A&DA · Practical guide
These terms describe different steps in preparing a U.S. document for use abroad. The destination country, the kind of document, and the official whose signature appears on it all help determine which authority may need to act.
This is general information, not a determination for a particular document. The receiving institution and relevant government offices set the requirements for each submission.
Start with the distinction
A notary performs a notarial act on a signer or signature under the law of the notary’s jurisdiction. In California, an acknowledgment verifies the signer’s identity; it does not certify the document’s truth or validity. See the California Notary Public Handbook.
A competent authority certifies the signature, official capacity, and—when appropriate—the seal on a public document. It does not certify the document’s contents. An apostille is used within the 1961 Hague Convention framework; check the Convention status table and the recipient’s instructions.
For a document headed to a non-Convention country, a government authentication certificate and sometimes a further legalization by that country’s embassy or consulate may be required. The sequence depends on the destination and document.
Issuer matters
“State” and “federal” describe who issued or signed a document, not two different kinds of apostille. State and local records commonly start with the authority in the state that issued them. In California, for example, the Secretary of State issues apostilles for eligible California public officials’ and notaries’ signatures; itsApostille FAQs explain the scope.
The U.S. Department of State’s Office of Authentications handles eligible federal documents. State-issued documents may need state-level certification before they can be submitted to the federal office for a non-Hague authentication certificate. The Department’s apostille guidance and authentication guidance describe those separate paths.
Destination matters
The Apostille Convention simplifies recognition of public documents between its parties: an apostille replaces the longer legalization chain covered by the Convention. Start with the HCCH status table, and confirm that the Convention applies between the issuing and destination countries. The official Convention outlineexplains the certificate’s purpose and limits.
If the Convention route does not apply, the destination may request a U.S. authentication certificate and then its own consular legalization. For U.S. state documents, state authentication can come first; eligible federal documents follow a different path. The U.S. Department of State describes its non-Hague authentication process. Because the exact chain varies, check the destination government, its embassy or consulate, and the organization receiving the document.
Whichever certificate is used, authentication concerns the origin of an official signature, capacity, seal, or stamp. It does not establish that the underlying document is accurate, legally sufficient, or accepted for a particular purpose.
A useful first pass
Treaty status and recipient rules can change. Confirm current requirements with the relevant authorities before sending original documents.
Primary references
Federal documents and the state-issued document path.
Requirements for federal and state documents used in non-Hague countries.
What a California apostille authenticates and which signatures California can certify.
California notarial acts and the limits of an acknowledgment.
Current Contracting Party status for the 1961 Apostille Convention.
How an apostille replaces legalization between Convention parties.
A&DA document request
The request form gives A&DA information to review. Submitting it does not confirm a route, government acceptance, processing time, or outcome for an individual case.