Deutsche Fassung: Apostille Vietnam–Deutschland (DE)
Status as of 4 September 2026. Verified against the HCCH status table, Decree 293/2026/NĐ-CP and current guidance of the German missions in Vietnam. Objections under Article 12 may be withdrawn at any time — see “Monitoring” below.
Executive summary
From 11 September 2026, Vietnam issues Apostilles under the Hague Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents (the Apostille Convention). Vietnam acceded on 31 December 2025; Decree No. 293/2026/NĐ-CP of 23 July 2026 implements the Convention domestically.
For most Convention States, a qualifying Vietnamese public document may now be authenticated with a single Apostille instead of the multi-step consular legalisation chain, and vice versa.
Germany is the principal exception. Germany objected to Vietnam’s accession on 20 May 2026 under Article 12(2) of the Convention. The legal consequence is precise and should be stated precisely:
From 11 September 2026 Vietnam issues Apostilles, but the Convention does not apply in the relationship between Vietnam and Germany because Germany objected under Article 12(2). Consular legalisation continues for Germany–Vietnam document flows.
Austria and the Czech Republic have lodged the same objection (see Section 9). This article focuses on Germany–Vietnam; the same rules apply to those two States.
Who is affected:
- German companies investing or operating in Vietnam;
- German nationals working or living in Vietnam;
- Vietnamese companies establishing businesses or undertaking transactions in Germany; and
- Vietnamese nationals moving to Germany for employment, study or family purposes.
The practical rule: do not assume that an Apostille replaces legalisation merely because both Germany and Vietnam are Contracting States. For Germany–Vietnam cases, the document route must be checked separately for each document, each receiving authority and each direction of travel.
1. What changes in Vietnam on 11 September 2026?
Decree No. 293/2026/NĐ-CP dated 23 July 2026 takes effect on 11 September 2026. Key features:
| Item | Position under Decree 293 | Provision |
|---|---|---|
| Competent authority | The Ministry of Foreign Affairs issues Vietnamese Apostilles; the Minister sets the criteria, conditions and roadmap for delegating issuance to provincial People’s Committees | Art. 6(1), 6(3) |
| Apostille route | Applies to public documents circulating between Vietnam and a Convention State with which the Convention operates for Vietnam | Art. 5(3)(a) |
| Legalisation route | Consular certification/legalisation under existing law continues for documents circulating with non-Convention States | Art. 5(3)(b) |
| Objecting States | Where a Contracting State objects to Vietnam’s accession under Article 12, the Convention has no effect between the two States; documents circulating between them follow the legalisation route in Art. 5(3)(b) | Art. 5(4) |
| Treaties | Where a treaty to which Vietnam is party provides simpler rules or exempts authentication, the treaty prevails | Art. 5(3)(c) |
| List of States | The Ministry of Foreign Affairs updates and publishes the list of Contracting States with which the Convention operates for Vietnam | Art. 30(5) |
| Scope of certification | An Apostille does not certify the content or form of the public document | Art. 4(2) |
| Effective date | 11 September 2026 | Art. 34 |
For countries with which the Convention operates, this is a material simplification of corporate, investment, immigration, civil-status and commercial documentation. It does not operate identically with every Convention State.
2. Why Germany is different
Article 12 of the Apostille Convention allows an existing Contracting State to object to the accession of another State. Where an objection is lodged, the Convention does not enter into force between the objecting State and the acceding State.
Germany exercised this right in relation to Vietnam on 20 May 2026. The German Federal Foreign Office lists Vietnam among the acceding States to which Germany has objected.
The consequence is not that Vietnam is excluded from the Convention. It is narrower:
| Document | Intended for | Route |
|---|---|---|
| Vietnamese public document with Vietnamese Apostille | France, Netherlands, Singapore, or any other Convention State that has not objected | Apostille suffices |
| Same document | Germany | Apostille has no Convention effect; legalisation by the German mission in Vietnam remains required |
| German public document with German Apostille | Vietnam | Apostille has no Convention effect; legalisation by the Vietnamese mission in Germany remains required |
Objections may be withdrawn at any time. Until Germany withdraws its objection, the position above applies.
3. German companies investing in Vietnam
German investors regularly need German corporate documents for Vietnamese procedures — investment registration (IRC), enterprise registration (ERC), M&A approvals, sector licences, capital changes and changes of legal representative. Documents typically include:
- commercial register extracts (Handelsregisterauszug);
- articles of association;
- board or shareholder resolutions;
- powers of attorney for the Vietnamese filing;
- evidence of the authority of company representatives; and
- bank, financial-capacity or ownership documentation.
After 11 September 2026, a German Apostille on these documents does not satisfy the Vietnamese authentication requirement. The route remains: German certification (notarial/ court or administrative pre-certification as applicable) → legalisation by the Vietnamese Embassy or Consulate in Germany → translation and notarisation/certification in Vietnam → filing with the licensing authority.
For time-sensitive projects, the document route should be settled before documents are executed or ordered in Germany. A defect in authentication is one of the most common causes of delay in IRC/ERC timetables.
4. German nationals moving to Vietnam
The same rule applies to German citizens relocating to Vietnam. Documents commonly required include:
- criminal record certificates (Führungszeugnis);
- university degrees and professional qualifications;
- employment or experience certificates;
- birth and marriage certificates; and
- documents relating to accompanying spouses or children.
These feed into work-permit, temporary-residence, civil-status and dependant procedures, each with its own requirements as to originals, validity period and translation. A German Apostille should not be treated as completing the Vietnamese requirement. Employers and employees should map each document before the employee leaves Germany.
5. Vietnamese companies investing in Germany
The reverse direction is more difficult.
Vietnamese investors entering Germany must establish corporate existence, signatory authority and ownership before German notaries, the commercial register (Registergericht), banks, counterparties and administrative authorities — for example when forming a GmbH, opening an account, contributing capital, appointing a Geschäftsführer or registering with the Handelsregister.
The German missions in Vietnam currently legalise only a closed list of Vietnamese documents, essentially civil-status and criminal-record documents (see Section 6). Their guidance states expressly that documents not on the list cannot be legalised through that procedure. Vietnamese corporate documents — enterprise registration certificates, charters, corporate resolutions and corporate powers of attorney — are not on that list.
A Vietnamese Apostille does not resolve this, because the Convention does not apply between Vietnam and Germany.
The prudent approach is “acceptance-first”:
Identify the final German recipient and obtain its confirmation of the acceptable evidentiary route before commissioning certification, translation or legalisation.
Depending on the recipient, alternative evidence may be considered — original or officially certified extracts, direct verification with the issuing Vietnamese authority, publicly accessible registry data, translations to the recipient’s standard, a Vietnamese legal opinion on existence and authority, or advance written confirmation from the German authority. Acceptance is decided case-by-case by the receiving German authority or notary; no route should be assumed in advance. German-law steps, including notarial acts and Registergericht filings, require German counsel or a German notary.
6. Vietnamese nationals moving to Germany
The German Embassy in Hanoi and the Consulate General in Ho Chi Minh City currently legalise the following Vietnamese documents (after Vietnamese pre-certification): birth, marriage and death certificates or register extracts; certificates of unmarried status; paternity acknowledgements; police residence confirmations; court divorce judgments; and criminal record certificates on the prescribed forms.
The missions advise applicants to verify in advance whether the German receiving authority actually requires legalisation. Requirements differ between, for example, an Ausländerbehörde, a Standesamt, a university and an employer. A Vietnamese Apostille should not be obtained on the assumption that it replaces the Germany-specific process.
Individuals should be alert to service providers offering “Apostille packages” for German visa, study or skilled-worker applications: for Germany, an Apostille is not the correct instrument.
7. An Apostille does not validate the substance of a document
An Apostille certifies specified formal elements of a public document. It does not determine whether the underlying statement is factually correct; whether a corporate act is legally valid; whether the signatory had sufficient authority; whether a translation satisfies the receiving authority; whether the document is sufficiently recent; or whether substantive investment, immigration or civil-status requirements are met. Authentication is one step in cross-border document acceptance, not the whole of it.
8. The six-question document test
Before obtaining an Apostille or commencing legalisation, identify:
- Where was the document issued?
- In which country will it be used?
- What type of document is it?
- Which authority, court, notary, bank or registry will receive it?
- What authentication and translation requirements does that recipient impose?
- Will the document also be used in another jurisdiction?
Question 6 matters for international groups: a document package prepared for France or the Netherlands may require a different route when the same transaction extends to Germany.
9. Extension: Austria and the Czech Republic
Germany is not the only State to have objected. The HCCH status table records objections under Article 12(2) to Vietnam’s accession by:
| State | Date of objection | Effect |
|---|---|---|
| Germany | 20 May 2026 | Convention does not apply between Vietnam and Germany |
| Austria | 19 June 2026 | Convention does not apply between Vietnam and Austria |
| Czech Republic | 2 July 2026 | Convention does not apply between Vietnam and the Czech Republic |
Everything in Sections 2–8 applies equally to Austria–Vietnam and Czech Republic–Vietnam document flows: consular legalisation continues in both directions, and the receiving authority’s requirements govern. Groups with entities in Vienna or Prague should therefore treat the DACH/CZ region as a single “exception zone” in their document planning, while the Convention operates with other EU Member States that have not objected.
This applies unless a treaty or bilateral arrangement between Vietnam and the State concerned provides otherwise at the relevant time; under Article 5(3)(c) of Decree 293, a treaty providing simpler rules or an exemption from authentication prevails over both the Apostille and the legalisation route.
10. The management implication: one transaction may need two document routes
Vietnam’s accession should not be implemented by replacing every “legalisation” item in an internal checklist with “Apostille”. Document workflows should distinguish between:
- Apostille jurisdictions — Convention States with which the Convention operates for Vietnam; and
- exception jurisdictions — Germany, Austria and the Czech Republic (and any other State that objects), where consular legalisation continues.
For German–Vietnamese investment and mobility matters, document-route planning is part of transaction and immigration project management, not a purely administrative step.
11. Transitional rules under Decree 293 (Article 36)
| Situation | Rule | Provision |
|---|---|---|
| Consular-certification applications for Vietnamese documents validly received before 11 September 2026 but not yet completed | Continue to be processed under the consular certification/legalisation rules; use of the result abroad follows the applicable treaty or reciprocity | Art. 36(1) |
| Foreign public documents already legalised by a Vietnamese authority before 11 September 2026 | Remain valid for use in Vietnam; the receiving authority may not require an Apostille for such documents | Art. 36(2)(a) |
| Vietnamese public documents consular-certified before 11 September 2026, now needed in a State with which the Convention operates | The holder may request an Apostille on the same document without obtaining a new original | Art. 36(2)(b) |
| Foreign Apostilles issued before 11 September 2026 by a State with which the Convention operates | Accepted in Vietnam unless a refusal ground applies | Art. 36(3) |
For Germany–Vietnam flows the transitional rules change nothing of substance: documents legalised before 11 September 2026 remain valid, and documents legalised after that date continue to follow the same consular route. The receiving authority’s own rules on validity period and age of documents still apply.
12. Monitoring
The position in this article can change without notice if an objection is withdrawn or a further State objects. ECOVIS Vietnam Law monitors the HCCH status table, the Ministry of Foreign Affairs’ list of States with which the Convention operates, and the guidance of the German, Austrian and Czech missions in Vietnam, and will update this page accordingly.
How ECOVIS Vietnam Law can assist
ECOVIS Vietnam Law provides a Document Passport Vietnam–Germany review for companies and individuals: an inventory of the documents required for the Vietnamese or German procedure, a route assignment for each document (consular legalisation, Apostille where the Convention operates, or alternative evidence subject to the recipient’s confirmation), translation and notarisation sequencing, and a submission-ready file with timeline.
The review covers Vietnamese-side requirements and coordination with German recipients. It does not include German, Austrian or Czech legal advice, notarial acts or registry filings in those States, or any guarantee of acceptance by a foreign authority. Fees are quoted on a case-by-case basis according to the number of documents and procedures involved.
For German companies entering or operating in Vietnam: settle the document route before German documents are executed, notarised or authenticated. For Vietnamese businesses expanding into Germany: identify the German recipient first and confirm its documentary requirements before selecting a certification route.
Request a Document Passport review before your next Vietnam or Germany filing.
Author: Vu Manh Quynh, Managing Partner, ECOVIS Vietnam Law Firm — [email protected]
Frequently asked questions
Does Vietnam issue Apostilles from 11 September 2026?
Yes. Under Decree 293/2026/NĐ-CP the Ministry of Foreign Affairs (or a delegated provincial People’s Committee) issues Apostilles from that date, for use in Convention States with which the Convention operates for Vietnam.
Can I use a Vietnamese Apostille in Germany?
No. Germany objected to Vietnam’s accession on 20 May 2026, so the Convention does not apply between Vietnam and Germany. Legalisation by the German mission in Vietnam remains required, subject to the receiving authority’s requirements.
Can a German company Apostille its documents for a filing in Vietnam?
No. A German Apostille has no Convention effect in Vietnam. German corporate documents for Vietnamese filings continue to require legalisation by the Vietnamese mission in Germany.
Does the same apply to Austria and the Czech Republic?
Yes. Austria (19 June 2026) and the Czech Republic (2 July 2026) lodged the same objection. Consular legalisation continues for document flows between Vietnam and those States.
Do all Vietnamese documents require legalisation before use in Germany?
Not necessarily. Requirements depend on the document and the receiving authority. The German missions recommend checking with the receiving authority whether legalisation is required before starting the procedure.
Does an Apostille certify that the contents of a document are correct?
No. It certifies the origin of the document — signature, capacity of the signatory, seal — not its content, validity or legal effect.
Can Germany’s objection be withdrawn?
Yes, at any time. If it is withdrawn, the Convention will operate between Vietnam and Germany and this page will be updated.
Sources: HCCH Apostille Convention status table and notifications concerning Viet Nam; Decree No. 293/2026/NĐ-CP dated 23 July 2026 (Arts. 4, 5, 6, 30, 34, 36); German Federal Foreign Office, “Das Haager Apostille-Übereinkommen”; German Embassy Hanoi / Consulate General Ho Chi Minh City, “Legalisation öffentlicher vietnamesischer Urkunden”.
Last verified: 4 September 2026. Implementation should be re-checked against official guidance applicable on and after 11 September 2026.
This publication provides general information only and does not constitute legal, tax or accounting advice. Specific transactions and document routes should be reviewed individually.
