Notarisation vs Apostille: Two Offices, Two Steps, and an Order You Cannot Reverse

What each step is actually for

Notarisation turns a privately signed paper into a recognisable instrument. Philippine notarisation is done by a commissioned lawyer, usually in one of 2 forms: a jurat, where the signatory swears the contents are true, or an acknowledgment, where the signatory confirms the document was signed voluntarily. Which one applies depends on the document's use.

The apostille makes that signature recognisable abroad. It certifies the signature, the seal and the signatory's capacity. Note what it attaches to: for a notarised document, the DFA is certifying the notary's signature and seal, not yours and not the contents.

They are sequential, not alternatives. Without the first step the second has nothing to verify.

Which documents need notarising first

The test is who issued the document, not how formal it looks.

No notarisation needed (public documents): birth, marriage and death certificates and CENOMAR in the PSA-issued version; NBI clearance in the official version; licences and permits from the issuing government agency.

Notarisation required (private documents): special powers of attorney, affidavits, consent letters, board resolutions and self-signed employment papers. In the Philippines these need one more step after notarisation — a Certificate of Authority for a Notarial Act (CANA) from the Regional Trial Court supervising that notary.

Two categories are routinely misjudged. Certificates issued by private schools, companies or hospitals are not government-issued, so they are usually treated as private documents; school records also need the education regulator's certification. Translations are issued by the translator and are likewise private documents.

Unsure whether your document is public or private? → Send Yixing the issuing body and the document name and we will check before you start

Three ways the order goes wrong

Skipping notarisation. The file is returned unprocessed. Fix: notarise, obtain the CANA, book a fresh appointment — DFA authentication counters have accepted online appointments only since 1 December 2024.

Notarised but no court certificate. The most easily missed return reason, because the document looks processed. Fix: obtain the CANA from the supervising Regional Trial Court; the document itself does not need redoing.

Apostille first, notarisation after. This cannot work — the apostille attaches to a specific signature, so adding another afterwards means the certificate no longer covers the final version. This one restarts the chain.

One prerequisite foreigners often miss: per the DFA Authentication Division's FAQ, foreign nationals processing employment-related documents must present the DOLE Alien Employment Permit and the BI ACR I-Card.

Yixing is a private consultancy registered in the Philippines (SEC No. CS202009551, BI Accreditation No. CA-202624381-1). We are not affiliated with the DFA, PSA, NBI or any embassy. We check document versions and prerequisites, book appointments, file and collect on your behalf, and arrange translation; acceptance is decided by the issuing authority and the receiving party, and we do not promise outcomes. This article is general information, not legal advice; current practice is whatever the DFA Authentication Division publishes at the time.