Using Foreign Documents in Portugal — Complete Guide

Quick Check — What You Need

Whether a foreign document works in Portugal depends on three things: the destination use (a specific Portuguese authority, a court, a private counterparty), the origin country, and whether a legalisation step happens on the origin side (apostille or consular legalisation) or is unnecessary because the specific use falls within an exception.

This guide walks the full flow from origin-country document to Portuguese-authority-ready document, with country-specific sections for the origins most commonly asked about at THE-Ö Legal.

The Three-Step Model

For most foreign documents, use in Portugal follows three sequential steps: (1) legalisation at the origin side — either apostille (for Hague-signatory origins) or consular legalisation (for non-Hague origins); (2) certified translation into Portuguese, performed or certified by a Portuguese-authorised professional; (3) Portuguese-side recognition or authentication where the specific act requires it — for instance, a signature recognition on the translated document, or a lawyer certification of the copy for filing.

The exception — Article 41 of the Código do Notariado — sits alongside this model and is explained below.

Step 1 — Origin-Country Legalisation

For a Hague-signatory origin country (125+ countries as of 2026), the document is apostilled by the competent origin-country authority. In the United States this is typically the Secretary of State of the issuing state. In the United Kingdom it is the Legalisation Office of the FCDO. In Brazil, since Brazil's accession to the Hague Convention in 2016, cartórios extrajudiciais handle apostille. Each origin country has its own specific competent authority.

For non-Hague-signatory origins — some African, Middle Eastern and Central Asian countries — a two-step consular legalisation is required: local notarisation, endorsement by the origin country's foreign ministry, and endorsement by the Portuguese consulate in that country (or a delegated Portuguese diplomatic representation). Post-2019 Portugal joined the Hague Convention, so the direction "documents leaving Portugal for other Hague countries" now uses apostille rather than the older consular route.

Step 2 — Certified Translation into Portuguese

Portuguese law does not maintain a sworn-translator registry equivalent to the Spanish traductor jurado or the Brazilian tradutor juramentado. Instead, IRN — the Portuguese Institute of Registries and Notary — confirms that translation certification is performed by one of the following professionals: notário, conservador ou oficial dos registos, advogado, solicitador, câmara de comércio e indústria (Decreto-Lei n.º 244/92 for chambers of commerce).

The practical mechanism: a qualified translator produces the translation and signs it, and a Portuguese advogado, solicitador or notário certifies the translator's signature. Alternatively, an advogado who reads and writes the source language can perform the translation and certification personally. For EU-Member-State-issued public documents (birth, marriage, death certificates), a specific EU regulation exempts certain certified translations from further recognition.

Step 3 — Portuguese-Side Recognition Where Required

For most Portuguese uses — AIMA files, IRN filings, bank onboarding, university enrolment — a legalised and translated foreign document is directly usable without further recognition. For specific acts — for example, when the foreign document is embedded in a Portuguese notarial act, or when the receiving authority explicitly requires an additional certified-copy stamp — an additional Portuguese-side act is needed.

This might involve: a Portuguese lawyer-certified copy of the legalised foreign document; a signature recognition on the Portuguese translation; or, for cross-border corporate acts, a termo de autenticação that references the foreign document. We identify which of these apply during intake.

The Article 41 Exception — When Origin-Country Legalisation Is Not Required

There is a notable Portuguese exception, confirmed by a leading Portuguese-notary competitor's own explainer: "Documents issued abroad according to the local law need no legalization to take effect in Portugal to be used in notarial acts" (csnotaria.com).

The legal basis is Article 41 of the Código do Notariado, which provides that a document validly executed under the law of the country where it was issued is admissible in a Portuguese notarial act without further legalisation. This exception is narrow and its application depends on the specific use: it works well for embedding a foreign document inside a Portuguese notarial act; it does not generally exempt the document from the apostille or consular legalisation step when the document is submitted directly to a Portuguese public authority such as AIMA or IRN.

In practice, the Article 41 exception is most useful for cross-border corporate acts, family-law acts and inheritance acts where a foreign document is referenced inside a Portuguese termo de autenticação or escritura. For standalone use before a Portuguese authority, plan for the apostille or consular route.

US and UK Documents

For US-issued documents (birth certificates, marriage certificates, court decisions, powers of attorney, corporate documents): apostille from the Secretary of State of the issuing state, plus certified translation into Portuguese in Portugal. State-issued vital records typically need to be certified by the county before the state apostille is added.

For UK-issued documents: apostille from the Legalisation Office of the Foreign, Commonwealth & Development Office (FCDO), plus certified translation into Portuguese. Court-issued documents and academic diplomas often require an intermediate notarial certification before the FCDO apostille.

Brazilian Documents

Since Brazil's accession to the Hague Convention on 14 August 2016, Brazilian documents are apostilled by Brazilian cartórios extrajudiciais with the delegation of the Corregedoria Nacional de Justiça. The apostille is added in the origin state — São Paulo, Rio de Janeiro, Minas Gerais, and so on — before the document leaves Brazil.

For Portuguese use, the apostilled Brazilian document is submitted with a certified translation into European Portuguese (yes — the linguistic difference matters for legal-terminology precision). Note that Portuguese authorities often accept Brazilian documents in Brazilian Portuguese without translation, but for use in a Portuguese notarial act a European-Portuguese translation may still be required.

Russian and Ukrainian Documents

Both Russia and Ukraine are Hague signatories, so Russian and Ukrainian public documents are apostilled in the origin country. For Russia, apostille is added by the Ministry of Justice or its delegated regional authorities. For Ukraine, apostille is added by the Ministry of Justice, the Ministry of Foreign Affairs or the Ministry of Education depending on the document type.

Cross-border complications: since 2022, verification of the origin apostille has become more nuanced for Russian documents in some Portuguese-authority contexts. We check destination-authority acceptance during intake. Certified translation into European Portuguese is performed in Portugal by a qualified translator with subsequent advogado certification under Decreto-Lei n.º 76-A/2006 art. 38.

Spanish Documents

Spanish-issued documents are apostilled by the Spanish Ministry of Justice or the delegated Colegio Notarial for notarial documents. Certified translation into European Portuguese is typically required for Portuguese-authority use, though Portuguese authorities often accept Spanish documents in Spanish for reading purposes.

The Spain-Portugal cross-border volume is high enough that certain regional Portuguese cartórios have Spanish-speaking capacity built in. For legal-service-adjacent acts, a Portuguese lawyer with Spanish-language capability handles the intake, the translation certification and the follow-on Portuguese notarial act in a single file.