Two different systems

Ukraine uses a notarial model: a translator does the work and a notary certifies that the signature is genuinely theirs. The notary does not check the quality of the translation and takes no responsibility for its content.

Most of Europe uses a different model: the state itself grants authority to the translator. Such a translator swears an oath, is entered in a state register and receives a personal seal — and their translation is official without any notary. They carry personal responsibility for its accuracy.

These are not two ways of doing the same thing. They are two systems, and a document prepared under one simply has no standing under the other.

What it is called where

The name and the appointing body differ everywhere, but the principle is the same: the state appointed this specific person.

  • Germany — beeidigter or vereidigter Übersetzer, appointed by a regional court. Austria — Gerichtsdolmetscher.
  • Poland — tłumacz przysięgły, register of the Ministry of Justice.
  • Spain — traductor jurado, accredited by the Ministry of Foreign Affairs.
  • France — traducteur assermenté from a court of appeal list. Quebec — a translator certified by OTTIAQ.
  • Czech Republic — soudní tlumočník, register of the Ministry of Justice.
  • Netherlands — beëdigd vertaler from the state Rbtv register.
  • Italy — no register as such, but the translation goes through asseverazione: the translator's oath before a court official or notary.
  • Türkiye — yeminli tercüman registered with a notary office, followed by noter onayı.
  • Romania — traducător autorizat, authorised by the Ministry of Justice, then certified by a Romanian notary.

When a Ukrainian notarised translation is enough

Whenever the document is submitted in Ukraine. The Ukrainian procedure applies in full, and for an apostilled foreign document it is exactly what is required.

When a document is used abroad informally: for an employer to read, for a university at a preliminary stage, for a partner in negotiations. Here the recipient decides, not the law.

When the destination country has no institution of sworn translators, or accepts a notary-certified translation. There are fewer such countries than people assume, so it is always worth checking.

What to do if the wrong translation was made

First establish what the institution actually requires: refusals are often worded generally, while the specific requirement is on their website or in their list of documents.

If a sworn translator of the destination country is required, the Ukrainian translation has to be replaced — it cannot be 'topped up' with extra certification, because the issue is authorship, not certification.

But the apostilled original does not need redoing: the apostille remains valid, and the new sworn translation is made from the same document. That is considerably cheaper than starting over, so do not rush to order a second apostille.