Apostille for documents used in Türkiye: a step-by-step guide for U.S. companies

Turkish courts, enforcement offices, notaries and the trade registry deal with U.S. documents every day: powers of attorney, certificates of good standing, board resolutions, court records. Each one has to arrive in a form that a Turkish official can rely on without calling the United States. For U.S. documents that form is the apostille, followed by a certified Turkish translation made in Türkiye (Turkey).

This guide explains which U.S. office issues the apostille for each type of document, the order of steps, what to budget for, the open question of e-Apostilles, and the errors that cause a document to be rejected. For the power of attorney itself, use our power of attorney checklist for U.S. companies.

What an apostille does, and why Türkiye asks for it#

The apostille comes from the Hague Convention of October 5, 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents (the Apostille Convention). It replaces the old chain of consular legalization with a single certificate issued in the country where the document was signed.

Under the Convention, the only formality a receiving country may require to confirm a signature, the signer's capacity and, where relevant, a seal is the apostille issued by the competent authority of the state of origin (Art. 3). A properly completed apostille certifies those three things (Art. 5). It does not certify that the content of the document is true or complete.

The apostille is placed on the document itself or on a page attached to it, and carries the French heading "Apostille (Convention de La Haye du 5 octobre 1961)" (Art. 4). Each issuing authority keeps a register, and anyone with an interest can ask it to confirm that an apostille matches its records (Art. 7).

Which documents qualify. Court documents, administrative documents, notarial acts, and official certificates placed on private documents, such as a notary's acknowledgment on a signed resolution (Art. 1). Documents issued by diplomatic or consular agents, and administrative documents dealing directly with commercial or customs operations, are outside the Convention.

Why Türkiye asks for it#

Under Article 224 of the Code of Civil Procedure (HMK), a public document issued by a foreign authority has the status of a public document in Türkiye only if it is certified by the competent authority of the issuing state or by the Turkish consulate. HMK Art. 224(2) preserves the treaties to which Türkiye is a party, and the Apostille Convention is the main one.

Türkiye approved the Convention by Law No. 3028 of 1984, and it entered into force for Türkiye on September 29, 1985. It entered into force for the United States on October 15, 1981 (HCCH status table). Between the two countries, an apostille therefore replaces consular legalization. The Court of Cassation has confirmed that an apostilled foreign notarial power of attorney and its Turkish translation are used without certification by a Turkish consulate (12th Civil Chamber, E. 2019/566, K. 2020/714, February 3, 2020).

Who issues the apostille in the United States#

The rule is simple: the apostille comes from the jurisdiction whose official signed the document. A federal document goes to a federal authority; a state document, or a document notarized under state law, goes to that state.

State and notarized documents#

According to the HCCH information page for the United States, public documents from the states, the District of Columbia and other jurisdictions are apostilled by authorities designated in each jurisdiction, generally the Secretary of State's office. Some states use another office: in Georgia it is the Superior Court Clerks' Cooperative Authority, and in New Jersey the Division of Revenue. The Department of State's Foreign Affairs Manual also states that state-issued documents are authenticated by officials of the issuing state (7 FAM 871).

A notarized document is apostilled by the state where the notary is commissioned. In some states the apostille office certifies only the signatures of state officials or county clerks, so the notary's signature is first certified by the county clerk. New York follows this two-step chain.

Federal documents#

The Office of Authentications of the U.S. Department of State is the competent authority for apostilles on documents executed by federal agency officials (2 FAM 1292.1). Requests are made with Form DS-4194, which lists the country of use; for Türkiye the office issues an apostille rather than an authentication certificate.

Federal court documents#

Clerks and deputy clerks of the U.S. federal courts issue apostilles for documents of their own courts (HCCH information page for the United States). This matters if you plan to enforce a federal judgment in Türkiye: the certified copy and proof of finality are apostilled at the court, not at the Department of State.

The order of steps#

For a document leaving the United States for a Turkish court or registry, the chain usually runs as follows:

1. Obtain the right original. A certified copy from the issuing office, or a document signed in wet ink before a notary. Ask Turkish counsel for the text first if it is a power of attorney or resolution.
2. Notarize private documents. A board resolution, secretary's certificate or power of attorney is signed before a notary public, who completes the notarial certificate.
3. County clerk certification, where required. In states like New York, the county clerk certifies the notary's signature before the apostille.
4. Apostille from the same jurisdiction. The state of the notary or the issuing office, or the federal authority for federal documents.
5. Check before shipping. Email scans of the full set to Turkish counsel. The apostille should name the right signer and be attached to the right document.
6. Courier the originals to Türkiye. Keep the tracking number. Originals may be needed in more than one file.
7. Translate and certify in Türkiye. A sworn translator (yeminli tercüman) translates the document, the notarial certificate, any county certificate and each apostille, and a Turkish notary (noter) certifies the translation.

In Türkiye: translation, notarization and filing#

A party relying on a foreign-language document must file a translation, and the court may ask for an official translation (HMK Art. 223). Turkish registries are more specific. The trade registry requires foreign documents to be certified by a Turkish consulate or under the Apostille Convention and filed with a Turkish translation certified by a notary (Trade Registry Regulation Art. 32). The civil registry accepts apostilled documents with the apostille attached to the original and a notarized Turkish translation (Civil Registration Services Implementation Regulation Art. 59).

In practice, counsel arranges the sworn translation and the Turkish notary's certification once the originals arrive. For a power of attorney, counsel then files the original, or a copy certified by the lawyer, in the court or enforcement file (HMK Art. 76).

Time and cost: what to budget for#

No official source we checked gives processing times for U.S. apostilles, and they change with workload. The table lists the cost items; figures are given only where an official source states them.

The total time depends on the slowest link: a notary appointment, the county step, the apostille office's queue, international courier and translation in Türkiye. Check the current processing options of the apostille office in your state before booking the notary. No timeline is guaranteed. If a filing in Türkiye is urgent, discuss with counsel whether the court can allow counsel to act and set a deadline to file the power of attorney (HMK Art. 77).

e-Apostilles: what is known and what is not#

An e-Apostille is an apostille issued and signed electronically. The HCCH runs the electronic Apostille Programme (e-APP) and states that an e-Apostille has the same validity as a paper apostille and should not be refused just because it is electronic. According to the HCCH e-APP implementation chart of August 2026, a small number of U.S. states issue e-Apostilles, and several state pilot programmes ended on September 30, 2025.

Türkiye issues e-Apostilles itself, since January 2019, for certain documents produced electronically by Turkish authorities, such as criminal record certificates and court decisions. The state postal company PTT acts as intermediary in delivering them (Law No. 6475 on Postal Services, Art. 22).

What is not settled is how a U.S. e-Apostille will be handled when it is filed in Türkiye. We found no Turkish statute, circular or Court of Cassation decision on the point. Turkish procedure is built around paper originals: HMK Art. 76 refers to the original power of attorney or a certified copy, and the civil registry asks for the apostille to be attached to the original. Until practice is clear, ask counsel before you order an e-Apostille for a document that will be filed in a Turkish court, notary office or registry. For a power of attorney, the paper chain is the route Turkish courts have tested.

Documents from countries outside the Convention#

If a group company signs documents in a country that is not a party to the Convention, the apostille route is closed. Under HMK Art. 224 and Article 195 of the Notaries Law No. 1512, a notarial act done abroad needs the signature and seal of that country's competent authority to be certified by the Turkish consul. The Court of Cassation describes the chain as the foreign notary, the official authority the notary reports to, and then the Turkish consulate (12th Civil Chamber, E. 2019/566). Check the HCCH status table first: a state that joined by accession has no Convention relationship with states that objected to its accession (Art. 12).

Common mistakes#

• Apostille from the wrong jurisdiction. The Court of Cassation refused an apostille issued by U.K. authorities on a Florida notarial power of attorney, and noted that it was unclear which signature it covered (11th Civil Chamber, E. 2017/4867, K. 2019/1249, February 18, 2019).
• Apostille on the translation. The apostille belongs on the U.S. original; the translation is certified in Türkiye.
• A private document sent without notarization. A board resolution or secretary's certificate needs a notary's certificate before it can be apostilled.
• A loose apostille page. If the apostille is not clearly attached to the document, its link to the signature can be challenged.
• Translating only part of the set. The notarial certificate, county certificate and apostille are translated with the document.
• Ordering an e-Apostille without asking counsel. Acceptance in Turkish filings is not yet tested.

Turkish documents for use in the United States#

The process also runs the other way, for example when a U.S. court needs a Turkish trade registry record or a Turkish judgment. In Türkiye, apostilles on administrative documents are issued by the governor's office (valilik) or the district governor's office (kaymakamlık). Apostilles on judicial documents are issued by the chair of the justice commission (adalet komisyonu başkanlığı) at seats of high criminal courts (Ministry of Justice Circular No. 68/1; HCCH information page for Türkiye). Criminal record certificates and electronically produced court decisions can receive an e-Apostille through eapostil.gov.tr.

Bottom line#

For a U.S. document going to Türkiye, the apostille comes from the jurisdiction that issued or notarized it: usually the Secretary of State, the federal Office of Authentications for federal documents, or the federal court clerk for federal court records. The apostille stays on the original, and the full set is translated by a sworn translator and certified by a notary in Türkiye. Check each document before it leaves the United States, because a missing or misplaced apostille usually means sending the document back. If you are preparing documents for a Turkish case or enforcement file, send scans for review before the originals travel.

Frequently asked questions

Law stated as at: October 11, 2026. Leyla Başkaya Şentürk is a lawyer (avukat) admitted to the Istanbul Bar Association, Türkiye (Reg. No. 67063). She advises on Turkish law only, is not admitted to practise law in any U.S. jurisdiction and does not advise on U.S. law. Content on this website is general information, not legal advice, and no outcome is promised. Using this website or submitting the contact form does not create an attorney-client relationship.