Electronic notarial certificates and digital apostille: how they work, and who accepts them
Since 2021, a notary in Israel may issue a notarial certificate as a PDF file signed with a certified electronic signature, instead of a paper document with a seal. The electronic certificate can be authenticated with a digital apostille from the Ministry of Justice, and both can be sent by email anywhere in the world. Where the applicant's signature is required, the applicant still appears before the notary in person. The question that really matters is whether the body receiving the document is willing to accept a file.
What is an electronic notarial certificate?
The Notaries Regulations were amended by an amendment published on 21 February 2021 (Regulations File 9196). The amendment added regulation 19A, which allows a notarial certificate to be issued by electronic means, and regulation 26A on an electronic archive. The certificate is signed with the notary's certified electronic signature, as defined in the Electronic Signature Law, 5761-2001, and bears an electronic seal instead of the physical seal. Under the Ministry of Justice guidelines:
- It is an option, not an obligation. You can choose between a paper certificate and an electronic one.
- A certificate that requires the applicant's signature, such as signature authentication, an affidavit or a power of attorney: the applicant appears before the notary and signs in their presence, with a handwritten signature that the notary scans or with an electronic signature (regulation 19A(1)). There is no video conferencing here. The notary identifies the applicant and makes sure they are acting of their own free will and understand the document, exactly as with a paper certificate.
- A certificate without the applicant's signature, such as a certificate of translation accuracy: there is no obligation to appear. The notary attaches to the certificate the document translated or a photocopy of it (regulation 15(c)), and in an electronic certificate states the name of the attached file (regulation 19A(3)). The strength of the certificate depends on the source it was translated from, as explained just below.
- The certificate is delivered as a file, by email or by other electronic means. The file can be forwarded to as many bodies as needed, without ordering additional copies.
- The notary's fee is the same as for a paper certificate, under the Notaries (Service Fees) Regulations.
- A single document is either electronic or paper, not both. Anyone who needs both forms receives two separate certificates, each with its own number.
In a certificate of translation accuracy, the notary states in the certificate what the translation was made from. There are three options, from the strongest to the weakest:
- Translation from the original. The original is shown to the notary, and the certificate states that the attached copy is a true copy of the original. This is the strongest certificate, and it requires bringing the original to the office.
- Translation of a digitally signed document, for example a certificate issued as a signed file. The notary translates from the file sent to them, and the certificate says so. This is possible both with an ordinary paper certificate, where the notary prints the file and translates from it, and with an electronic certificate. Either way there is no need to come in: you send the file and receive the certificate by post, or by email as an electronic certificate, with a digital apostille if needed.
- Translation of a photocopy or scan. The certificate states that the translation was made from a photocopy. This is the weakest option, so it is worth confirming in advance that the receiving body accepts it.
A file, not a page: why a printout is not enough
Under the regulations, a paper printout of an electronic notarial certificate is regarded as a copy only, and the certificate itself states that a hard copy does not constitute a notarially signed certificate. The original is the signed file. So you send the receiving body the file as received from the notary. Do not print and scan it, and do not re-save it in another program: editing or re-saving may invalidate the digital signature.
This point matters to the authorities too. The State Comptroller's report on apostilles (2026) found that the Ministry of Foreign Affairs had issued apostilles on printouts of electronically signed documents without checking the signed file, and held that such a certificate does not meet the requirements of the Hague Convention. A digital document is authenticated digitally.
What is a digital apostille?
An apostille is a certificate under the Hague Convention of 1961 confirming that the signature on the document is that of an authorised notary, and it removes the need for consular legalisation. The full explanation is on the apostille page. A digital apostille is the same certificate, as an electronically signed file attached to the document.
For an electronic notarial certificate, the competent authority for the digital apostille is the Ministry of Justice. According to the Hague Conference implementation chart, Israel has issued electronic apostilles since 21 December 2021, under Israel's notification to the Hague Conference, and it has an online register for verification. This is how it works:
- The notary prepares and signs the electronic certificate.
- The notary files an online application for a digital apostille with the Ministry of Justice at apostillenotary.justice.gov.il, and a fee is paid.
- The apostille is received as a signed file, and the applicant receives the certificate and the apostille by email. There is no need to go to the court.
- The recipient abroad can check the apostille in the Ministry of Justice's register of electronic apostilles, eregister.justice.gov.il. The notary's digital signature can be checked with suitable PDF software, such as Adobe Acrobat Reader, according to the Ministry of Justice guide.
A digital apostille is issued only for a certificate made as an electronic certificate from the outset. A paper certificate cannot be scanned and submitted for a digital apostille. A paper notarial certificate receives an apostille at the court registry, as before.
The Ministry of Justice also issues digital apostilles for government certificates issued digitally, for example a bilingual birth certificate, a population registry extract, a police certificate, an inheritance order and a Land Registry extract. These are ordered directly on gov.il, without a notary.
Which countries accept a digital apostille?
The Hague Convention applies between 130 countries and territories. There is no official list of countries that "accept" a digital apostille. In 2021 a Special Commission of the Hague Conference stated in its recommendations that an apostille duly issued in a member state must be accepted in every other member state, regardless of its format, and encouraged states to take steps to ensure that electronic apostilles are accepted.
In practice, the decision lies with the receiving body. Some authorities, banks and consulates still require a paper document with a stamp, and some have systems that do not accept a signed file. The Ministry of Justice also recommends checking in advance whether the authority in the destination country accepts documents in electronic format.
A good sign that a country recognises the format is that it issues electronic apostilles itself. According to the Hague Conference implementation chart, these are among the countries that issue electronic apostilles, in some cases only some of their authorities:
| Region | Countries |
|---|---|
| Europe | Spain, Austria, Belgium, Denmark, Estonia, Latvia, Slovenia, Greece, Bulgaria, France (from 2025, some authorities), Luxembourg, United Kingdom, Moldova, Ukraine, Turkey, Georgia, Armenia |
| The Americas | United States (some states), Mexico, Colombia, Chile, Brazil, Peru, Argentina, Uruguay, Ecuador, Bolivia, Guatemala, El Salvador, Dominican Republic, Panama, Venezuela |
| Asia and Oceania | New Zealand, South Korea, China and Hong Kong, Singapore, the Philippines, Kazakhstan, Uzbekistan, Mongolia, Bangladesh, Bahrain |
| Africa | Rwanda |
The list does not guarantee that every body in these countries will accept a file, and a country not on the list does not necessarily reject a digital document. What decides is the answer of the receiving body.
A country that is not party to the Hague Convention: there is no apostille there at all. A notarial certificate for such a country is made on paper and authenticated with a stamp of the Courts Administration.
Which bodies in Israel accept an electronic notarial certificate?
Legally, an electronic notarial certificate signed with a certified signature is equivalent to a paper certificate. So wrote the head of the professional regulation department at the Ministry of Justice, in the announcement of the cooperation with Bank Mizrahi-Tefahot. The practical question is whether the receiving body is set up to accept a file.
- Bank Mizrahi-Tefahot has accepted, since March 2023, a mortgage power of attorney with an electronic notarial signature authentication, which the notary transmits to the bank online. It was the first bank to do so. However, since the amendment to the law allowing ordinary signature authentication on a mortgage power of attorney for a bank, interest in a digital notarial certificate for this purpose has declined.
- Other bodies known to accept an electronic certificate include, among others, the Registrar of Inheritance, the Land Registrar, the Ministry of Health and the Ministry of Education. Each has its own method of submission, and not every procedure at every body is open to it.
- Most bodies in Israel are not yet set up to accept a digital notarial certificate, and there is no official, up-to-date list of those that are. A body that requires an original document to be handed in at a counter or by post will treat a printout of the file as a copy only.
So before ordering a certificate, it is worth asking the receiving body one question and getting a written answer: do you accept a PDF file of a notarial certificate signed with a certified electronic signature, and how is it submitted? If the answer is unclear, a paper certificate is the safe choice.
When to choose a digital certificate and when paper?
| The situation | What fits |
|---|---|
| The document is being sent to a Hague Convention country, and the receiving body has confirmed in writing that it accepts files | An electronic certificate with a digital apostille. No international courier and no trip to the court |
| The receiving body requires a paper original, or it is not known what it accepts | A paper certificate, with a court apostille if required |
| The country is not party to the Hague Convention | A paper certificate and authentication by the Courts Administration |
| The document is needed both on paper and as a file | Two separate certificates, each with its own number |
Electronic certificates at our office
At the notary office of Amos Ilan in Ness Ziona you can obtain an electronic notarial certificate and a digital apostille on it, without going to the court. For a certificate that requires a signature you come to the office once. For a translation of a digitally signed document or of a photocopy there is no need to come in: you send the document through the form on the translation page. For a translation from the original, you bring the original to the office. In both cases the certificate and the apostille are sent by email. The notary's fee is set by regulation and is the same as for a paper certificate (see the fees page), and the Ministry of Justice fee is added for the apostille. The requirements of the receiving body, including whether it accepts an electronic certificate, should be checked with it before ordering.
Sources
- Ministry of Justice: Guidelines for preparing notarial certificates and documenting notarial acts electronically
- gov.il: Preparing an electronic notarial certificate and authenticating it with a digital apostille
- gov.il: Authentication of government certificates with a digital apostille
- Israel's notification to the Hague Conference on the electronic apostille (2022)
- Ministry of Justice: Digital notarial certificate service at Mizrahi-Tefahot (2023)
- HCCH: e-APP Implementation Chart
- HCCH: Conclusions and Recommendations, Special Commission 2021
- State Comptroller: Report on the issue of apostille certificates, 2026
More on this topic: Apostille | Certified translation | Signature authentication | What to bring to a notary | Which certificate a document needs
Questions and answers
Can I get an electronic notarial certificate without coming to the notary?
It depends on the type of certificate. Where the applicant's signature is required, as in signature authentication, an affidavit or a power of attorney, the applicant appears before the notary in person, and this cannot be done by video call. In a certificate of translation accuracy the applicant does not sign. When a digitally signed document or a photocopy is translated, you can send it and receive the certified translation by email, and the certificate states what it was translated from. Translation from the original, which is the strongest certificate, requires the original to be shown to the notary.
I printed the electronic certificate. Is the printout valid?
Under the regulations, a paper printout of an electronic notarial certificate is a copy only. The original is the signed file, and that is what you send to the receiving body.
Does the digital apostille replace the court apostille?
Only for an electronic certificate. A paper notarial certificate receives an apostille at the court registry, and an electronic certificate receives a digital apostille from the Ministry of Justice.
How does the recipient abroad know the apostille is genuine?
Every electronic apostille Israel has issued appears in the Ministry of Justice's register of electronic apostilles, eregister.justice.gov.il, where it can be checked.
