1. The process decision
An exporter contemplates building a European subsidiary and asks whether the corporate documents need an apostille or full legalization.
The answer depends on whether the destination is a Convention party, and on what the receiving authority accepts.
2. The apostille route
For Convention parties, the apostille replaces legalization.
Under a week after notarisation.
3. What that means for a European subsidiary
Business licence, articles of association and the parent company’s corporate documents are notarised in China and apostilled.
The subsidiary’s registration authority accepts them.
4. The complication
Company name consistency
The English name used on the business licence must match the name used in the subsidiary’s registration documents.
Where the company uses a different English trading name, the registration authority queries it.
Translation
The destination language, notarised with the document.
Document currency
Registration extracts age. Some authorities require documents issued within three months.
5. The countries outside the Convention
A small number of European jurisdictions fall outside or have specific arrangements.
6. The banking side
For opening a corporate account, banks often require an apostilled set even where the registration authority does not.
Banks add their own requirements, and they change more often than the Convention status does.
7. A scenario
A company registered a subsidiary in the Netherlands, using an apostilled set of documents.
The bank then required a further apostilled document: a notarised resolution of the parent company’s board authorising the investment.
The registration had succeeded. The account opening waited two more weeks.
8. Closing view
Convention status determines the authentication route. The receiving institution determines the document list.
The second is usually the larger constraint.
*This article is based on the Apostille Convention and China’s consular authentication regulations, updated October 2026.*