Certify / Attest / Beglaubigen

I’ve been writing a lot in German about the use of the word ‘beglaubigen’ (certify) for translations, and forgetting to discuss how to translate some of these terms into English, as Adrian reminds me in a comment.

There is a Beurkundungsgesetz in Germany. It is all about notaries. I have translated it, sometimes, as Notarial Recording Act. Neither Dietl nor Romain has it, nor von Beseler – Jacobs-Wüstefeld. It is often translated as ‘Documents Act’, which I don’t much like.

German notaries either beurkunden or beglaubigen. If they beglaubigen (öffentliche Beglaubigung), they certify / witness a signature. Or attest. If they beurkunden (öffentliche Beurkundung), or record (the best word I’ve found, but not very transparent, unfortunately), they produce a whole document.

So I normally say:

|Beurkundungsgesetz|Notarial Recording Act|
|öffentliche Beglaubigung|notarial certification|
|öffentliche Beurkundung|notarial recording|

I don’t like to use notarization. Reasons: firstly, the term is associated in the US with a notary public’s witnessing of a signature, and so conjures up the idea of a different kind of notary. In addition, it is not clear whether beglaubigen or beurkunden is meant. – Of course, the word notarization works perfectly well in context, if one is careful – I’m just setting out my own objections.Now, what does authentication mean? I ask myself. Collins says ‘1. to establish as genuine or valid, 2. to give authority or legal validity to’
So it would be a synonym for certification. As would attestation – as you say, mainly used in connection with wills.

When it comes to the apostille and legalization, the Germans use the word Apostille. They also talk of Überbeglaubigung. I think strictly speaking they use it, for example, where the President of the Landgericht where I am registered as a sworn translation confirms that I have authority to certify a translation, which is not an apostille but is similar. So let’s say legalization = Überbeglaubigung.

I found a site saying ‘Why apostille with us?’ and giving some information, with graphics.

A topic for another time is: what is an original and what kinds of copies exist.

There’s a large sort of translators’ bible in German with 114 articles on all kinds of translation. It’s called Handbuch Translation, ISBN 3 86057 991 6 – dated 1998, but there may be a new edition. There is an article in there about Urkundenübersetzung by Klaus Fleck, who is responsible for the Doucet-Fleck DE>FR and FR>DE dictionary – I use the DE>FR to find Swiss German. He’s an interesting speaker. He lived in France from the age of ten and studied law in France, but lives in or near Munich. He, btw, refers to ‘beglaubigte Übersetzung’!

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