What 领事认证 means
Consular legalization is a multi-step authentication of signatures and seals on a public document (often after notarization). It does not certify that the document’s contents are true. Since 7 November 2023, Apostille generally replaces this chain between China and other Hague Apostille Convention members for documents within the Convention’s scope.
Teams still default to “legalize at the embassy.” The first question is whether both jurisdictions are Convention members and whether the document is a public document covered by the Convention. Using the wrong chain delays closings, visas and court filings.
Where you see the term
Translation note
领事认证 is “consular legalization” or “consular authentication”. Do not label a Chinese 附加证明书 (Apostille) as legalization.
Primary legal basis
Example
A notarized Chinese corporate document is needed in a country that is not a Hague Apostille Convention member with China. The file still follows consular legalization rather than an Apostille. The same document bound for France would typically use an Apostille instead.
Primary authorities.
18 Sep 2026