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Public Document or Private Document?

1. The category split

The Convention distinguishes between documents that are public and those that are not.

The boundary is decided by national law and by notarial practice.

2. Where the split is clear

Clearly public

Court judgments. Registry certificates. Notarial acts. Administrative decisions.

Clearly private

Handwritten correspondence. Internal company records. Commercial invoices as such.

3. Where it is ambiguous

Certified copies of private documents

Public because the copy certification is a notarial or authority act.

Signatures on private documents

Public once the notary certifies them.

Documents issued by chambers

Depends on whether the chamber is an authority in the Convention’s sense.

Chamber of commerce certifications are treated as public in some parties and not in others.

4. The consequence

An apostille that assumes the wrong classification may be refused.

5. The scenario

An exporter prepared an apostille on a chamber-certified document.

At destination, the authority required either a notarial certificate or an authority-issued document, and the chamber certification did not qualify.

6. The check

Confirm with the destination which authority’s certification it accepts.

7. Closing view

The public-document question is answerable, but not from the Convention alone.

*This article is based on the Hague Convention of 5 October 1961 and national implementing rules.*

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