A power of attorney, a consent or an undertaking signed in London, Lyon or Montreal for use in Türkiye can take two very different shapes: a deed made by a local notary, or a notarial act made at a Turkish consulate. The two documents are built differently and travel differently. This page describes the consular act, how it is used in Türkiye, and when it needs a translation at all.
Consuls carry out notarial work abroad
Article 191 of the Notaries Law provides that notarial affairs in foreign countries are carried out by consuls. Under Article 192, this work is done inside the consulate building and in accordance with the provisions of the Law on notarial acts. A consular act is therefore a Turkish notarial act made abroad, not a document of the host country.
The same form rules
Article 193 lists, by exclusion, the provisions that apply to consuls: everything outside Articles 41, 51, 53, 54, 55, 60, 61, 68 to 70, 72 to 76, 78 to 108, 113 to 116, 198/A and the fourteenth part does not apply to them. Read the other way round, the form rules for deeds drawn up by the notary (Articles 84 to 89), signature certifications (Articles 90 to 93), copies, translations (Article 103) and notices (Article 106) apply at the consulate as they do in Türkiye. A power of attorney drawn up at a consulate carries the same record elements: place and date in figures and words, identities, declaration, reading note, signatures and seal.
An interpreter at the consulate
Because Articles 72 to 76 are among the provisions that apply, so does the rule of Article 74: a party who does not know Turkish is assisted by a sworn interpreter, whose identity and address go into the record. A later written translation renders that passage as it stands and does not replace the interpretation given at the signing.
What differs on the page
The parts that differ from a document made by a notary in Türkiye concern the authority: the consulate’s name in place of the notary’s office, for example a Consulate General of the Republic of Türkiye in a named city; the consular officer’s name and title in place of the notary; the journal or register number; and the consular seal. The rest of the document follows the elements of the form used, whether a record drawn up by the officer or a signature certification.
Used in Türkiye without further certification
A Ministry of Justice opinion reproduced by the Union of Turkish Notaries states that a notarial act performed by a Turkish consulate can be used in Türkiye without certification by any other authority (Consolidated Circular 25, para. 6). A consular document drawn up in Turkish and used in Türkiye does not need translating. A translation becomes necessary when the same document is also shown to a foreign authority, bank or court; in that case the consulate’s name, the officer’s title and the register number open the translation.
Honorary consulates
Where the issuing office is an honorary consulate, the word “honorary” (fahri) stays in the translation without exception: Turkish civil registry offices do not act on documents issued by honorary consulates (Civil Registry Services Implementing Regulation Article 59/3). The difference between a consulate general and a consulate is kept as well; neither is corrected or merged.
A foreign notary’s deed is a different document
A deed made before a notary of the host country is not a consular act. Under Article 195, the signature and seal of the competent foreign authority under such a notarial act are certified by the Turkish consul, with special laws reserved; for States party to the 1961 Hague Apostille Convention, the apostille takes the place of that certification (Consolidated Circular 25, para. 1). When such a deed comes to Türkiye, the foreign notary’s text and every certification under it are translated together, because the certification is part of the document. Acte Tercüme translates consular notarial acts and foreign notarial deeds between Turkish, English and French, with the consulate’s name, the officer’s title and the register number included.