Notarization, Apostille and Consular Legalization for African Countries

The Hague Apostille Convention has applied to China since 7 November 2023. A Chinese document going to another member state now needs only an apostille from the Ministry of Foreign Affairs or an authorised provincial foreign affairs office, with no legalization by that country’s embassy in China. A document from a member state needs only that country’s apostille to be used in China.

Most African countries, however, are not members. As of October 2026, only South Africa and Mauritius among our eight focus countries are parties. Nigeria, Egypt, Kenya, Tanzania, Zambia and Madagascar still use the old route of notarization, foreign-ministry authentication and embassy legalization.

What the Apostille Convention changed

According to the MFA announcement of 23 October 2023, the Ministry of Foreign Affairs is China’s competent authority for apostilles. Authorised by the MFA, the foreign affairs offices of provinces, autonomous regions and municipalities, and of some cities, can issue apostilles for public documents issued in their area. Chinese apostilles are stickers bearing a silver national emblem and can be checked on the MFA online verification site.

An apostille only certifies the signature and seal on a document, not its content. Under Article 1 of the Convention, notarial acts count as public documents that can be apostilled. Documents executed by diplomatic or consular agents, and administrative documents dealing directly with commercial or customs operations, fall outside the Convention.

On accession, China declared that the Convention does not apply between China and contracting states it does not recognise as sovereign states (China’s declaration on the HCCH site). India objected to China’s accession, so the Convention does not apply between the two; this does not affect Africa.

Which African countries are parties

The table follows the HCCH status table, checked on 10 October 2026: 17 African states. “In force” is the date the Convention entered into force for that state; between it and China the Convention applies from 7 November 2023 at the earliest. We checked the objection records for these states and found no objection by China.

Focus countries that are not parties (as of October 2026): Nigeria, Egypt, Kenya, Tanzania, Zambia, Madagascar. Ethiopia, Ghana, Angola and the DRC are not on the status table either.

On Eswatini: China has no diplomatic relations with Eswatini. Before relying on an apostille for documents involving Eswatini, check with the MFA or a local foreign affairs office.

The list of parties changes, so check the HCCH table again before you send documents.

Documents Chinese residents in Africa need most

• Work permits: degree certificates, no-criminal-record certificates and certified passport copies. For example, the MOFCOM country guides (2025 edition) list a notarized degree certificate (in Chinese and English) for Tanzania’s Class C work permit, qualification certificates and certified passport copies for Zambia’s employment permit, and education and professional certificates for Kenya’s Class D permit. See Tanzania visas and work permits and Kenya visas and work permits.
• Company registration: the parent company’s business licence, articles, board resolutions and powers of attorney. The 2025 MOFCOM guide for Zambia says foreign contractors must submit company registration documents and proof of home-country qualifications. See registering a company in Zambia.
• Family matters: marriage and birth certificates, for dependant permits, school enrolment, or registration back in China.

Sending documents from China to Africa

To member states (e.g. South Africa, Mauritius)

1. Have the degree, criminal-record or other document notarized at a notary office in China.
2. Apply for an apostille at the MFA or an authorised local foreign affairs office.
3. Use the document directly in the destination country; no embassy legalization is needed.

To non-member states (e.g. Nigeria, Kenya, Egypt)

1. Notarize the document at a notary office in China.
2. Have it legalized by the MFA or a local foreign affairs office.
3. Have it legalized by the destination country’s embassy or consulate in China. The Chongqing foreign affairs office’s application form warns that the embassy’s working days can delay this step.

Doing it from Africa: what Chinese embassies offer

Notarization for Chinese citizens abroad

Chinese embassies in Africa can notarize some documents for Chinese citizens legally resident there, mainly powers of attorney and declarations (Embassy in Egypt). Since 31 October 2025 the Embassy in Egypt has used the “China Consular” (中国领事) app for notarization appointments and pre-checks (notice). Since 1 June 2023 the Embassy in Nigeria has worked with notary offices in China on remote video notarization, so matters it cannot handle itself, such as property, equity and inheritance, can go directly to a notary office in China (notice). For passport issues see renewing a Chinese passport abroad.

African documents for use in China

According to China Consular Service, a document from a member state can be used in mainland China once it has been apostilled by that state’s competent authority. A document from a non-member state must first be legalized by that state’s authorities and then by the Chinese embassy or consulate there.

Kenya as an example (Chinese Embassy in Kenya, guidance of 30 June 2026):

1. Notarize the document with a local notary in Kenya.
2. Take it to Kenya’s Supreme Court, which certifies the notary’s credentials.
3. Have it authenticated by Kenya’s Ministry of Foreign Affairs.
4. Apply to the Chinese Embassy in Kenya for consular legalization. From 6 July 2026, applications go through the Chinese Visa Application Service Center in Nairobi (notice).

Example embassy legalization fees

The Embassy in Nigeria does not accept cash or personal cheques, only online transfers (guidance). Company documents also need proof of the legal representative’s identity; see registering a company in Nigeria.

Common problems

• Six-month limit: marital-status notarizations and single-status declarations for marriage registration in mainland China must be no more than six months old when legalization is requested, or they are refused. The same applies to marriage, health, property, income and criminal-record notarizations for adoption (Embassies in Kenya and Egypt).
• Local documents only: a Chinese embassy does not legalize documents for use in a third country and generally does not legalize documents issued by a third country. A Nigerian document cannot be legalized in Kenya.
• Names and numbers must match: if the name, passport number or date of birth differs from the passport, extra proof is needed; if the notary’s signature or seal is inconsistent, an affidavit may be required.
• Binding: documents of two or more pages must be bound with sealing wax, a seal across the pages or an embossed seal. A legalized document that is altered or has pages replaced loses its legalization.
• Role of visa centers: visa centers only give information, accept applications, collect fees and return documents; the embassy alone decides whether to legalize. If something goes wrong, contact the embassy; see consular protection and assistance.

References

1. Apostille Convention to enter into force in China on 7 November 2023 (Ministry of Foreign Affairs of the PRC, 2023)
2. Status Table: Apostille Convention (HCCH, accessed 10 October 2026)
3. China: Declarations and Objections, Apostille Convention (HCCH, 2023)
4. Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents (HCCH, 1961)
5. Consular Legalisation/Apostillisation to China (China Consular Service, accessed 2026)
6. Guidance on Consular Legalization (Chinese Embassy in Kenya, 2026)
7. Notice on consular legalization via the Nairobi Chinese Visa Application Service Center (Chinese Embassy in Kenya, 2026)
8. Legalization requirements, fees and payment (Chinese Embassy in Nigeria, 2026)
9. Notice on remote video notarization (Chinese Embassy in Nigeria, 2023)
10. Introduction to notarization and legalization (Chinese Embassy in Egypt, 2018)
11. Notice on notarization appointments via the China Consular app (Chinese Embassy in Egypt, 2025)
12. Consular legalization application form (Chongqing Foreign Affairs Office, undated)
13. Country Guides for Outward Investment and Cooperation: Kenya, Tanzania, Zambia (MOFCOM, 2025 edition)