notarisation

noun · notarielle Beurkundung

Notariell beurkundet or notariell beglaubigt, and the gap between the two words is § 125 BGB, nullity. Beurkundung is the full ceremony, content, advice and record, § 128 BGB, § 17 BeurkG, Beglaubigung merely certifies a signature, § 129 BGB, and the machine reaches for the smaller word where the deal needs the larger one.

Which translation, when

notarielle Beurkundungthe heavy form, § 128 BGB, the notary records the whole transaction, reads it back, § 13 BeurkG, and advises, § 17 BeurkG. Required where statute says so, land deals, § 311b BGB, GmbH share transfers, § 15 GmbHG.

notarielle Beglaubigungthe light form, § 129 BGB, the notary certifies that a signature is genuine and nothing more. The right level for commercial register filings, § 12 HGB, and for certified copies.

Why

English notarisation is a light ceremony, a notary public witnesses and stamps, and the word carries no hierarchy. German law splits notarial involvement into two levels with a cliff between them. The Beglaubigung of § 129 BGB authenticates a signature, the document’s content is not the notary’s business. The Beurkundung of § 128 BGB is the full procedure, the notary drafts or records the transaction itself, reads it aloud, § 13 BeurkG, and must advise the parties, § 17 BeurkG, and statute prescribes exactly this level for the deals it distrusts, the land purchase of § 311b BGB, the GmbH share transfer and even the promise of one, § 15 Abs. 3 und 4 GmbHG. The cliff is § 125 BGB, the transaction that needed Beurkundung and got only a certified signature is void. So notarised translated as notariell beglaubigt is not a smaller version of the truth, in the wrong deal it is a description of a nullity, and the German office behind both words, the Notar as an impartial holder of public office, is itself larger than the English notary public the machine has in mind.

Typical mistakes

Notariell beglaubigt for a transaction that needs Beurkundung describes a form failure, § 125 BGB, the signature was genuine and the deal is void.
A German Notar is not a notary public with a nicer office, the Beurkundung carries drafting and advice duties, § 17 BeurkG, and whether a foreign notary can substitute is a question of equivalence German case law polices deal by deal.
Beglaubigung is right at its own level, commercial register filings run on it, § 12 HGB, and upgrading every mention to Beurkundung overshoots the statute and the fee schedule.

What matters

Share deals over a German GmbH put the two words to the test: the English SPA says the transfer will be notarised, the German version must say notariell beurkundet, § 15 Abs. 3 GmbHG. Rendered as notariell beglaubigt the clause promises a certified signature, the statute demanded the full ceremony, and § 125 BGB prices the difference at the validity of the transfer.

Authority

§ 125 BGB
§ 128 BGB
§ 129 BGB
§ 13 BeurkG
§ 17 BeurkG
§ 311b Abs. 1 BGB
§ 15 Abs. 3, 4 GmbHG
§ 12 HGB

What the machine misses

Notarisation drifts to beglaubigt in machine output, the dictionary’s first offer, and the German hierarchy of forms collapses into its lower rung. Where the transaction needed the full notarielle Beurkundung the output certifies a signature and skips the ceremony the statute was pointing at, and the reader holds a document that names precisely the form failure that would kill the deal.

Examples

notarised	notariell beurkundet
a notarised copy	eine beglaubigte Abschrift
to have the signature notarised	die Unterschrift notariell beglaubigen lassen
the sale was notarised	der Kaufvertrag wurde notariell beurkundet