The Portuguese Government has published Ordinance No. 452/2026/1, which regulates the issuance of apostilles by notaries. From 1 January 2027, individuals and companies will be able to request an apostille from any notary’s office in Portugal or through the website of the Portuguese Chamber of Notaries.
In Portugal, anyone who currently needs to apostille a document must go to the Attorney General’s Office, where walk-in service is limited and an appointment can take two to three months. The ordinance offers a closer and faster alternative. For foreign investors and international groups with Portuguese subsidiaries, this means quicker access to apostilled commercial registry certificates, powers of attorney and other Portuguese documents needed abroad.
Each notary will set the price of the apostille, which is expected to exceed the €10.20 currently charged by the Attorney General’s Office.
1. What is an apostille
An apostille is a certificate that allows a Portuguese public document to be used in any of the approximately 130 countries that are party to the Hague Convention of 5 October 1961. By issuing it, a competent authority confirms the authenticity of the signature of the person who performed the public act, the capacity in which that person acted and, where applicable, the authenticity of the seal or stamp on the document.
An apostille removes the need for diplomatic or consular legalisation, a longer and more expensive process. A single formality in the country of origin is enough for the document to be accepted in the country of destination.
The apostille certifies only the origin of the document, not its content, and does not guarantee the accuracy of the statements it contains.
Companies and individuals frequently need to apostille documents such as commercial registry certificates, powers of attorney, notarial deeds, civil registry certificates and academic diplomas for use abroad.
For countries that are not party to the Convention, consular legalisation is still required. Conversely, certain foreign documents intended for use in Portugal must be apostilled in their country of origin, as Portuguese notaries may apostille only Portuguese public documents.
2. The current system
Currently, only the Attorney General’s Office and the Regional Prosecutor-General’s Offices issue apostilles on Portuguese public documents.
The Attorney General’s Office has changed its service model and now requires issuing entities to register as “e-Partners” on the Online Apostille System. Its services also validate documents before the applicant goes to the counter.
In practice, prior validation has not solved the problem. Lawyers still go to the Attorney General’s Office in person, relying on the priority service granted to them by Portuguese law. It makes 10 tickets available to lawyers each day, five in the morning and five in the afternoon, with a limit of 5 documents per lawyer.
To secure a place, many lawyers arrive at 6:30 or 7 a.m. and coordinate among themselves: each brings as many documents as possible, including those of colleagues, so that everyone can have what they need apostilled.
Electronic documents, which may benefit from an electronic apostille, also face delays. Validation takes two weeks on average, and the apostille itself at least another week. In total, applicants wait between three weeks and a month, a timeframe that is incompatible with the pace of international business. For foreign investors, these delays can hold up closings, appointments of directors, bank account openings and filings in other jurisdictions.
3. What changes under the new ordinance
The Portuguese Notaries’ Statute already gave notaries the power to legalise documents by apostille, on terms to be set by ordinance. Ordinance No. 452/2026/1 gives effect to that power and sets the rules for the electronic platform to be managed by the Portuguese Chamber of Notaries.
From 1 January 2027, notaries, and the employees they authorise to perform notarial acts, may issue apostilles on Portuguese public documents and verify apostilles already issued. The ordinance excludes documents issued by the Public Prosecutor’s Office and the courts; for these, applicants must still go to the Attorney General’s Office.
The main changes are as follows:
- the interested party, or any holder of the document, may request the apostille at any notary’s office in Portugal or online, at www.notarios.pt;
- notaries will issue all apostilles through a single electronic platform managed by the Chamber of Notaries;
- for paper documents, the notary prints the certificate, signs it, staples it to the document and affixes the office’s embossed seal;
- for electronic documents, the notary combines the document and the certificate into a single PDF file, signed with a qualified electronic certificate;
- at the request of the interested party, the notary may scan a paper document in order to affix an electronic apostille; and
- each apostille bears a QR code and an alphanumeric code, which the applicant receives immediately and which anyone, including counterparties and authorities abroad, can use to verify the apostille on the Chamber of Notaries’ website.
The Chamber of Notaries will keep a register of the signatures, stamps and seals of the entities that issue public acts. If a signature, stamp or seal is not on file, or does not match the specimen, the notary will contact the issuing entity to confirm that it is authentic. Issuing entities, in turn, must provide the Chamber with the information it needs.
4. How other countries do it
Portugal is not the first country to entrust apostilles to notaries. In Brazil, notary offices authorised by the National Council of Justice have issued apostilles since the country joined the Convention in 2016, through an electronic system with QR code verification. In France, notaries took over this task from the public prosecutors’ offices of the courts of appeal on 1 May 2025, through 15 regional notarial councils and an online platform. In Spain, notarial colleges, or the notaries they designate, apostille notarial documents. Elsewhere in Europe, for example in Germany, Italy and the Netherlands, apostilles are still issued mainly by courts, public prosecutors or ministries. In the United States, apostilles are issued by the Secretary of State of each state or, for federal documents, by the US Department of State.
5. Costs
At the Attorney General’s Office, an apostille currently costs €10.20. The ordinance does not set a price for notarial apostilles: the notary’s office charges the fee and the notary sets their own fees, plus VAT. The Chamber of Notaries may also charge notaries a fee for managing the platform.
Notarial apostilles are expected to cost more than those issued by the Attorney General’s Office, and prices will vary between notary offices. However, the current model carries hidden costs, well known to those who regularly apostille documents: hours of lawyers’ time spent queuing, travel and unpredictable timeframes that can exceed a month.
Competition between notary offices and online requests should keep prices in check. For those who need an apostille urgently, or in volume, the extra cost is likely to be worth it.
6. Conclusions
The ordinance meets a long-standing need of lawyers, companies and individuals. By extending this power to notaries, the Portuguese Government draws on the nationwide network of notary offices and eases the burden on the Attorney General’s Office.
For lawyers, the change ends long waits and the need to share tickets. For companies, and in particular for foreign investors with operations in Portugal, it brings shorter and more predictable timeframes in cross-border transactions.
The success of the new regime will depend on issuing entities joining the signature register and on the pricing policies of notary offices. If notaries can meet demand, the apostille will cease to be an obstacle and become a routine over-the-counter service.