documentos in order to take effect in Brazil.
Two cautions keep this honest. First, offices differ in what they ask for in practice, and some act on an apostilled, translated document without asking for the RTD registration; the text, however, is the one above, and the registry or bank that refuses a document that skipped it has the text on its side. Second, a few procedures carry their own rule — a foreign divorce recorded on a Brazilian marriage record, a foreign judgment that needs the Superior Court of Justice — and the firm's articles on enforcing foreign judgments in Brazil and on inheritance in Brazil as a foreign heir follow those roads to the end.
Apostille and the Brazilian consulate
"Apostille Brazilian consulate" is one of the most searched forms of this question, and it carries a misunderstanding. A Brazilian consulate does not issue apostilles — not for foreign documents, and not for Brazilian ones. Under article 6 of Resolution 228, the National Council of Justice may delegate apostilles to public bodies, under specific rules of the National Inspectorate of Justice, and to the holders of notary and registry offices; I found no delegation to consulates. The Chicago page says it in one line: The Consulate General does not issue apostilles for Brazilian documents. And for documents of the country where it sits, Washington writes that Brazilian Consulates no longer legalize foreign documents issued by countries which are also parties to the 1961 Hague Convention.
But "the consulate does nothing with documents" is wrong too, and the difference matters to Brazilians abroad. The pages I checked — Washington, Chicago and Guangzhou — say the consulate continues to recognize the signatures of Brazilians and of foreigners holding a Brazilian residence card (RNE, now CRNM), and to authenticate copies of Brazilian documents. Washington lists, among what it still does: Signatures from Brazilian nationals and foreigners with a non-expired "RNE" (Registro Nacional de Estrangeiro) upon presentation of the original Brazilian identification document. The Convention's own scope leaves consular acts out:
Entretanto, a presente Convenção não se aplica: a) Aos documentos emitidos por agentes diplomáticos ou consulares; b) Aos documentos administrativos diretamente relacionados a operações comerciais ou aduaneiras.
However, this Convention does not apply: (a) to documents issued by diplomatic or consular agents; (b) to administrative documents dealing directly with commercial or customs operations.
For use in Brazil, a document drawn up by a Brazilian consular officer is not a foreign document waiting for an apostille. The Vienna Convention on Consular Relations lists among consular functions to agir na qualidade de notário e oficial de registro civil — to act as notary and civil registrar, where the laws of the receiving State do not prevent it (article 5(f), Decree 61,078/1967) — and a power of attorney drawn up that way is, in my reading and in the firm's article on hiring a Brazilian lawyer from abroad, a Brazilian public document: no apostille, no translation. Which notarial acts a post performs, and for whom, is set post by post; that article explains the three routes to a power of attorney from abroad and when each one is open to you. Read your consulate's page on the day you book. For use outside Brazil, the same exclusion means a consular document cannot be apostilled, and Resolution 228 sends it to legalization (article 5, below).
Apostille for Brazilian documents: the cartório
Now the other direction: a Brazilian birth or marriage certificate, a diploma, a criminal record certificate, a court decision or a notarial deed, headed for another country. Since 2021, the National Council of Justice is itself the competent authority to issue apostilles on Brazilian documents, and it delegates the work — article 6 of Resolution 228, as amended — to public bodies under the Council's rules and to the titulares dos serviços extrajudiciais, the holders of Brazil's notary and registry offices (the cartórios). The operating rules are in the first chapter of the Council's National Code of Rules for those offices (Provision 149/2023), and the one that saves most people a trip is this:
§ 1.º O apostilamento poderá ser executado por qualquer notário ou registrador cadastrado, mediante capacitação oferecida por suas entidades de classe, sob supervisão da Corregedoria Nacional de Justiça, independentemente de especialização do serviço ou de circunscrição territorial.
§ 1. The apostille may be issued by any registered notary or registrar, after training offered by their professional bodies, under the supervision of the National Inspectorate of Justice, regardless of the office's specialty or territorial jurisdiction.
In plain terms: your birth certificate does not have to be apostilled by the registry office that issued it, nor in the city where you were born. Any office registered in the Council's system will do. Every notary and registry office in the state capitals and in the Federal District is required to offer the service, unless excused for justified reasons (article 3 and § 1); in the interior it is optional (§ 2). The Council keeps a public search of authorized offices by state and city on its apostille pages.
The same chapter answers the practical questions:
- Who may ask. The bearer of the document, with no written application (article 9). The Convention itself says the apostille is issued at the request of the signer ou de qualquer portador — or of any bearer (article 5). A relative or a representative in Brazil can take the document in for you.
- How long. The office gives a receipt with a delivery date que não poderá ultrapassar cinco dias — which may not exceed five days (article 9).
- How many. A apostila será emitida por documento, não importando a quantidade de páginas que possuir. — one apostille per document, whatever its number of pages (article 11).
- Original or copy. A document signed on paper is apostilled on the original (Resolution 228, article 8, § 3). Apostilling a certified copy or a signature recognition is an ato excepcional, and then the apostille carries the signature of the notary who certified it, not of the original issuer (article 9, § 3); and apostilling a registration certificate or a signature recognition is allowed only on private documents (§ 4) — ask the destination whether that is enough.
- Diplomas and transcripts. School transcripts, certificates of completion and diplomas registered in Brazil are treated as Brazilian public documents for this purpose (article 1, § 2).
- A refusal. If the office doubts the document's authenticity, it runs a prior check and may refuse in a reasoned decision; you can challenge it within five days, and if the office does not reconsider, the state's Inspectorate of Justice decides within 30 days (article 10). And no apostille is placed on a document that evidentemente consubstancie ato jurídico contrário à legislação brasileira — that evidently embodies an act contrary to Brazilian law (Resolution 228, article 4).
- A mistake. If the apostille comes out wrong through the office's fault, it is redone at no cost to you (article 13, § 1).
The cost is set state by state:
Art. 18. Os emolumentos corresponderão, para cada apostila emitida, ao custo de Procuração Sem Valor Declarado, segundo os valores vigentes em cada Estado da Federação.
Article 18. The fees shall correspond, for each apostille issued, to the cost of a Power of Attorney With No Declared Value, according to the amounts in force in each State of the Federation.
The National Code adds that this rule applies enquanto não for editada legislação específica no âmbito dos estados e do Distrito Federal — while no specific state legislation is enacted (article 17). So there is no national price: the fee is the one in the fee table of the state where the office is located, and it is charged per apostille.
The translation that goes with it. If the destination accepts a Brazilian sworn translation of your Brazilian document, the Code requires two separate apostilles:
Art. 15. A aposição de apostila em tradução de documento público produzido no território nacional somente será admitida em tradução realizada por tradutor público ou nomeado ad hoc pela junta comercial. § 1.º O procedimento deverá ser realizado em duas apostilas distintas: apostila-se primeiro o documento público original e, posteriormente, o traduzido.
Article 15. An apostille on the translation of a public document produced in Brazil shall be accepted only on a translation made by a sworn public translator or one appointed ad hoc by the Junta Comercial. § 1. The procedure must be carried out with two separate apostilles: first the original public document is apostilled, and then the translation.
That is the step the "translate after the apostille" advice misses: the translation of a Brazilian document is itself a Brazilian public document, and it gets its own apostille. And a bilingual Brazilian document, with a version in another language printed on it, does not replace the sworn translation for this purpose (article 15, § 2). Whether the destination wants a Brazilian translation at all is the destination's rule: the Cape Town page, for instance, writes that Brazilian documents to be valid in South Africa must be apostilled by an authorized Cartório (registry/notary office) and translated in South Africa by a sworn translator.
Electronic apostille in Brazil
Brazil issues electronic apostilles. The Council's page on the electronic apostille records that it began with Provision 119/2021, now incorporated into the National Code, whose article 14 reads:
Art. 14. O documento eletrônico apresentado à autoridade apostilante ou por ela expedido poderá ser apostilado independentemente de impressão em papel, desde que esteja emitido em formato compatível para upload no sistema do CNJ e assinado eletronicamente. § 1.º A apostila eletrônica será salva em arquivo único, na sequência do documento, assinada pela autoridade apostilante, entregue em mídia ou enviada no endereço eletrônico fornecido pelo solicitante.
Article 14. An electronic document presented to or issued by the apostilling authority may be apostilled without being printed on paper, provided it is issued in a format compatible for upload to the CNJ system and electronically signed. § 1. The electronic apostille shall be saved as a single file, following the document, signed by the apostilling authority, and delivered on a storage medium or sent to the email address provided by the requester.
For someone abroad, that is the practical answer to "can I do my apostille online?" on the Brazilian side: an electronically signed Brazilian document can be apostilled without paper and delivered by email. Every Brazilian apostille, paper or electronic, can be checked: the Council's validation page points to its Apostil system for apostilles issued there, and to the SEI system named in the original text of Resolution 228.
Accepting foreign electronic apostilles is a different question, and I keep to what the texts say. Article 2 of Resolution 228 accepts the apostilas emitidas por países partes da Convenção da Apostila without distinguishing paper from electronic, and I found no Brazilian rule written specifically for foreign e-apostilles. The receiving office still decides what it will act on — ask it before you choose the electronic format.
When an apostille is not the answer
Four situations take a document outside the apostille, and each one sends people looking for a certificate that does not exist.
- The other country is not a party — or not yet. Resolution 228 keeps the old route for them:
Art. 5º Permanece regido pelas normas do Ministério das Relações Exteriores o procedimento de legalização diplomática ou consular de documentos que tenham como origem ou destino países que não sejam partes da Convenção da Apostila, ou quando não for possível a sua aplicação, com base nas exceções previstas em seu art. 1º ou na hipótese de objeção mencionada em seu art. 12.
Article 5. The procedure of diplomatic or consular legalization of documents whose origin or destination is a country not party to the Apostille Convention remains governed by the rules of the Ministry of Foreign Affairs, as does the case in which the Convention cannot be applied, on the basis of the exceptions in its article 1 or of an objection under its article 12.
The same article says that legalization may continue to be done at the Ministry in Brasília, at its regional offices in Brazil, and at Brazil's embassies and consulates; the destination country may add steps of its own, which I did not survey. Thailand, until February 28, 2027, is the live example.
- The document is consular. Article 1 of the Convention excludes documents issued by diplomatic or consular agents. For use in Brazil, a Brazilian consular act needs nothing further, because it is Brazilian; for use abroad, it cannot be apostilled and follows the legalization route of article 5.
- The document is commercial or customs paperwork. The same article excludes administrative documents dealing directly with commercial or customs operations. The Tokyo consulate's page, published February 2, 2024, says the post only legalizes documents issued by the Chamber of Commerce or documents that cannot be apostilled.
- A treaty makes things simpler. No apostille is required when the law, a treaty or an agreement to which Brazil is party removes or waives legalization for the country where the document will be used (Resolution 228, article 3), and such treaties prevail over the Convention whenever their formal requirements are less strict (§ 1). Check whether one exists between Brazil and the other country before you order anything.
Common mistakes
- Asking a Brazilian office to apostille a foreign document. The apostille comes from the country of origin. Brazilian offices apostille Brazilian documents only.
- Booking the Brazilian consulate for an apostille. Consulates do not issue apostilles. What the posts I checked still do for Brazilians — recognizing signatures — and the consular power of attorney explained in the firm's article on hiring a lawyer from abroad may make the apostille unnecessary for use in Brazil.
- Ordering the translation abroad. A certified or notarized translation made outside Brazil's system has no public faith there (Law 14,195/2021, article 27, § 1). Commission a Brazilian sworn public translator — remotely, if need be.
- Stopping at the translation. For effects before public bodies, courts and third parties, the apostilled, translated document is registered at an RTD (Law 6,015/1973, articles 129(6) and 148).
- Translating a Brazilian document and apostilling only the original. If the Brazilian sworn translation travels too, it needs its own apostille (National Code, article 15, § 1).
- Assuming a recent accession works with Brazil. Check the entry-into-force date and any objection on the Hague Conference's table — Thailand, for one, is not in force until 2027.
- Apostilling a copy when the destination wants the original. A copy's apostille certifies the notary, not the issuer (National Code, article 9, § 3).
What I do in your case
I start every file with a list: each document, the country that issued it, the office that will receive it, and what that office has said it wants. From that list, each document gets its route — apostille or legalization, a consular act where the post offers it and the client may use it, or a notary abroad, translation, RTD registration — before anyone pays for a certificate.
For clients abroad, the work is usually the Brazilian end of the chain: commissioning the sworn translation from a public translator registered with a Junta, the RTD registration, and the use of the document in the procedure it was gathered for — an estate, a property sale, a divorce record, a company, a residence file. Where a Brazilian document has to leave Brazil, I check whether an electronic apostille is possible and whether the destination wants a Brazilian translation at all.
What I do not do is promise results. Recipients decide what they accept, consular pages change, and the list of Convention countries moves every year. My job is to make sure each document arrives with every link the law requires, in the right order.
Carvalho Barros Advocacia Internacional handles document chains for Brazilians and foreigners with matters in Brazil — a Brazilian practice serving clients in more than 30 countries. Written communication with the firm is in English; meetings are conducted with an interpreter at no cost to the client. No promise of outcome is made or implied anywhere in this article.
Frequently asked questions
Is Brazil part of the Hague Apostille Convention?
Yes. Brazil acceded to the Convention by depositing its instrument of accession on December 2, 2015, and the Convention has been in force for Brazil since August 14, 2016 (an entry-into-force date, not a ratification date) — dates stated in Decree 8,660/2016, which promulgated it, and in the Hague Conference’s status table. Since then, under article 2 of CNJ Resolution 228/2016, apostilles issued by Convention countries are accepted throughout Brazil in place of consular legalization. The Convention had 130 contracting parties on the Hague Conference’s table last updated June 30, 2026; check the other country’s entry-into-force date and any objection marked “A**” before relying on it.
Can the Brazilian consulate apostille my document?
No. An apostille is issued in the country where the document originates: a foreign document is apostilled by that country’s competent authority, and a Brazilian document by a registered notary or registry office in Brazil. The Consulate General of Brazil in Chicago writes that it “does not issue apostilles for Brazilian documents”, and under article 6 of CNJ Resolution 228/2016 the National Council of Justice delegates apostilles to public bodies under specific rules and to notaries and registrars — I found no delegation to consulates; and the Washington page says Brazilian consulates no longer legalize documents from Convention countries. What the consulates I checked — Washington, Chicago and Guangzhou — still do is recognize the signatures of Brazilians and of holders of a Brazilian residence card and authenticate copies of Brazilian documents. For use in Brazil, a Brazilian consular act is not a foreign document waiting for an apostille: the Vienna Convention on Consular Relations lists acting as notary and civil registrar, where the laws of the receiving State do not prevent it, among consular functions (article 5(f)), and, for use abroad, the Hague Convention excludes documents issued by consular agents (article 1), which then go to legalization under article 5 of Resolution 228. Which acts each post performs is on its own page.
Who apostilles a U.S. document for use in Brazil?
The U.S. authority where the document was issued. For state documents — birth, marriage and death certificates, court decrees, school records — the Washington and Chicago consulates’ pages, and the State Department’s own page, send you to the Secretary of State of the issuing state. For documents signed by a U.S. federal official, a U.S. consular officer, a foreign consul registered with the State Department’s Office of Protocol, or a military notary or judge advocate, the U.S. Department of State’s Office of Authentications issues the apostille; by that test, a record signed by an official of a federal agency, such as an FBI background check, takes the federal route. For a private document, like a power of attorney signed by a foreign national, the Washington consulate’s page says signatures must be notarized by a local notary public and apostilled by the Secretary of State that commissioned the notary, and its list and Chicago’s mention private documents previously certified by a Notary Public and a County Clerk. The exact chain is set state by state — check the issuing state’s page.
How do I get my Brazilian birth certificate apostilled from abroad?
Through any notary or registry office in Brazil registered in the National Council of Justice’s apostille system — not necessarily the office that issued the certificate, and not necessarily in the city where you were born (National Code of Rules, article 4, § 1). The apostille is issued at the request of the bearer, with no written application (article 9), so a relative or representative in Brazil can take the certificate in; the office must set a delivery date no more than five days away. If the certificate is an electronically signed document in a format the system accepts, article 14 allows it to be apostilled without paper and the electronic apostille to be sent to the email address you provide. Ask the destination which certificate it wants before you order the apostille: the apostille certifies the signature, not that the certificate is the right one for your file.
Do I need a sworn translation after the apostille?
If the document is not in Portuguese, yes, for legal effect in Brazil: the Civil Code, article 224, requires translation into Portuguese, and Law 14,195/2021, article 27, § 1, says no translation has public faith unless made by a sworn public translator — someone who is Brazilian or a foreigner resident in Brazil and registered with a Junta Comercial (article 22). A certified or notarized translation made abroad does not meet that rule. The public translator may act electronically (article 33), so you can commission the translation from abroad. For effects before public bodies, courts and third parties, the apostilled document and its translation are then registered at a Registry of Titles and Documents (Law 6,015/1973, articles 129(6) and 148).
Should I get the apostille before or after the translation?
For a document coming into Brazil, the practice is apostille first, so that the Brazilian sworn translation covers the apostille too; I state that as practice, because no text I read fixes the order for incoming documents. For a Brazilian document going abroad with a Brazilian sworn translation, a text does fix it: article 15 of the National Code of Rules requires two separate apostilles — first on the original public document, then on the translation — and only a translation by a sworn public translator (or one appointed ad hoc by a Junta Comercial) can be apostilled.
Does Brazil accept electronic apostilles? Can I do my apostille online?
On the Brazilian side, Brazil issues electronic apostilles: under article 14 of the National Code of Rules, an electronically signed document in a compatible format can be apostilled without being printed, and the electronic apostille is saved as a single file and delivered on a storage medium or by email; Brazilian apostilles can be checked on the National Council of Justice’s validation page. For foreign electronic apostilles, article 2 of CNJ Resolution 228/2016 accepts apostilles issued by Convention countries without distinguishing paper from electronic, and I found no Brazilian rule written specifically for them; the receiving office decides what it will act on, so ask it first.
How long does an apostille take in Brazil, and how much does it cost?
The office gives you a receipt with a delivery date that may not exceed five days (National Code of Rules, article 9). The fee is set state by state: each apostille costs the same as a power of attorney with no declared value in the state where the office is located (CNJ Resolution 228/2016, article 18), while no specific state legislation is enacted (National Code, article 17). One apostille covers one document, whatever its number of pages (article 11). If the office makes a mistake, the apostille is redone at no cost to you (article 13, § 1).
What if the other country is not in the Apostille Convention?
Then there is no apostille: the document goes through diplomatic or consular legalization under the rules of Brazil’s Ministry of Foreign Affairs (CNJ Resolution 228/2016, article 5). Article 5 says legalization may continue to be done at the Ministry in Brasília, at its regional offices in Brazil, and at Brazil’s embassies and consulates; the destination country may add steps of its own. The same route applies to documents the Convention excludes and where an objection under its article 12 prevents its application. Thailand, for example, deposited its accession on June 30, 2026, but the Convention enters into force for it only on February 28, 2027.
What documents need an apostille for Brazil?
Public documents issued in a Convention country and headed for a Brazilian office: civil-registry certificates, court decisions, administrative documents, notarial acts and, through a notary’s certification of the signature, private documents such as powers of attorney and sworn statements (Convention, article 1). The Washington consulate’s page lists birth, marriage and death certificates, notarial acts, court documents, school and university documents, and private documents previously certified by a Notary Public and a County Clerk. Documents issued by consular agents and administrative documents dealing directly with commercial or customs operations are excluded. Which documents a given Brazilian office wants — and whether it asks for the Registry of Titles and Documents registration — is its own requirement; ask it in writing first.
Legal note. This article is informational and does not replace individual legal advice, and it makes no promise as to whether any office in Brazil or abroad will accept a given document (Brazilian Bar Provision OAB No. 205/2021). The provisions supporting it — Decree 8,660/2016, which promulgated the Hague Convention of October 5, 1961 (articles 1 to 5 and 12); CNJ Resolution 228/2016 in the consolidated text with the amendments of Resolutions 247/2018, 302/2019 and 392/2021 (articles 2, 3, 4, 5, 6, 8 and 18); the chapter on apostilles of the National Code of Rules of the National Inspectorate of Justice for notary and registry services, CNJ Provision 149/2023 in its consolidated text (articles 1, 3, 4, 9 to 11, 13 to 15 and 17); Law 14,195/2021 (articles 22 to 34); the Vienna Convention on Consular Relations, Decree 61,078/1967 (article 5(f), read in the capture made on August 22, 2026 for the firm’s article on hiring a Brazilian lawyer from abroad, the federal portal returning an error on October 8); the Civil Code (article 224); the Code of Civil Procedure (article 192); and Law 6,015/1973 (articles 129 and 148) — were read on October 8, 2026 on the federal legislation portal and on the National Council of Justice’s official acts pages, together with the Council’s apostille pages (authorized offices, electronic apostille, validation) and the Hague Conference’s status table for the Convention (last updated June 30, 2026). Consulate pages are stated only as each post writes them, with their publication or update dates: Washington (legalization, updated December 14, 2023; apostille, published June 15, 2023), Chicago (updated May 30, 2023), Guangzhou (updated March 19, 2025), Cape Town (updated October 11, 2024) and Tokyo (published February 2, 2024), and the Embassy in Helsinki (updated February 5, 2024); no general rule for all posts is implied. The U.S. Department of State’s page on preparing a document for an apostille (last updated December 13, 2024) was read in a browser. Portuguese passages are reproduced from the official texts and English passages from official English pages are reproduced from them; other English renderings are the author’s working translation, and the Portuguese is the only authoritative version of Brazilian texts. Declared limits. (i) The order “apostille, then translation” for documents entering Brazil is stated as practice; no text read fixes it. (ii) No Brazilian rule written specifically for foreign electronic apostilles was found; the article reports article 2 of Resolution 228. (iii) The objections behind the accessions marked “A**” were not read, and nothing is said about whether Brazil is among the objecting States. (iv) No state fee table was read; no amount is stated. (v) Treaties that waive legalization between Brazil and particular countries were not surveyed. (vi) Each receiving office’s own requirements, including whether it asks for registration at the Registry of Titles and Documents in a given case, were not surveyed. (vii) U.S. state apostille procedures were not read state by state. (viii) ADI 7196, flagged on article 22 of Law 14,195/2021 on the federal legislation portal, was not read. To review your specific case, contact attorney Luiz Barros — Brazilian Bar, OAB/AL 7.530.
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