
Sworn Translation Explained: Italy, Germany, Spain, Czech, Poland, Brazil 2026
A sworn translation is done by a translator who has taken an oath before a court or government authority in the destination country, which gives the translation legal force in that country. Italy uses Consulente Tecnico d\'Ufficio (CTU) translators on the Italian Embassy New Delhi and Italian Consulate General Mumbai empanelment lists. Germany uses vereidigte Übersetzer registered with each Land court. Spain uses traductores jurados authorised by the Ministerio de Asuntos Exteriores (MAEC). The Czech Republic uses soudni prekladatel, Poland uses tlumacze przysiegli, France uses traducteurs assermentés, Brazil requires Tradutor Público e Intérprete Comercial (TPIC) translation done in Brazil after the document arrives. SiZA Global itself is not a sworn translator. We coordinate the work through translators who hold that status in each jurisdiction.
What is the difference between certified, notarised and sworn translation?
The three words sound similar. They do different things. Knowing which one your file actually needs is the first step in avoiding a rejection at the destination counter.
Certified translation
Translator signs a declaration that the translation is true and accurate. Document is in plain typed format with the translator's name, signature, contact and certification statement attached.
Notarised translation
Translator signs the certification page in front of a notary public. The notary stamps the signature page. The notary is vouching that the translator signed, not that the translation is accurate.
Sworn translation
Translator has taken an oath before a court or government authority in the destination country. The translation carries the translator's court seal and registration. The sworn declaration gives the translation legal force in that country.
Which countries have their own sworn translator systems for 2026?
Each country runs its own list. The translator who is sworn in Madrid is not automatically sworn in Berlin. Below is the practical map of where SiZA coordinates sworn translation and where the work has to happen.
Italy
Traduttore CTU
Court-listed translator (Consulente Tecnico d'Ufficio)
For Embassy of Italy New Delhi and Italian Consulate General Mumbai use, the translator must be on the empanelment list maintained by those offices. For Italian courts, communes and university registries, a CTU translator listed with an Italian court does the translation, then takes the sworn declaration (asseverazione) at the court. The asseverazione page is what carries the apostille for Italy files, not the translation pages themselves.
Germany, Austria, Switzerland (partial)
Vereidigter Übersetzer
Court-sworn translator
Required for Standesamt marriage registration, Notar acts, Approbation for doctors, German university registries and most German court use. Each German state (Land) maintains its own list. Austrian Beeideter Dolmetscher and some Swiss cantonal lists work similarly. Translations carry the translator's court-issued seal and a sworn certification.
Spain
Traductor Jurado
Court-authorised sworn translator
Authorised by the Spanish Ministry of Foreign Affairs (MAEC). The translator stamps and signs the translation; that stamp gives it legal force in Spain. Required for civil registries, university nostrification, NIE-related applications and most Spanish court use.
Czech Republic
Soudní tlumočník
Court-appointed translator and interpreter
Court-registered translator under Czech Act No. 354/2019 Sb. Required for university nostrifikace, employment files, residency files and Czech court use. The sworn translation carries the translator's registration number and round seal.
Slovakia
Úradný prekladateľ
Authorised translator
Authorised by the Slovak Ministry of Justice under Law No. 382/2004 Z.z. Required for nostrifikácia at Comenius University Bratislava, Slovak Health Care Surveillance Authority licensing, residency and Slovak court use.
Slovenia
Sodno zapriseženi prevajalec
Court-sworn translator
Authorised by the Slovenian Ministry of Justice. Required for ENIC-NARIC Slovenia recognition at the Ministry of Higher Education Science and Innovation, Upravne enote residence permits, Slovenian medical (Zdravniška zbornica) and nursing chamber files, and Slovenian court use.
Poland
Tlumacz przysiegly
Sworn translator
Authorised by the Polish Ministry of Justice. Required for Karta Pobytu, university files, civil registry, court use. The translation carries the translator's court registration number.
France, Belgium, Quebec
Traducteur assermenté
Sworn translator
Court-appointed in France (Cour d'Appel), Belgium and Quebec (where the destination case requires it). Used for French civil registry, university and Quebec immigration files where sworn status is required.
Hungary
OFFI hiteles fordítás
OFFI-certified translation (Országos Fordító és Fordításhitelesítő Iroda)
OFFI is the Hungarian state translation office. Hungarian law reserves certain official translation categories (civil registry, naturalisation, court use, Stipendium Hungaricum scholarship documents) to OFFI. Private sworn translators do not have parallel authority for those categories.
Romania
Traducător autorizat
Ministry of Justice authorised translator
Translator authorised by the Romanian Ministry of Justice on Order No. 233/C/1996 register. For notarised use the translation is also countersigned by a Romanian notary public. Required for residence permits, university enrolment at Bucharest, Cluj-Napoca, Timișoara and Iași, and Romanian medical universities.
Japan
No national sworn-translator register
Certified translation with translator declaration
Japan does not maintain a national sworn-translator register the way Germany or Spain do. Translations for Japanese government use carry the translator's declaration; where a public Japanese document is involved, notarisation followed by apostille is the legal-recognition path. Apostille is the route since Japan joined Hague.
China (post Hague Nov 2023)
公证处 (gōngzhèngchù) notarisation
Chinese notarial office certification
China joined the Hague Apostille Convention effective November 2023, replacing the old Chinese Embassy legalisation process. For Chinese-issued documents going abroad, the gōngzhèngchù (公证处) handles in-China notarisation. For India-issued documents going to China, MEA apostille is what the destination reads; Chinese translation is commissioned per the destination authority's expectation.
Brazil
Tradutor juramentado (TPIC)
Sworn public translator and commercial interpreter
Brazil is the unusual case. India-side translation is not accepted for Brazilian government use, even certified translation. The Brazilian government requires a TPIC (Tradutor Público e Intérprete Comercial), who must be a Brazilian citizen, civil-service-licensed, and resident in Brazil. India-side work is limited to apostille and the English source. Translation has to happen in Brazil after the document lands.
What do customers usually get wrong about sworn translation?
We hear these in WhatsApp every week. Naming them upfront saves a lot of time.
Often heard
Certified, sworn and notarised mean the same thing.
What is actually true
They do not. Certified is a translator declaration. Notarised is a notary witnessing the translator's signature. Sworn is a court-authorised translator in the destination country. The receiving authority decides which one applies.
Often heard
If a translator is qualified, the translation will be accepted anywhere.
What is actually true
Sworn status is jurisdiction-specific. A Spanish jurado is not automatically a German vereidigter. A German vereidigter is not automatically a Czech soudni. Each destination authority recognises its own court-authorised list.
Often heard
India has sworn translators that work for any country.
What is actually true
India has Embassy-empanelled translators for some countries (Italian Embassy, for example). India does not have a general system of cross-jurisdiction sworn translators. For Spain, Germany, Czech, Slovak, Slovenian, Polish and Brazilian use, the sworn translation often happens in the destination country.
Often heard
The translation itself gets apostilled.
What is actually true
Usually the apostille goes on the original Indian document, or on the SDM, HRD or Chamber attestation before it. For Italy, the sworn declaration page (asseverazione) is what gets the apostille, not the translation pages. For some Mexican use, the destination may ask the translation to be apostilled separately, by a destination-authorised translator. The order varies by country.
Often heard
ISO 17100 means a translation company can provide sworn translation.
What is actually true
ISO 17100 is a quality management standard for translation services. It is not the same as sworn status. A company can be ISO 17100 certified and still not provide sworn translation in any specific country.
Often heard
A sworn translation done five years ago will still be accepted.
What is actually true
Some destinations have a freshness rule, especially for civil registry and immigration use. Germany Standesamt often wants sworn translations within a 3 to 6 month window. Plan the sworn translation close to the actual filing date.
Does the apostille go on the original or on the sworn translation?
Most customers assume the apostille goes on the translation. It usually does not. The apostille goes on the original Indian document, or on the SDM, HRD or Chamber attestation that came before it. The sworn translation is a separate step on top.
Italy is a special case. The translator goes to an Italian court and signs the sworn declaration (asseverazione). The asseverazione page is then apostilled. The translation pages themselves are not the apostille target.
Brazil is another special case. Apostille happens in India on the original document. The TPIC translation in Brazil happens after the document lands. There is no India-side apostille on the Brazilian sworn translation.
Order of work for common destinations
- Italy: Indian original → Notary → HRD or Home Attestation (educational and family docs) → MEA apostille → Italian Embassy / Consulate empanelled translator → asseverazione at Italian court → asseverazione page may be apostilled separately for some uses.
- Germany: Indian original → SDM or HRD as document type asks → MEA apostille → German vereidigter Übersetzer in Germany.
- Spain: Indian original → SDM or HRD as document type asks → MEA apostille → Spanish traductor jurado in Spain.
- Czech Republic: Indian original → SDM or HRD → MEA apostille → Czech soudni prekladatel in Czech Republic.
- Brazil: Indian original → SDM → MEA apostille (India side). Translation by Brazilian TPIC after document lands in Brazil.
How does a sworn translation order move through SiZA?
Five steps. Honest about what happens at each.
Document and destination check
WhatsApp scan, destination country, receiving authority, deadline.
Sworn jurisdiction confirmed
We confirm which country's sworn list applies and whether the sworn step happens in India or in the destination country.
India side first
Notary, SDM or HRD where the document type asks, MEA apostille, certified English translation if the source is in regional language.
Sworn translation
India-side empanelled translator (Italy), or destination-country sworn translator (Germany, Spain, Czech, Polish, French, Brazil).
Return and proof
Photo and video proof of the completed sworn translation, tracked courier back to your address.
What does SiZA not promise on sworn translation?
Sworn translation sits in a fussy part of the documentation world. Customer-facing claims have to be careful. SiZA is not on any embassy empanelment list. We are not a sworn translator in any country. We coordinate sworn translation through translators who do hold that status. This is the honest version, and the brand stands on it.
We will not pretend a certified translation will pass where the destination authority has asked for sworn. We will not skip the destination-country sworn step on a Spanish jurado, Czech soudni or Polish przysiegly file. We will not run a Brazilian file with India-side translation when Brazil only accepts TPIC.
Where we draw the line
- No claim that SiZA itself is empanelled or sworn anywhere.
- No claim of ISO 17100 status. SiZA does not hold that certification and we will not pretend.
- No claim of NAATI status. NAATI is an Australian system; SiZA is not on it.
- No fixed timeline that we cannot honour. The sworn translator\'s queue is real.
- No promise on destination authority acceptance. We bring the file to the standard. The authority decides.
Frequently asked questions
What does sworn translation actually mean?
It means the translation was done by a translator who has taken an oath before a court or government authority in the destination country. That oath gives the translation legal force in that country. Italy uses CTU translators. Germany uses vereidigte Übersetzer. Spain uses traductores jurados. Czech, Slovak, Slovenian, Polish, French and other systems each have their own court-authorised list. The translation carries the translator's court-issued seal, registration number and sworn declaration.
Is SiZA a sworn translator?
No. SiZA itself is not a sworn translator in any jurisdiction. We will not claim that we are. What we do is coordinate sworn translation through translators who hold that court-authorised status, in India where the Embassy maintains an empanelment list (Italy), and abroad where the destination court does (Germany, Spain, Czech, Polish, Brazilian, French).
Where can sworn translation happen in India?
For Italy, the Italian Embassy in New Delhi and the Italian Consulate General in Mumbai maintain a list of empanelled translators in India. Most Italy files can have the sworn translation done in India. For Germany, Spain, Czech, Slovak, Slovenian, Polish and Brazilian use, the sworn step typically has to happen in the destination country itself. We coordinate either way.
When do I need sworn translation versus certified translation?
The receiving authority decides. A Spanish civil registry, an Italian university DoV counter, a German Standesamt or a Polish Karta Pobytu office will tell you they need sworn translation in their own language. USCIS, IRCC, most Schengen visa offices, most Australian and Canadian credential evaluators accept certified translation. For files going to Saudi MOFA, UAE MOFA, Qatar MOFA, certified Arabic translation is the usual format, sometimes with notarisation. Send us the document and the destination, and we confirm.
My Italian file says translation by an Italian Embassy empanelled translator. Are you empanelled?
No. SiZA itself is not on the Italian Embassy New Delhi or Italian Consulate Mumbai empanelment list. What we do is work closely with the translators who are. The file is routed through one of them so the Embassy or Consulate accepts the translation when it lands.
For Brazil, can I get the Portuguese translation done in India?
No. Brazil is the unusual case. India-side translation, even certified by a senior Indian translator, is not accepted by Brazilian government use. The Brazilian system requires a TPIC (Tradutor Público e Intérprete Comercial), who must be Brazilian, civil-service-licensed, and resident in Brazil. India-side work for Brazil files is limited to the apostille. Translation has to happen in Brazil after the document lands.
Does a sworn translator have to be a lawyer?
No. A sworn translator is a translator who has taken an oath before a court or a government body. They are not lawyers. They are linguists with court-authorised status. The oath certifies their translation, not their legal advice.
How long does sworn translation take?
It depends on the destination, the document length and the sworn translator's queue. India-side sworn options (Italian Embassy empanelled translators) usually move within 5 to 10 working days. Destination-country sworn translation (German vereidigter, Spanish jurado, Czech soudni, Polish przysiegly) depends on the translator's schedule in that country, typically 5 to 15 working days. Brazilian TPIC turnaround depends on the city in Brazil. We get a real-time estimate from the translator before we accept the file.
Related desks
Reviewed by SiZA Global documentation desk. Last updated 23 May 2026. Sworn translator lists, court registrations and destination-country acceptance rules change without notice; we re-verify against the receiving authority before accepting each file. Brazil TPIC and Italian Embassy empanelment specifically have hard country-side requirements that India-side translators cannot substitute.
Tell us the destination country. We will tell you where the sworn step actually happens.
WhatsApp the document scan, the destination country and the receiving authority. We confirm whether the sworn step is in India (Italian Embassy empanelled) or in the destination country (German vereidigt, Spanish jurado, Czech soudni, Polish przysiegly, Brazilian TPIC), and we coordinate.