UK Notaries Public – How they differ from US Notaries – Part 1

As a UK Notary in London, I am often contacted by US citizens requesting a notarial service such as legalising a document, witnessing a document or issuing an apostille.

A UK Notary Public greatly differs from a US Notary however, so at M D Pryke Notary Public we have decided to produce a series of articles illustrating the difference between US and UK Notary services.

1. Notaries Public Status

US Notaries are not regarded as a public authority.

A UK Notary is deemed to be a public official. Therefore, documents which have been notarized by a UK Notary Public can subsequently be legalised.  This process of legalisation is completed by the Foreign and Commonwealth office adding an apostille, or, alternatively, through various UK embassies.

2. Notary qualifications

 

In the United States of America, a Notary does not have to be legally qualified.  A US Notary may purchase their entitlement for a limited period.

A Notary Public in the UK is most often a lawyer too.  It is technically possible to qualify as a UK Notary without being, say, a Solicitor or Barrister, but one must sit an extensive series of examinations at considerable expense.

3. Notarial Commissions

In the United States a notary will pay a fee to practice for a predetermined length of time.  This period is referred to as the ‘commission’. For this reason, all US Notaries must include a reference to the expiry date of their commission.

British Notaries are qualified for an indefinite period.  Although English Notaries Public are issued with annual practicing certificates by their governing body, the Faculty Office, they are effectively a Notary for life.

To avoid any potential miscommunication, at M D Pryke Notary Public we include the phrase ‘my commission expires with life’ on all notarised documents pertaining to the United States.

For further information on the differences between UK Notaries and their North American counterparts please see other articles in this series, or alternatively contact us through the usual channels.

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Comments

  1. Kevin Burke  April 20, 2010

    Great series of articles. As both an English notary public and US notary, I see these issues you address all the time.

  2. Dave Rigby  June 7, 2010

    Hi quick Q? for you if you would. I am a real Estate agent in the U.S.A. A lot of my clients are buyers from the U.K. and often need notary services for their mail away closing docs they sign within the U.K. Would a U.S Notary public be able to notarise within the U.K. for their docs or does the law prevent it?
    I have been posed this interesting Q? more than once.
    Apreciated. Dave R

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