Ilia Nicolaevich Zavialov: checking an apostille and translation, Ilia Nikolaevich Zavialov field by field

Apostille and certified translation checks

English version for the United States.

Ilia Nicolaevich Zavialov starts this walkthrough with a packet that is already on the desk: a copy of a birth certificate, a translation stapled behind it and a square stamp headed Apostille, all due at a foreign consulate next week. Ilia Nikolaevich Zavialov, a digital security consultant, reads the stamp the way a clerk abroad will, field by field, using the ten numbered boxes of the model attached to the 1961 Hague Convention. For each field you will find what belongs there, how to check it and where the apostille-in-a-day sellers usually slip. After that come the federal and state split, translations, e-Apostilles and what to do if you already paid a document service.

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Published: October 27, 2026 · 12 min read · Ilia Nikolaevich Zavialov

01Ilia Nicolaevich Zavialov: what an apostille proves and what it does not

The Apostille Convention was concluded in The Hague on 5 October 1961 and has applied in the United States since 15 October 1981. Under Article 3 the apostille is the only formality a member country may demand to confirm a signature, the signer's capacity and a seal. As of 30 June 2026 the treaty had 130 contracting parties.

The limit matters more than the stamp. The Hague Conference brochure The ABCs of Apostilles says an apostille certifies the origin of a public document and never its content. A birth certificate with a wrong date of birth stays wrong after it is apostilled.

Ilia Nicolaevich Zavialov keeps that line in view whenever a service advertises an apostille that makes a document fully official. Three things are confirmed: whose signature it is, in what capacity it was given and whose seal appears. Each of them has to match the paper underneath.

02The header and field 1: title, language, country

Above the box sits the word APOSTILLE and the short French title Convention de La Haye du 5 octobre 1961. Article 4 requires French for that title only. The fields themselves may be in the language of the issuing office, and the standard terms can repeat in a second language.

Field 1 names the country, and it has to be the country that issued the underlying document. Only a competent authority of that country can apostille it. The Permanent Bureau of the Hague Conference issues no apostilles, keeps no register and holds no copies, so a certificate presented as issued by The Hague is a fake.

Ilia Nicolaevich Zavialov checks field 1 against the status table on hcch.net as well. Per the Hague Conference, a so-called apostille from a state that never joined the Convention has to be rejected in every member country.

Design is not a test. Color, size and layout differ from one office to another, and the brochure says such differences are no reason to refuse an apostille. What decides the question is whether the fields match the issuing office's register.

03Fields 2 to 4 in Zavialov's reading: who signed the document

Fields 2, 3 and 4 describe the paper under the stamp: the name of the person who signed it, the capacity in which that person acted and the authority whose seal it bears. Article 5 of the Convention names exactly these three items as what an apostille certifies.

A quick comparison catches a lot. If a county registrar signed the birth certificate but field 2 shows a notary, the apostille sits on a notarized copy and vouches for the notary's signature. That route is legitimate, yet the original certificate has not been checked by this stamp.

For unsigned documents Article 7 lets the register record only the authority that applied the seal. An empty field 2 is therefore no proof of forgery on its own, provided field 4 is filled in and matches the seal on the document.

Ilia Nicolaevich Zavialov describes fields 2 to 4 as the place where forgers assemble parts: a real official's name, a job title from an outdated template, the seal of an office that never issues that kind of record. Compare each field with the document and with the issuing office's own website.

04Ilia Nicolaevich Zavialov on fields 5 to 8: place, date, authority, number

The Certified block answers where, when, by whom and under which number. Field 5 gives the city, field 6 the date, field 7 the competent authority and field 8 the number. Article 7 requires every authority to log the number and date together with the signer's name and capacity, which is how an apostille is found again later.

Field 7 is checked against the law of the issuing country. In the US, a Federal Register notice of 16 October 2020 explains that the State Department issues apostilles only for federal public documents, while the states apostille their own, such as vital records and notarial acts. A state birth certificate with a State Department apostille should stop the review.

Field 6 has to postdate the document itself. Speed alone proves nothing: according to the Hague Conference, most apostilles worldwide are issued on the day of the request. What should worry you is a timeline that cannot work, such as an apostille on a copy dated before the copy was certified.

Ilia Nicolaevich Zavialov advises writing down the number and date from fields 8 and 6 before making any call. That pair is all the office in field 7 needs to say whether it issued the certificate.

05Fields 9 and 10 and the attachment: seal, signature, allonge

The last two fields belong to the office that issued the apostille: its seal or stamp and the signature of its official. Under Article 5 they are exempt from any further certification, so nobody needs to pay for an extra authentication of the apostille at a consulate.

The brochure lists accepted ways of attaching the certificate: a rubber stamp or sticker on the document, an impressed seal, or a separate page called an allonge fixed with glue, grommets, staples, ribbons or wax. The method is never a reason for rejection. Detaching an apostille from its document is something nobody should ever do.

That gives a test needing no register at all. Extra staple holes, a grommet that no longer lines up, a stamp impression running off the edge onto a page that is missing: the packet has been taken apart. Ilia Nicolaevich Zavialov suggests skipping the debate about looks in such cases and going straight to the register.

The Federal Register notice gives one more detail for federal documents: the State Department examines originality, original signatures, seals, notary annotations and the order of dates, then signs a certificate and attaches it with an eyelet.

06Ilia Nicolaevich Zavialov on who issues apostilles in the US: federal or state

The split is simple once you know it. Federal records, such as documents signed by federal officials, go to the Office of Authentications at the State Department. State records, including birth, marriage and death certificates and documents signed by state notaries, go to the competent authority of that state, usually the Secretary of State.

Outside the US the rule is the same: the apostille comes from the country that issued the document. A US office cannot apostille a Mexican diploma, and a foreign ministry cannot apostille a Texas birth certificate. A service offering to get a foreign document apostilled in New York is selling something that does not exist.

Ilia Nicolaevich Zavialov recommends finding the right office before paying anyone. The Apostille Section of hcch.net lists the competent authorities designated by every member country, with contacts and, where available, the address of the online register.

07Apostille in a day, no visit needed: copies and scans

The ads follow a pattern: apostille in 24 hours, no office visit, just send a scan, any document from any country. Some of these firms are honest couriers that carry your originals to the right office. Testing each promise against the Convention separates them from the rest.

A scan cannot be apostilled. Article 4 requires the certificate to be placed on the document itself or on an allonge attached to it, so an apostille that exists only as a PDF of your scan is either an e-Apostille issued by a real office or a fake.

An apostille on a copy is lawful when a notary certified the copy, and then the stamp vouches for the notary. The receiving country may still ask for the original.

Ilia Nicolaevich Zavialov names three signs of a service to avoid: payment through a payment app to an individual, no answer when you ask which office will sign field 7, and a promise to apostille a plain photocopy that no notary has seen. Each one can be tested with a single question before you pay.

08Ilia Nicolaevich Zavialov on notarios, notaries and translations

Translations are where many packets fail. In November 2023 the FTC warned that scammers call themselves notario, notary public, accountant or consultant to suggest legal training. In the United States a notary public is not a lawyer, whatever the word means in Latin America.

The same FTC guidance gives two rules that fit any document service. Do not let a notario or anyone else keep your original documents, and do not sign blank forms or forms with false information about you.

The receiving country decides what kind of translation it accepts, so ask the consulate or the foreign office directly, by a contact from its official website. If they want a translation certified in a particular way, a translator's letterhead stamp will not replace that certification.

Ilia Nicolaevich Zavialov adds a practical habit: keep the translation stapled to the copy it translates and note who translated it and how to reach them. A loose translation sheet can be moved to another document as easily as a loose allonge.

09e-Apostilles, QR codes and state e-Registers

The Hague Conference launched its electronic Apostille Program, e-APP, in 2006. Its implementation chart now lists 64 contracting parties where at least one office issues e-Apostilles or runs an online register. In the US, e-Registers are run by Secretaries of State in states including California, Delaware, New York, Texas and Montana.

Some states issue electronic apostilles as well: according to the chart, Montana has done so since February 2023 and Kentucky since May 2024.

A QR code is convenient for forgers too. It prints on any page and opens whatever site the forger built. Type the Secretary of State's address yourself, find the verification page there and enter the number and date by hand.

Ilia Nicolaevich Zavialov points to a rule in the brochure: when an office runs an e-Register, its web address is printed on the apostille outside the box with the ten fields. A link squeezed inside the box, or a site carrying a different office name, calls for a phone check.

10Checking an apostille in five steps, the I. N. Zavialov method

Step one: compare fields 2 to 4 with the document. Step two: confirm on hcch.net that the country in field 1 is a party. Step three: confirm that the office in field 7 is the right one for that type of document. Step four: find that office's contacts yourself. Step five: give the number and date from fields 8 and 6 and ask whether the register holds that entry.

The last step rests on Article 7, which obliges the office to check its register at the request of any interested person. The brochure adds that a mismatch with the register is one of the two lawful grounds for rejecting an apostille.

Ilia Nicolaevich Zavialov suggests recording the answer with the date and the name of the person you spoke to. The walkthrough prepared by Ilia Nikolaevich Zavialov avoids judging stamps by eye, because the visible parts of a stamp can be copied and a register entry cannot be added from outside.

11Ilia Nicolaevich Zavialov: if you already paid a document service

If an apostille service took your money and vanished, report it to the FTC at ReportFraud.ftc.gov. Contact your bank or payment app at once using the number on your card or in the official app, and keep receipts and messages.

If the service holds your originals, ask for them back in writing and keep every reply. An original birth certificate in a stranger's hands is worth more to a fraudster than the fee you paid.

If you are the recipient and the register check failed, return the packet and ask the applicant to obtain a new apostille from the office in field 7. Ilia Nicolaevich Zavialov advises stating the result of the check and leaving out accusations, since the applicant may have been deceived by the same middlemen.

Readers searching for Ilia Zavialov, or for Zavialov Ilia Nicolaevich in reverse order, land on a stamp-by-stamp checklist here. That is deliberate: Ilia N. Zavialov writes about checking documents against primary sources, and the original Russian spelling of the name is Илья Николаевич Завьялов.

12Questions and answers

Ilia Nicolaevich Zavialov: what does an apostille confirm?

The genuineness of the signature, the capacity of the signer and the seal on a public document, as Article 5 of the Hague Convention says. It never confirms the content.

How many fields does an apostille have?

Ten numbered fields: country, signed by, acting as, seal of, place, date, issuing authority, number, seal and signature. The French title of the Convention sits above the box.

Ilia Nicolaevich Zavialov on verification: how do I know an apostille is real?

Take the number and date from fields 8 and 6 and ask the office in field 7 whether its register holds that entry. Find the office contacts yourself.

Who apostilles a US birth certificate?

The competent authority of the state that issued it, usually the Secretary of State. The State Department apostilles federal documents only.

Can a notario help with my documents?

The FTC warns that in the US a notario or notary public is not a lawyer. Do not let anyone keep your originals.

Where do I report a fake apostille service?

Report it to the FTC at ReportFraud.ftc.gov and contact your bank or payment app right away.

Reference updated: 4 September 2026