Using Turkish Documents in China: Translation, Notary, Apostille

What did China's accession to the Apostille Convention change?

For many years, Turkish documents needed consular legalisation to be used in mainland China: the document was first certified by the relevant Turkish authorities and then legalised by China's mission in Turkey. China acceded to the Convention Abolishing the Requirement of Legalisation for Foreign Public Documents, known as the Hague Apostille Convention, and the convention entered into force for China in November 2023. Since Turkey is also a party, in general an apostille has replaced consular legalisation for using Turkish public documents in China. This brought significant savings in both time and procedural steps.

This change simplified the process considerably, but it does not mean that everything is resolved automatically. An apostille only confirms the authenticity of the signature, seal and issuing authority on the document; it does not guarantee its content or whether the Chinese institution will accept it. Some Chinese institutions may require the document to have been issued within a certain period, the Chinese translation to be done in a particular way, or additional explanations. Since practice can vary by institution and by city, the right approach is to confirm in advance the current requirements of the authority to which you will submit the document.

Where to get an apostille in Turkey: authorities by document type

In Turkey, an apostille is issued by different authorities depending on the type of document. Administrative documents, such as civil registry extracts, diplomas, chamber of commerce documents and notarised documents, are generally apostilled by governorships or district governorships. Judicial documents, such as court decisions and criminal record certificates, are apostilled by the justice commission presidencies in places with a high criminal court. Electronic apostille options are also developing for some documents. Since the competent authority depends on the nature of the document, checking the relevant authority's current practice before applying saves time.

For private documents, the notary step comes first. For example, documents such as a power of attorney your company gives to someone in China or a board resolution are first drawn up or certified by a notary, and then an apostille is obtained on top of the notarisation. This order matters, because the apostille confirms not the private document itself but the official certification on it, that is, the notary's signature and seal. Whether barcoded documents obtained via e-Devlet will be accepted directly in China may vary by institution; in most cases these documents also need to go through the apostille process.

• Administrative documents: generally governorship or district governorship
• Judicial documents: justice commission presidencies
• Private documents: notarisation first, then apostille
• e-Devlet documents: additional steps may be needed depending on the institution

Chinese translation: should it be done in Turkey or in China?

One of the most common questions about using Turkish documents in China is where the translation should be done. There are two common models. In the first, the document is translated into Chinese in Turkey by a sworn translator, the translation is certified by a notary and the apostille is obtained on top of that notarisation, so the translation also gains international validity. In the second, the original Turkish document is apostilled and sent to China, and the Chinese translation is done in China by a translation company accepted by the institution and certified with the company's seal. Both models have advantages, and which one to choose depends on the procedure for which the document will be used.

Which model is appropriate depends on the Chinese institution that will accept the document. Some market regulation offices, banks or work permit authorities may prefer translations done in China bearing the translation company's seal; others accept a notarised and apostilled translation done in Turkey. At Yeni İpekyolu, before starting to prepare the documents, we confirm the relevant institution's expectations through our team in China, avoiding unnecessary repetition and cost. This simple preliminary check significantly reduces the risk of the document being rejected in China.

Turkish documents required for company formation in China

When a Turkish company wants to set up a foreign-invested company or a representative office in China, documents proving the founding company's existence and its authorised persons are required. These usually include trade registry documents showing the company's establishment and current status, a certificate of activity, a signature circular, a passport copy of the authorised person and, where necessary, a board resolution. In some cases a bank reference letter may also be requested. Which documents are required depends on the type of entity, the city and the local authority's current practice, so the list should be confirmed separately for each project.

The most common problem with company documents is inconsistency between them. The Turkish company's name should be written identically in the trade registry gazette, signature circular and power of attorney; differences such as abbreviations, or “Ltd. Şti.” versus “Limited Şirketi”, can become a question mark during review in China. The Chinese rendering of the Turkish company name must also be written the same way in all translations. The Chinese name chosen in the first document will later be used in the Chinese company's investor records, banking and contracts, so it should be decided carefully from the outset. It is therefore good practice to settle the Chinese name before the first translation and record it in a reference list.

How to prepare a power of attorney for China

During company formation, a trademark application, banking or a dispute in China, it may be necessary to give a power of attorney to someone who will act on behalf of the Turkish company or individual. The power of attorney should clearly state the attorney's identity details and the scope and duration of the powers granted. Chinese institutions generally prefer powers to be specific and limited; very general expressions such as “all kinds of transactions” may sometimes not be considered sufficient. Preparing the text with someone who knows the procedure to be carried out in China is therefore the soundest approach. Stating the validity period of the power of attorney and, where needed, the conditions for revoking it removes uncertainty later.

A practical solution is to prepare the power of attorney as a bilingual Turkish–Chinese document from the start. That way, when the notary certifies the Turkish text, the Chinese text appears in the same document and a separate translation in China may not be needed; whether this is accepted, however, also depends on the institution. The attorney's name in the power of attorney must match exactly the spelling in their passport, or, for a Chinese attorney, the name on their Chinese ID card. Even a small spelling difference can lead to the document having to be redone. Checking the text line by line in both Turkish and Chinese before signing therefore prevents later delays.

Points to watch for work permit, education and family documents

Using Turkish documents in China is not limited to companies. For a Turkish citizen who will work in China, documents such as a diploma and criminal record certificate may be requested during the work permit process. For a diploma, the document issued by the university and, where necessary, certifications from relevant institutions are needed; for a criminal record, a recently dated certificate is required. When relocating with family, marriage and birth certificates may also be requested. The apostille and Chinese translation process should be planned separately for each document according to its type.

The most important point for these documents is how recent they are. Some Chinese authorities require documents such as a criminal record or civil status certificate not to be older than a certain period. Obtaining documents too early may mean they are no longer valid by the time you arrive in China, while obtaining them too late can delay the process. The best approach is to ask your employer in China or the relevant authority in writing for the current document list and validity requirements and to set your timeline accordingly. Tracking each document's issue date in a table when obtaining them from different authorities also makes things easier.

Checklist for using Turkish documents in China

To summarise the process: first clarify the Chinese institution that will accept the document and its expectations. Then determine whether the document is public or private; complete notarisation for private documents. Obtain an apostille from the appropriate authority for the document and, if needed, the translation. Choose whether the translation is done in Turkey or China according to what the institution accepts. Finally, check that names, titles and dates are consistent across all documents. Following this sequence significantly increases the likelihood of your documents being accepted on the first attempt.

At Yeni İpekyolu, our Istanbul office coordinates sworn Chinese translation, notarisation and apostille processes, while our team in China confirms the current requirements of the institution where the document will be submitted. We also plan the order in which documents are prepared, which steps can run in parallel and how they are sent to China, so you always know clearly where each step stands. Contact us to prepare your documents together for company formation, trademark registration, a power of attorney or a work permit and avoid unnecessary repetition.

• Confirm the requirements of the receiving institution.
• Get notarisation first for private documents.
• Obtain an apostille from the right authority.
• Choose where to translate based on what the institution accepts.
• Check consistency of names, titles and dates.
• Add documents' validity requirements to your timeline.