Who issues an apostille is always the authority of the country that issued the document. An American document is apostilled by the Secretary of State of the state that issued it; a Brazilian document, by a notary office (cartório) authorized by the CNJ. A translation or apostille agency can handle the request, but the apostille always comes from the authority.
Knowing this avoids two common mistakes: trying to apostille in the country where you live instead of the one that issued the document, or thinking whoever places the request is the one who apostilles it.
Key takeaways
- The apostille is issued by the authority of the country that issued the document, not by the country where it will be used.
- In the United States, it is the Secretary of State of the issuing state; for federal documents, the Department of State.
- In Brazil, only notary offices authorized by the CNJ issue apostilles, since August 14, 2016.
- What matters is where the document was issued, not where you live.
- Roxo handles the request, but is never the authority that issues the apostille.
Contents
- Who issues an apostille
- In the United States: the state Secretary of State
- In Brazil: notary offices authorized by the CNJ
- Where you live does not matter
- Who handles the request and who issues the apostille
- Frequently asked questions
Who issues an apostille
An apostille authenticates the signature and seal of the public official who issued the document. That is why only the authority of the country that issued the document can apostille it: it is the one that recognizes the signatures of its own agencies. A Brazilian document cannot be apostilled in the United States, and an American document cannot be apostilled in Brazil.
In the United States: the state Secretary of State
In the United States, each state apostilles the documents it issued, through its Secretary of State. A document issued in Florida, for example, is apostilled by the Florida Department of State, in Tallahassee. A federal document, such as an FBI background check, can only be apostilled by the US Department of State.
In Brazil: notary offices authorized by the CNJ
In Brazil, only notary offices authorized by the CNJ issue apostilles, since August 14, 2016 (Decree 8,660/2016 and CNJ Resolution 228/2016). The Brazilian apostille is electronic, with a QR code that can be checked on the CNJ portal. Because our partner notary office works electronically, we serve all 27 Brazilian states without you leaving home.
Where you live does not matter
What defines who issues the apostille is where the document was issued, not where you live. With a Florida certificate, you can be in Boston, Lisbon or Bogotá: the Florida Department of State still issues the apostille. With a Brazilian document, a notary office in Brazil issues it, even if you live in the United States.
Who handles the request and who issues the apostille
| Document issued in | Who issues the apostille | Who handles the request |
|---|---|---|
| Florida | Florida Department of State | Roxo, filing in person or by mail |
| Brazil | Notary office authorized by the CNJ | Roxo, through the partner notary office, electronically |
| US federal document (FBI) | US Department of State | We do not handle federal documents |
Roxo handles the review, filing and logistics through its sister service Roxo Apostille, but is never the authority that issues the apostille. We do not handle US federal documents or consular legalization.
Frequently asked questions
Who issues a Hague apostille?
The authority of the country that issued the document. A Florida document goes to the Florida Department of State; a Brazilian document, to a notary office authorized by the CNJ. Roxo handles the request, but is never the authority that issues it.
Can I apostille a Brazilian document in the United States?
No. A document can only be apostilled in the country that issued it: a Brazilian document in Brazil, at a notary office authorized by the CNJ, and an American document at the Secretary of State of the issuing state. The Brazilian apostille is electronic, so you do not need to travel.
I live outside Florida. Can I apostille a document from there?
Yes. What matters is where the document was issued, not where you live.
Do you apostille FBI background checks?
No. The FBI record is a federal document, apostilled only by the US Department of State, and we do not handle federal documents. Once the apostille is ready, we translate the record and the apostille.
Want to apostille your document?
Now you know who issues the apostille for your document. Tell us where it was issued and where it is going, and we handle the request with the right authority.
Related topics: apostille services | certified translation | certified translation for USCIS | help center
Related article: Apostille the original or the translation: the right order depends on the destination
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