Sworn Translations: Country Requirements
Why UK certified translations are not always accepted abroad, and what you need instead
The Key Difference: Common Law vs Civil Law
The UK operates under common law, which does not maintain a register of officially approved translators. Any professional translation agency can produce a certified translation by attaching a signed statement of accuracy.
Most of continental Europe operates under civil law, where translators must be vetted, examined, and officially sworn in before a court. Only a translator on the official state register can produce a translation carrying legal weight. The translator’s oath is part of the document’s legal validity.
Practical implication: You need to know which country your translated document will be used in before commissioning any work, because the answer determines whether a UK certified translation will suffice or whether you need a sworn translator in the destination country.
Country-by-Country Requirements
France — Traducteur Assermenté
Sworn translators are appointed by the Court of Appeal (Cour d’appel). French courts, ministries, universities, and embassies all require sworn translations for foreign-language documents. A UK certified translation will not be accepted by French public authorities. Common use cases: marriage registration, property transactions, judicial proceedings, residency applications.
Spain — Traductor Jurado
Official translations must be produced by a sworn translator appointed by the Spanish Ministry of Foreign Affairs (MAEC). Required by Spanish courts, notaries, the Civil Registry, and most public bodies. Common use cases: Spanish citizenship applications (which have increased significantly post-Brexit), inheritance matters involving Spanish property, and academic credential recognition.
Germany — Beeidigter Übersetzer
Sworn translators are appointed by a Regional Court (Landgericht). German courts, government agencies, notaries, and immigration offices require sworn translations. A translation produced in the UK is unlikely to be accepted if German authorities have asked for a vereidigter Übersetzer. The apostille on the original should be in place before commissioning the German sworn translation.
Italy — Traduzione Giurata (Asseverazione)
Italy’s system is distinct: the translator must physically appear at an Italian court (Tribunale) to swear an oath. The process (asseverazione) must take place in Italy — it cannot be done remotely from the UK. Documents for Italian courts, the civil registry, notaries, and government bodies require this procedure.
The Netherlands
Exception for English: The Dutch Immigration and Naturalisation Service (IND) does not require sworn translations for documents originally in English, French, German, or Dutch. For use in Dutch court proceedings or notarial contexts, however, a Wbtv-registered sworn translator is required.
Other Countries
The sworn translation pattern extends across continental Europe and beyond: Belgium (traducteur juré), Austria (gerichtlich beeidigter Dolmetscher), Poland (tłumacz przysięgły), Portugal (tradução juramentada), Czech Republic (soudní tlumočník), Romania (traducator autorizat), Brazil (tradutor público juramentado), and Argentina and Mexico (traductor público).
How Thames Translation Handles Sworn Requirements
As a UK-based agency, our certified translations are accepted by all UK authorities. For sworn translation requirements in civil law jurisdictions, we work with qualified sworn translators registered with the relevant courts in each country. Rather than producing a UK certified translation and hoping it will be accepted abroad, we advise on the correct requirement and engage the appropriate sworn translator within that jurisdiction.
We can also handle combined instructions — for example, FCDO apostille on the original plus sworn translation in France — as a single managed instruction.
Need a Sworn Translation?
Tell us the destination country and we will advise on the correct requirement and provide a quote.