When China asks for a certified translation

Where is your document going?

Find your row and read the texts it names. They are quoted below, and the section after them works through what they mean in practice.

The texts

If your document only has to satisfy a business partner under a contract, none of these five texts governs it, and you can skip ahead to the contract paragraph in the next section.

Text 1: the translation rule. It takes the Civil Procedure Law one sentence, in its chapter on evidence.

In a case with a foreign party, article 273 adds that the court works in Chinese and that a party may ask for interpretation, at its own expense.

Text 2: when the translation is disputed. The Supreme People’s Court’s interpretation of the Civil Procedure Law fills in what the statute leaves out. Note the words “at the same time” (同时): the translation goes in with the document, and a promise to file it later doesn’t meet the rule.

Text 3: documents made outside China. Here the formalities come from the court’s own rules of evidence.

Article 17 of the same provisions repeats the translation rule for foreign-language exhibits and explanatory materials. For a power of attorney sent from abroad, article 275 of the Civil Procedure Law asks for notarization in that country and authentication by the Chinese embassy or consulate, or the procedure of a treaty between the two countries.

Text 4: the apostille. Article 16 keeps pointing to treaties, and the Apostille Convention is one of them. China acceded on March 8, 2023, and the Convention entered into force for China on November 7, 2023, according to the HCCH status table. The foreign ministry’s notice sets out what changed for documents coming in.

The Convention covers public documents only. Article 1 lists court documents, administrative documents, notarial acts and official certificates placed on private documents, such as a notary’s authentication of a signature. It excludes documents made by diplomatic or consular agents and administrative documents dealing directly with commercial or customs operations. What an apostille proves is set in article 5:

Text 5: the notary. For a document leaving China, the Notarization Law lists what a Chinese notary office certifies. Article 2 defines notarization as certifying the authenticity and legality of legal acts, facts and documents. Among the items in article 11:

What it means for you

In a dispute. Say a company in Germany sues a supplier in a Chinese court over a bad shipment. Its evidence is a year of English emails, an English purchase order and a lab’s test report. Each one goes in with a Chinese translation (text 1). Article 16 of the evidence provisions sets formalities for public documents and for evidence on personal status; it says nothing about a private exhibit such as an email. So have the translations made early, by someone whose work you can defend line by line, and expect the other side to challenge them. Ask for the Chinese set out beside the English, paragraph by paragraph, with the translator’s name on it, so each disputed passage can be answered on its own. If the other side does challenge them, article 525 sends both parties to a translation agency (翻译机构) they choose together. None of the texts read here says who pays that agency, so agree it with the other side or ask the court.

For an authority. Ask the authority for its list of requirements in writing. A rule such as a translation company’s seal comes from the receiver; the texts above contain none. Requirements can differ from one office to the next, so a list from one office tells you nothing certain about another. Keep the written answer with the file.

For a contract with a freelancer or a supplier. Write it in both languages and say which one prevails. If the contract makes both versions equally authentic, article 466 of the Civil Code presumes the words in each have the same meaning and, where they differ, interprets them in light of the contract’s related terms, its nature, its purpose and good faith. The freelance services agreement checklist includes the language clause.

Your own company’s papers need one more step, in either direction. A board resolution or a contract is a private document, and the Convention does not reach it directly. It becomes a public document through a notary: a notary’s authentication of the signature is one of the official certificates article 1 lists. Going by the Convention’s own list, the chain runs: notary first, apostille on the notary’s certificate second. Where the receiver also wants a Chinese translation, ask it whether the translation should sit inside that chain or simply travel with it.

For documents going abroad. Check the HCCH status table for the destination, and look at China’s row: an objection shows as A** in the type column. On October 18, 2026, the table showed one objection to China’s accession, from India, dated September 8, 2023. Under article 12 of the Convention, an accession takes effect only with states that did not object, so between China and India the Convention does not apply and legalization is still needed. In China, apostilles are issued by the foreign ministry and, on its authority, by provincial and some city foreign affairs offices, according to the ministry’s notice. The same notice says Chinese apostilles are stickers that can be verified online. That helps if the receiver abroad has never seen one.

What it does not say

Four things people look for in these texts and won’t find:

• None of these texts defines “certified translation” or creates a register of sworn translators.
• None requires a translation to carry a translation company’s seal; where a receiver asks for one, that is the receiver’s rule.
• An apostille certifies the signature, the signer’s capacity and the seal on a public document, not the accuracy of a translation attached to it (Convention, art. 5).
• A national standard exists, Translation services: requirements for translation services (翻译服务 第1部分：笔译服务要求), GB/T 19363.1-2022, in force since July 1, 2023, replacing the 2008 edition; it sets requirements for a translation service, and nothing in its record says it certifies a single translation.

Where a freelance translator fits

A freelance translator in China is the right hire for contracts, evidence drafts, correspondence and anything where the parties agree the translation. When a court or an authority names a kind of provider, follow the receiver. A translator’s work for you is a commissioned work, so ask for the written assignment that the rule on commissioned work describes.

Before you post, two pages help with the budget and the scope: what translation costs in China, and the translation category, which shows the work freelancers take on. If the document belongs to a dispute, the legal support category is the closer fit. Spoken work is a different hire altogether, covered in how to hire an interpreter in China. A Chinese-speaking assistant can translate short texts for you, though an assistant’s translation is not a certified one. The rest of the job is in the overview, How to hire a freelancer in China without speaking Chinese.

Post the translation as a brief, and say where the document is going. Start a brief.