Digital Aviation Document QAs

As a rule, documents submitted with ACAA are not required to be signed before a notary (for e.g., lease agreement, IDERA, etc.); however, for certain documents, the law may explicitly require the notarial form (for e.g., certain security agreements governed by Albanian law). In practice, documents are submitted either as originals or certified copies (by a notary public) thereof.

Documents executed digitally by Albanian public authorities can be submitted to ACAA in hard copy provided that the hard copies are certified by the authority which has issued the document. Regarding private documents executed digitally (with a qualified electronic signature) and governed by Albanian law, the secondary legislation for certification of hard copies by a public notary has not yet been enacted, and the ACAA can refuse to consider them.

The form of foreign-law documents (including signature) must comply with the laws of the jurisdiction governing the document. As a matter of practice, when foreign public documents or private documents governed by foreign law are submitted to Albanian authorities, hard copies authenticated by a notary public of such jurisdiction may be required and not just simple copies (i.e., the printed version of the electronic document). In such case, the applicant should make sure that under the laws of the jurisdiction where the document is issued or signed, a notary of that jurisdiction can authenticate the copy of the document signed through an electronic signature of any kind and that the apostille seal can be affixed accordingly (unless the apostille seal is not required for specific countries based on bilateral agreements).

In the event the foreign country is not a member of the Hague Convention of 5 October 1961, “Abolishing the Requirement of Legalisation for Foreign Public Documents”, documents issued in such country must undergo the legalization process.

a. Has Albania implemented the e-Apostille program?

Albania has not implemented the e-Apostille program. Therefore, documents intended for Albania must be provided with an apostille in paper form

For electronically issued documents that are forwarded electronically to the competent authority without media disruption, the data contained in the electronic signature or seal certificate can be confirmed by using an electronic signature confirmation (apostille) if the technical and organizational requirements are met.

Please note that Austro Control generally does not require notarized documents for the registration process of aircraft.

a. Has Austria implemented the e-Apostille program?

Yes, according to the Apostille Act, electronic apostilles are equivalent to paper apostilles and are recognized by the contracting states to the “Hague Convention Abolishing the Requirement of Legalization for Foreign Public Documents.”

a. Has The Bahamas implemented the e-Apostille program?

If the documents are to be recorded at the Bahamian Registrar General’s Department pursuant to the provisions of the Registration of Records Act (RRA), there are notary and apostille requirements. Recording at the Registry of Records, inter alia, requires an affidavit to be sworn by each witness to the execution of the document before a notary public. If the execution takes place outside of The Bahamas, the affidavit must be apostilled or legalised for use in The Bahamas. If the execution of the document is not witnessed, then each executing party must swear an affidavit of due execution before a notary public.

Section 16 of the ECTA specifically provides that a document may be notarized using an electronic signature. It should be noted that, as a matter of practice, the Registry of Records is reluctant to accept documents executed and notarized using electronic signatures.

a. There is no e-Apostille program in The Bahamas.

Electronic communication is defined in the ECTA as information which is communicated, processed, recorded, displayed, created, stored, generated, received or transmitted by electronic means.

Transaction is defined in the ECTA as an action or set of actions relating to the conduct of business, consumer, or commercial affairs between two or more persons, including the sale, lease, exchange, licensing, or other disposition of personal property, including goods and intangibles, interest in real property, services, or any combination of the foregoing.

Security procedure is defined in the ECTA as a procedure, established by law or agreement or knowingly adopted by each party, that is employed for the purpose of verifying that an electronic signature, communication or performance is that of a particular person or for detecting changes or errors in content of an electronic communication.

There are Notary and Apostille requirements in BH for some types of documents. With the Apostille Convention in force in BH, public documents must be certified with an apostille by a court in BH to be recognized in other countries/parties to the convention and vice versa.

Once a document certified with an apostille abroad is to be used in BH, it must be translated into one of the official languages in BH by a court interpreter, and then, the identity of the translated and the original version of the document must be certified by a court in BH.

However, there are countries for which public documents the Apostille is not required in BH. Those documents only need to be certified or issued by the local authorities of the country, and if the document is in a foreign language, it must be translated by a BH court interpreter. The list of those countries includes 21 countries, most of them from the region and EU.

If the country in question is not a signatory of the Apostille Convention, public documents from that country must pass a full legalization procedure to be used before the authorities in BH. That implies a procedure that is a lot more complicated and time-consuming, but once legalized, those documents can be used in BH.

a. Has BH implemented the e-Apostille program?

No, BH has not implemented the e-Apostille program.

According to local laws, documents that are signed outside Brazil in a State that is a signatory to the Convention Abolishing the Requirement of Legalisation for Foreign Public Documents of October 5th, 1961 (the “Apostille Convention”), would have to bear a certificate called “Apostille”, issued by the competent authority of the State from which such documents emanate. In the case of any documents signed in a State that is not a signatory to the Apostille Convention, then documents must be consularized (sometimes called “legalized”) by the Brazilian consulate responsible for the jurisdiction where the signature has taken place. Alternatively, documents signed in Brazil by attorneys-in-fact pursuant to notarized and apostilled or consularized powers of attorney (if necessary, as mentioned herein above) do not require apostille / consularization.

Notarized and apostilled documents received in paper can be digitalized, including specific certification of ICP-Brazil by local Notaries before submitting with the Aviation Authority.

a. Has Brazil implemented the e-Apostille program?

Brazil has implemented the e-Apostille program for documents executed in Brazil.

As previously mentioned, for acts and contracts subject to registration to be valid, they must be executed in accordance with legal formalities, particularly before a Notary Public. That is to say, Chilean law requires that they be granted in Chile or, if granted abroad, to be done before the Chilean consul.

Given the above, for the purposes of aeronautical contracts, it would not be possible to use the apostille, which can be used in the common civil legislation.

a. Has Chile implemented the e-Apostille program?

Yes. Chile has implemented the e-Apostille program, applicable to contracts that are not regulated in the aeronautical legislation.

In Colombia, notary and apostille requirements apply to certain documents used in legal proceedings or transactions. To have legal effect in Colombia, a document may need to be notarized by a Colombian notary public and, if issued by a foreign country, apostilled in the country of origin who has signed the Apostille Convention. The applicability of these requirements to electronically executed aviation documents depends on the specific circumstances and type of document.

Electronic execution and delivery of aviation documents is possible but may require compliance with certain formalities, such as digital signatures or electronic authentication methods for notarization and obtaining electronic apostilles that comply with the requirements established by the Ministry of Foreign Affairs. Legal professionals with experience in Colombian aviation law can provide guidance on compliance with these requirements.

a. Colombia has implemented the e-Apostille program, which allows for the electronic issuance and authentication of apostilles. This program is managed by the Ministry of Foreign Affairs and eliminates the need to physically submit documents for authentication. The e-Apostille is issued in the form of a QR code that can be scanned to verify the authenticity of the document.

In Costa Rica, all the documents that are issued outside of the country must be apostilled or legalized and translated to Spanish. This also applies to electronically executed documents. The above is based on article 294 of the Public Administration General Law.

For certain processes, documents are admitted electronically with no apostille, such as the noise certificate, airworthiness certificate, or registration certificate.

The authorities in Costa Rica admit the electronic apostille from other countries, which can be validated on an official website or with a QR code. Costa Rica has not implemented the e-Apostille program, and currently, the documents that are issued in Costa Rica must have the physical apostille stamped by the Ministry of Foreign Affairs.

a. Has Croatia implemented the e-Apostille program?

With respect to the execution of documents that require registration with any official Registry (including the Registry of Civil Aircraft maintained by the CCAA), all such signatures must be notarized before a notary public of the country of execution. Regarding Apostille requirements, Croatia is a signatory of the 1961 Convention on Apostille and therefore recognizes the process of Apostille confirmation of documents issued by competent authorities on the territory of a foreign country.

Croatia has not implemented the e-Apostille program.

The requirements to notarise and apostille documents vary significantly depending on the type of document and the jurisdiction of the documents’ origin. In general, contracts and agreements do not require notarised signatures. When corporate documents are submitted (in order to prove the identity of the entities to be registered in the Aircraft Registry), notarisation or apostille may be required depending on the type of the documents and jurisdiction of origin.

a. Has the Czech Republic implemented the e-Apostille program?

No, at this time, the Czech Republic has not implemented the e-Apostille program.

As previously established, all the documentation signed abroad has to be legalized and apostilled for it to be valid in the Dominican Republic. If the country in which the document is being signed is not part of the Hague Agreement, then that jurisdiction’s apostille equivalent must be presented.

Notwithstanding the above, these Notary and Apostille requirements do not particularly affect the possibility of electronic execution and delivery of aviation documents in the country, provided that, to date, the Dominican Republic does not accept electronically executed documents in aviation matters.

a. Has the Dominican Republic implemented the e-Apostille program?

Yes.

Yes. Any document to be filed with the Aircraft Register needs to be duly notarized and also apostilled if granted outside of Ecuador. There are no exemptions for digitally signed documents.

a. Has Ecuador implemented the e-Apostille program?

No.

a. Has El Salvador implemented the e-Apostille program?

In El Salvador, all the documents that are issued outside of the country must be apostilled or legalized and translated into Spanish. This also applies to electronically executed documents. For certain filings, documents are admitted electronically with no apostille, such as the noise certificate, airworthiness certificate, and registration certificate.

The authorities in El Salvador admit the electronic apostille from other countries, which can be validated on an official website or with a QR code. In January 2022, El Salvador implemented the e-Apostille program, and currently, the documents that are issued in El Salvador can have the physical apostille stamped by the Ministry of Foreign Affairs, or they can have the electronic apostilled, which can be obtained at https://apostilla.rree.gob.sv.

Documents issued abroad by a foreign authority (except in the Nordic countries) need to be legalised in order for the document to have the intended legal effect in Finland. Certain public documents in the EU are accepted without an Apostille according to an EU Regulation.

There are no apostille requirements in France. Documents may be presented to the Aviation Authority in French or English; documents in another language must be accompanied by a free translation in either French or English. As for French courts, documents must be presented in French or with a certified French translation. It should be noted that the commercial court and the court of appeal of Paris accept documents in English.

a. Has France implemented the e-Apostille program?

No.

According to section 128 of the BGB, there are some declarations that must be notarized, such as contracts in real estate law and in the law of succession. An electronic execution instead of a notarial one would lead to ineffectiveness; thus, documents and declarations that have to be notarized according to German law cannot be executed electronically.

As stated before, certain documents that need to be provided to the Aircraft Mortgage Register in a notarized (and apostilled, as applicable) form cannot be executed electronically by the parties.

In Honduras, all the documents that are issued outside of the country must be apostilled or legalized and translated to Spanish. This also applies to electronically executed documents pursuant to article 398 of the Administrative Simplification Law.

For certain processes, documents are admitted electronically with no apostille, such as the noise certificate, airworthiness certificate, and registration certificate.

Yes, Honduras has implemented the e-apostille program. Digital apostilles are issued by the Ministry of Foreign Affairs.

a. Has India implemented the e-Apostille program?

Yes, India has implemented the e-Apostille program for the attestation of documents. The program provides a centralized platform for document verification/attestation/apostille service for Indian citizens and foreigners who have obtained documents from document-issuing authorities in India. Certain documents filed with the DGCA are required to be notarised and apostilled, and in such cases, coloured scanned copies of the notarised and apostilled documents can be filed electronically.

a. Has Israel implemented the e-Apostille program?

Yes. Notarization of a wide range of documents is required in Israel, including documents produced in Israel for use in Israel, as well as documents produced outside Israel for use in Israel. Examples of documents of the latter type are an affidavit intended for submission in proceedings before an Israeli court, a deed of sale for registration in the relevant local Land Registry of a transaction in real property located in Israel and in some cases, a power of attorney. Such a document also requires verification by apostille attached to it or legalization by the Israeli consul in the country in which the document is signed.

Further to Israel’s Electronic Signature Law (see response to question 7 above) and Israel’s participation in actions taken presumably with respect to the modernization of the Hague Apostille Convention, to which Israel is a party, the Israeli Ministry of Justice has established a system enabling notarization by electronic signature and electronic application of the apostille in Israel, including electronic delivery of the documents. The ESL empowers the Registrar appointed under that Law to recognize an entity approving electronic signatures in a foreign country abroad as an approving entity under the Law, thus enabling reciprocal recognition of electronic signatures between Israel and the foreign country in question. The ESL also provides that the admissibility of a signature shall not be refused merely because it is an electronic signature.

As indicated in the response to question 1 above, the Israeli aviation authorities are willing, in some cases, to accept electronic delivery of documents (instead of hard copies thereof) and hence it is possible, in the light of the provisions of the Electronic Signature Law, that in cases where a document submitted to the authorities requires notarization and the apostille (in general, that is not required), electronic signatures and delivery of the documents will be (and perhaps may have to be) accepted by the authorities.

In Italy, notary requirements and apostille requirements are applicable to certain types of documents, including electronically executed documents. However, the specific application of these requirements to aviation documents may depend on the nature of the document and the applicable regulations in the aviation industry.

Regarding notary requirements, Italian law may require certain contracts or documents to be executed in the form of “public deeds.” Public deeds involve specific formalities for their conclusion and typically require the involvement of a public official or a notary.

In the case of electronically executed documents, the parties may sign the document through a simple electronic signature. However, for the contract to be valid, it generally needs to be executed with the digital signature of the public official or notary.

Otherwise, the e-Apostille program is not enabled.

a. Has Kenya implemented the e-Apostille program?

Kenya has not ratified the Apostille Convention (Hague Convention of 1961) and therefore does not have apostillation requirements.

Notary services in Kenya have not been digitized. The process of providing notary services still requires physical presence for the purpose of execution. This means that notaries public cannot affix their stamp or signatures electronically. The Notaries Public Act, CAP 17 and related regulations do not currently provide for the electronic affixation of notary seals or signatures.

Therefore, in order to fulfil notarial requirements, notaries public must physically affix their official notary seal and manually sign the documents in the presence of the concerned parties.

In Luxembourg, the Passport, Visas and Legalisation Office within the Ministry of Foreign and European Affairs has the mission to manage the entire organisation of the apostille service.

There are currently two possibilities for file transmission:

First possibility: going directly to the apostille desk: the request for an apostille will be made in the traditional form;

Second possibility: initiating the procedure via the online platform MyGuichet.lu.

In both cases, the apostille will be issued in the format of a sticker which is affixed to the public document.

a. Has Luxembourg implemented the e-Apostille program?

An e-apostille program has been in development since 2019, but we have no information about the timing of its entry into force.

The Civil Aviation Directorate requests that documents signed (electronically or in wet-in) in the EU are notarized, while those executed outside of the EU are notarized and apostilled. However, the Civil Aviation Directorate may waive these requirements at their own discretion on a case-by-case basis. The documents that would need to be notarised and/or apostilled will also include, inter alia, a power of attorney issued by a foreign lessor and/or a foreign registrant of an aircraft, duly appointing identified signatories to execute and submit any security documents (IDERA, mortgage or a deregistration power of attorney) to be registered over an aircraft registered in Malta and any foreign law governed lease agreement if this is executed outside Europe.

With regards to any document that indicates it was signed in Malta and/or by a Maltese-established entity will be accepted by the Civil Aviation Directorate without additional formalities.

It would persist that these requirements, as well as specific requirements catered for in Information and Advisory Notices, are to be carried on to the publishing of electronic documents on the Centrik Application.

All documents to be recorded with the RAM must be duly notarized. If such documents were (i) issued abroad, they must be notarized and further apostilled or legalized (as applicable) and/or (ii) entered in any language other than Spanish; a Spanish-certified translation thereof must be issued by a Mexican court-approved expert translator.

Notarization in Mexico involves the execution of documents with wet ink signatures on original copies.

For further information on registrations with the RAM, please refer to L2B’s publication on Aircraft Title and Registration – Mexico.

a. Has Mexico implemented the e-Apostille program?

a. Has Montenegrin jurisdiction implemented the e-Apostille program?

In case of a document for which the law of Montenegro is applicable and for which the national legislation requires one of the special forms, the contract/document must be drawn up in the same form, which may exclude the use of an electronic signature.

The Law on Legalization of Public Documents in International Traffic foresees the obligation to legalize public documents issued in another country that are intended for use in front of Montenegrin authorities.

Also, Montenegro has been a signatory to the Hague Convention since 1961, which means that a document supplied with an apostille is exempt from any further certification and is eligible for use without the obligation of legalization when signing/authenticating foreign public documents.

Montenegro has not implemented the e-apostille program. Therefore, the documents intended for Montenegro must be provided with an apostille in paper form.

There is no additional requirement for a document executed through the use of an electronic signature to be notarized or apostilled.

If a certain document needs to be notarized abroad, it also has to include an apostille or other type of legalization, depending on whether the country of notarization is a signatory party to the 1961 Convention on Apostille. This also applies to electronically executed documents that are notarized abroad.

Most of the aviation documents that should be provided to the Aviation Authority do not need to be notarized. However, some of them are notarized in practice for greater legal certainty and easier enforcement (as explained in the answer to question no. 1 regarding the security documents). There is a possibility for carrying out the notarization electronically in North Macedonia. However, as far as we are aware, this has not been tested in practice.

a. Has North Macedonia implemented the e-Apostille program?

No, North Macedonia has not implemented the e-Apostille program yet.

One requirement for registration is that if the owner is an EEA company, enterprise or association, a self-declaration must be submitted confirming this. The declaration must be confirmed by a Notary Public. Outside the Nordic countries, the notary’s signature must be confirmed by an apostille or legalization.

As stated above, it is not possible to submit aviation documents electronically.

Consequently, Norway has not implemented the e-Apostille program.

As of 9 March 2023, Pakistan has acceded to the Hague Convention (which abolishes the requirement of legalization for public documents and introduces the requirement for apostilization) and has recently introduced a bill to incorporate the Hague Convention into domestic law. The bill is currently titled the ‘Apostille Act 2023’ which has been passed by the National Assembly and is pending approval by the Senate of Pakistan. Therefore, once the Hague Convention is enacted as part of the domestic law, documents may be required to be notarized and apostilled in accordance with the Apostille Act 2023 and public documents, which previously were also required to be consularized would no longer be required pursuant to Article 2 of the Hague Convention.

In general terms, all documents issued abroad with manual or electronic signature must be duly apostilled for their validity in Peruvian entities; however, there are administrative procedures before the aeronautical authority that validate some documents issued abroad with simple or manual signature.

Yes. Any document signed outside the Philippines for filing at the Aviation Authority would require such document to be either apostilled or consularized at the Philippine Consulate. If the document is electronically executed outside of the Philippines, so long as the Aviation Authority receives the original apostilled (or consularized) document, it will accept such document.

However, we note that there is a difference between the apostille and the consularization process. In order to apostille, the local laws of the country where the document is to be executed govern the formalities of the apostille. Therefore, if the local laws allow the electronic execution of a document and its eventual apostille, so long as the Aviation Authority receives the original apostilled documents, it will accept such documents.

For consularization, the Philippine Consulate, where located, would have its own rules for consularization (signing formalities). Generally, the consularization process requires that the document be wet signed in front of the consular officer. Therefore, electronic execution for documents to be consularized might not be allowed.

a. Has the Philippines implemented the e-Apostille program?

It is still under consideration to date.

Notarized form is required for some transactions and statements governed by Polish law, including for a pledge agreement (which is the local equivalent of an aircraft mortgage). Whenever notarization is required, electronic execution of documents is generally excluded (or, at the least, an additional carbon copy with hand signatures is required).

Apostille is generally required for documents issued by foreign public authorities that are presented to Polish authorities or courts, e.g., excerpts from foreign aircraft registers shown to the Polish CAA at registration. Since local law governs the procedure for applying apostille, in principle, Polish authorities should accept electronically signed foreign documents with valid apostille.

a. Has Poland implemented the e-Apostille program?

No.

Portuguese CAA requires all documents and agreements to be notarized with express confirmation of the signatory’s powers to bind the company. Thus, e-signatures cannot be used.

Portuguese CAA will accept registration filings made by email, but all filings must be followed with the original (wet ink) documents.

a. Has Portugal implemented the e-Apostille program?

No, Portugal has not implemented the e-Apostille program but will accept e-Apostilles from other contracting States which have implemented said program.

Those who require the certification of a document to be used in a foreign country must use the apostille or certification service, as corresponds, which is issued by the Puerto Rico Department of State. Its purpose is to authenticate the signatures of public officials on documents to be used outside Puerto Rico.

For Hague Convention countries, an apostille is issued pursuant to the mentioned convention. In the case of non-Hague Convention countries, a certification is issued instead of an apostille.

The document or certificate to be apostilled must be original. In the case of public deeds, you must present a certified copy of the deed issued by the notary public with the corresponding stamps canceled.

If so, do they apply to electronically executed documents, and how does this affect the possibility of electronic execution and delivery of aviation documents?

Puerto Rico notaries are still not allowed to issue certifications for electronic signatures of third parties, thus not being able to apostille documents from them. However, note that there is currently legislation pending examination to amend this.

a. Has Romania implemented the e-Apostille program?

The Romanian Registration Regulation provides that the documents issued by foreign authorities or institutions are filed apostilled or legalized.

Romania did not implement the e-Apostille program.

a. Has Serbia implemented the e-Apostille program?

Yes, there are notary and (in certain cases) apostille requirements for specific documents (for example, deregistration PoA has to be signed before a notary and, depending on the country of signing, apostilled or legalized). The Law stipulates those agreements and other legal transactions which, under law, must be performed before a notary public, and cannot be executed with the use of electronic signatures. These agreements cannot be executed with the use of digital platforms or any electronic signatures, regardless of whether they must be submitted to the Directorate.

Serbia has not implemented the e-Apostille program. Except the Serbian Business Registry, no other Serbian authority accepts e-Apostille from other countries.

Notary requirements only apply to a statement given by the aircraft owner for entry of the aircraft in the Slovenian Aircraft Register. Depending on the place of notarization, an apostille may be required (and an official translation into the Slovenian language).

Notarization and apostille requirements also apply to electronically executed documents. In the notarization in electronic form, the Slovenian notary must indicate how the identity of the party was established and how the validity of the qualified electronic signature was verified. The notarization in electronic form must be linked to the original document in electronic form on which the signature is authenticated or to a scan script thereof, so it is impossible to separate them. The notary must electronically sign the notarization in electronic form with a qualified electronic signature, secure it with a qualified electronic seal and accompany it with a qualified electronic time stamp.

a. Has Slovenia implemented the e-Apostille program?

Yes, but only for public documents originally issued in electronic form, containing the electronic source document to be authenticated or a scan-script thereof, so it is impossible to separate them.

Public and private documents accrediting the acquisition of ownership or possession of the aircraft for registration in the Aircraft Registry, when granted in foreign territory, must be legalized with the Apostille provided for in 1961 The Hague Convention. Where the country involved is not a party to the Convention, then other more traditional systems must be followed, such as legalization through diplomatic channels.

a. Has Spain implemented the e-Apostille program?

The need to adapt the Apostille to technological means has been implemented in the Spanish legal system by Order JUS/1207/2011, which creates and regulates the Electronic Register of Apostilles of the Ministry of Justice and regulates the procedure for issuing Apostilles in paper and electronic format.

All Apostilles issued by the competent authorities in Spain in both paper and electronic format are filed centrally and automatically in the Register, and the validity of the Apostilles issued can be verified by means of a verification code (CSV).

The aforementioned Order JUS/1207/2011 establishes that original documents originally issued by the General State Administration and the Administration of Justice in electronic format and digitized electronic copies of documents issued in paper format, made by the competent officials, may be subject to electronic Apostille, being these documents of a public nature, such as administrative or judicial documents. With regard to notarial documents, the Order states that documents authorised by a notary and private documents whose signatures have been authenticated by a notary may only be apostilled on paper.

The said Order also states that electronic Apostilles validly issued by the authorities of the other Contracting States of the 1961 The Hague Convention will be fully valid in Spain.

No, generally, there are no notary or apostille requirements. In cases where authentication of a document is required, it is sufficient that a physical person (stating name, SSN, telephone number) asserts the authenticity of the relevant document with a staple on the copy.

a. Has Sweden implemented the e-Apostille program?

No.

a. Has Switzerland implemented the e-Apostille program?

There are Notary or Apostille requirements in Switzerland for certain transactions (such as with real estate). Switzerland has not implemented the e-Apostille program.

There are both Notary and Apostille requirements in Turkey. Notaries do not apply affirmation to electronically signed documents; they require ink signature copies of the documents for the affirmation.

a. Has Turkey implemented the e-Apostille program?

Turkey is one of the signatory parties to the Hague Convention of 1961 and its amendments. Therefore, documents that include an e-Apostille can be used for all procdures concerning registration with Civil Aviation Authorities.

a. Has the United States implemented the e-Apostille program?

Yes, there are Notary and Apostille requirements in the United States, but they may not necessarily apply to electronically executed documents in the same way as paper documents. Documents signed by a U.S. federal official, or a U.S. consular officer require an apostille issued by the U.S. Department of State. Notary requirements in the United States typically involve the certification and authentication of signatures on legal documents by a notary public, and these requirements vary by state. While some states allow for electronic notarization of documents using electronic signatures and seals, others require the physical presence of the parties involved in the notarization process.