Since China joined the Hague Apostille Convention on 7 November 2023, the document-authentication process has become simpler for many Australian documents. But the rules are still evolving, and different Chinese authorities have different expectations. Clients often ask:
- Do I need notarisation before sending documents to China?
- If I notarise the document, do I still need translation?
- What exactly does a JP do?
This article provides an up-to-date, practical overview of how notarisation, apostille, translation and JP witnessing work — and when each is required.
1. Using Australian Documents Officially in China
Notarisation + DFAT apostille + Chinese translation
For formal administrative, legal or academic procedures in China, the standard process now involves three steps:
-
Notarisation
A public notary confirms the authenticity of your original Australian document.
-
DFAT apostille
Since China now recognises apostilles, DFAT’s apostille replaces the old requirement for Chinese-consulate legalisation in most cases.
-
Chinese translation (with restrictions)
Chinese authorities do not accept just any Chinese translation. Requirements vary widely. A receiving authority may require that the translation:
- Be included inside the notarial certificate, or
- Be produced or verified by the notary office, or
- Come from a translator approved or recognised by that authority.
Because the translation requirements are not standardised, you must always confirm with the receiving Chinese authority before preparing your documents.
Are apostilled Australian documents widely accepted?
Yes — but acceptance is not universal. Most national-level and provincial authorities have adopted the apostille process, but many universities, employers and regional agencies are still transitioning.
2. NAATI-Certified Translation — Separate From Notarisation
A NAATI-certified translation verifies that the translated content is accurate and professionally prepared. It confirms the accuracy of the wording, not the authenticity of the original document.
When NAATI translation is enough (Australia)
In Australia, NAATI translations are the standard for:
- Immigration applications
- University admissions
- Legal and court documents
- Medical records
- Employment and licensing
For these uses, NAATI translation alone is usually sufficient, without notarisation.
When NAATI translations are enough (China — reference purposes only)
For non-official, non-legal use — for example:
- Showing a translated prescription at customs
- Sharing a translated résumé with an employer
- Providing translated documents for internal review
— a NAATI translation is normally acceptable.
A single mention: Lingofish Translation Services offers NAATI-certified translations suitable for both Australian and Chinese contexts.
3. JP Witnessing — Only Valid Within Australia
A Justice of the Peace (JP) is a free Australian service. A JP can:
- Certify photocopies as true copies of the original documents.
- Witness signatures on statutory declarations and affidavits.
Important:
JP witnessing is not valid in China and cannot replace notarisation or apostille for international use.
4. Updated 2024–2025 Decision Guide
| Your Situation | Correct Process |
|---|---|
| Using documents officially in China | Notarisation + DFAT apostille + Chinese translation (widely accepted, but always confirm with the receiving authority) |
| Using documents in China for reference only | NAATI-certified translation |
| Submitting documents to Australian authorities | NAATI translation; JP witnessing if required |
| Certifying photocopies in Australia | JP-certified copies |
| When unsure | Confirm with the receiving party |
Conclusion
Understanding these processes can save you unnecessary steps, delays and costs. China’s acceptance of apostilled Australian documents has simplified international documentation — but translation formats and institutional requirements still vary. If you need reliable NAATI-certified translations for use in Australia or China, you can always reach out for advice or a quote.