Guide to Authenticate Documents for China in 2024

The process for correctly authenticating your documents, such as degree certificates, TEFL certificates or other teaching licenses, and no criminal record certificates for use in China, can sometimes appear convoluted or complex. There are several terms that at first glance seem to mean the same thing: Apostille, legalization, authentication, notarization… What do they all mean? What should you focus on? What steps should you take to ensure you’re doing it correctly? This article will help you understand the steps you need to take to authenticate your documents for use in China.

Below, the three main steps for document authentication are explained. These also serve as a basic overview of the main terms: Notarization, Apostille, and Legalization.

The general rule of thumb is:

• Have your documents authenticated in the country where they were issued

Are Your Documents Authenticated?

Once you have completed the authentication process, you'll need to obtain a work visa and work permit. To learn more about that, see here: How to Apply for a Work Visa and Work Permit

Living Abroad?

Notarisation, Apostille and Legalisation

Below, the three main steps for document authentication are explained. These explanations also act as a basic explanation of the main terms: Notarisation, Apostille, and Legalisation.

1. Notarisation: This is the process by which a document is verified by a legal professional known as a notary. Notaries are internationally recognised and regulated private lawyers who are authorised to check that certain documents are true and correct. A notary will take a copy of your original document an affix a certification to say that it is true and real, then sign and seal it.

   
   

   Not all documents need to be notarised. If the original document was produced by a government body, you may be able to bypass the notarisation step.

    

   In the case of a Chinese work visa application, the most likely documents requiring notarisation are your degree certificate and TEFL certificate. In some cases, your non-criminal record clearance may also require notarisation; this is dependent on the country you are from.

   
   

2. Apostille: An apostille is an additional level of authentication which is required for documents to be accepted internationally. After notarisation (if it was required), you must send your document for an apostille by a government department such as the Home Office, Foreign & Commonwealth Office or Department of State.

   
   An apostille can only be granted for documents that have come from institutions based in the same country of origin. For example, the UK Foreign & Commonwealth office can only grant an apostille for documents that were obtained via a UK institution.
   

   
   All countries that are part of the Hague Convention must accept apostilled documents. Since China joined the Hague Convention, it recognizes and accepts apostilled documents for work visa applications, streamlining the process for foreign workers to authenticate their necessary paperwork from their home countries

   
   

3. Legalisation: Previously, this process was necessary to grant legal status to documents in a foreign country. For Chinese work visa applications, it required that your authenticated documents undergo legalization at a Chinese embassy in the country where the authentication was obtained, typically your home country. However, since China joined the Hague Convention in November 2023, this step is no longer needed, simplifying the procedure for verifying the authenticity of documents for work visas and other applications.

Note: Once you have completed the authentication process, you'll need to obtain a work visa and work permit.

To learn more about that, see here: How to Apply for a Work Visa and Work Permit

The Authentication Process for China

After your documents have been authenticated via the above steps, you should send a scanned copy of the documents, along with scans of all authentication certificates and/or stamps, to your new employer who will be able to start the work visa application process on your behalf.

 The notarisation and authentication process can differ depending on what country you are from, or whether you have any peculiarities that need to be dealt with. For example, if you have lived outside your home country for a long time, it may be more difficult to obtain a criminal record certificate.

Authentication processes for the United Kingdom, United States, Australia, South Africa, Canada and Ireland are outlined below.

Document authentication in the United Kingdom

1. Obtain a recent non-criminal record check via the Disclosure and Barring Service (DBS) or Criminal Records Office (ACRO)

• A DBS check
• If you have been out of the UK for a long time (i.e., you have no verifiable UK address or bank account), you may need to go via the Criminal Records Office instead. Also, some parts and regions in China can only accept an ACRO police check.

2. Have your degree certificate (and TEFL certificate if required) notarised by a solicitor or notary public

• The notary will create a copy of your document(s) and attach a letter of attestation

3. Obtain certification of your non-criminal record document

• The document must be sent back to the issuing authority with a request for a legalisation stamp
• The certificate will be given a government stamp recognising it as a true document
• If this option is not available, you will need to go via a notary  instead

4. Have all your documents apostilled by the UK government legalisation service

• Standard service takes up to 10 days
• Express service 1 day
• The criminal record certificate must be the original. Copies will be rejected

5. Your documents are now ready to make your Chinese work visa application 

Document authentication in the United States

• This can be done at the state level or federal level
• State level checks can be done via your home state’s website
• Federal level checks must be conducted through an FBI Background Check and typically take 2 to 4 weeks. This report is highly recommended and, unlike the police check and state report, it is widely accepted in China.
• Ensure the document you receive is signed by the issuing authority

2. Have your degree certificate (and TEFL if required) notarized by a public notary

• This must be done in the state the certificates were issued
  
  

3. All documents must then be authenticated by the Secretary of State in your home state or in case of federal documents, US Department of State

• Authentication must contain an appropriate seal, signature and clear wording
• More information can be found on the Department of State Document Authentication website
• When submitting documents, make it clear that they are for usage in China, so that the official handling your case can use appropriate wording and formatting in the authentication document
  
  

4. Your documents are now ready to make your Chinese work visa application

Document Authentication in Australia

1. Obtain a non-criminal record check from your local authority

• The certificate is obtained via a National Police Check

2. Degree and TEFL certificate (if required) must be notarised by an Australian notary

• You can do this via a notary in any Australian state or territory

3. Have all documents apostilled by the Department of Foreign Affairs and Trade

• Visit smartraveller.gov.au for more information on what legalisation services are available
• Can be done in person or by post
• Postal service is only possible via Melbourne or Sydney

4. Your documents are now ready to make your Chinese work visa application

Document Authentication in South Africa

• Do this via the Department of International Relations and Cooperation
• In some cases, your TEFL certificate will need to instead be notarised by a public notary and then verified by the South African High Court
  
  

4. Your documents are now ready to make your Chinese work visa application

Document Authentication in Canada

1. Obtain a non-criminal record certificate

• Visit canadainternational.gc.ca for more information
• In most cases you will be applying for a Certified Criminal Record Check
• You will need to provide your fingerprints
• If the check brings up no criminal matches, you will be able to obtain the certificate in 3 days or less
• If the check requires any manual processing, or you are found to have criminal matches, the certification process may take up to 4 months

2. Your degree, TEFL (if required) and non-criminal record documents must be notarized by a notary public, lawyer or Commissioner of Oaths of Canada

3. All documents must be apostilled by the Canadian government

• This must be done in the same province or jurisdiction as that in which your documents were notarized
  
  

4. Your documents are now ready to make your Chinese work visa application

Document Authentication in Ireland

1. Apply for a Gardaí Police Certificate

• A Police Certificate is issued by the Superintendent in the District where the relevant applicant resides, or formerly resided, in the Republic of Ireland.
• Certificates are issued free of charge
  
  

2. Degree, TEFL, (if required) and police certificate must be notarised by a local notary public

3. Have all your documents apostilled and legalised by the Irish Department of Foreign Affairs and Trade

4. Your documents are now ready to make your Chinese work visa application

Document Authentication in Other Countries

Unfortunately, we can't write an article for every country here. The above list covers the most common cases that we deal with here at eChinaCareers.

Most countries follow a similar authentication process to those explained above. However, there are some exceptions. For example, Brazilian, Russian and Indian passport holders are able to get their no-criminal record certification at a consulate in China without having to leave the country.

If you have any doubts or questions, the best bet would be to visit your country’s relevant authority’s website.

The authentication process can always seem a little confusing at first. Just remember to break it down into the three main points: Obtaining the relevant documents (based on the purpose of your application), Notarization, and Authentication. With this in mind, you should feel more at ease following the relevant steps for your country outlined above.