Notary
From Civil law (Latin notary)
Legal professionsProperty
What it means
In civil-law countries, a notary is a trained legal professional and a public officer. They draft and authenticate important documents, such as property sales, wills and company documents, which then have special legal force.
Why it travels badly
In most common-law countries a 'notary public' mainly witnesses signatures and needs little or no legal training. The same word describes very different jobs. In England the 'scrivener notary' is closer to the continental model.
How other systems say it
notaire / Notar
A law-trained public officer. An authenticated deed carries stronger evidential and enforcement value, and the notary is often required for property transfers.
notary public
Usually witnesses and certifies signatures. No law degree is required in most states.
notario / escribano
Follows the Latin model, with authentic deeds and a public role.
Tip for translators and students
Never translate 'notaire' as 'notary public' without a note: a lawyer from a common-law country may think the person only witnesses signatures.
Related: Prosecutor
Updated October 2026. Spotted a mistake? Tell us.
TheLawToKnow Tools’s glossary is an educational overview of the main differences between legal systems. It is not legal advice.
