If you have ever dealt with a notary public in the United States, you might be surprised by how different the experience is in Ireland. Despite sharing the same title, Irish and American notaries public operate under fundamentally different systems with different qualifications, authority, and international recognition. This guide explains the key differences and why they matter for your documents.
The Fundamental Difference
The most important difference can be summed up simply: in Ireland, a Notary Public is a highly qualified legal professional appointed by the Chief Justice. In the United States, a notary public is typically a lay person who has completed a basic application process with minimal training requirements.
This fundamental difference affects everything — the scope of services, the level of legal review, the fees charged, and crucially, the international recognition of the notarial act.
Qualifications and Training
Ireland
- Must be a qualified solicitor or barrister with a law degree
- Must complete the Diploma in Notarial Law and Practice from the Faculty of Notaries Public in Ireland
- Must be appointed by the Chief Justice of Ireland
- Appointment is for life
- Must demonstrate there is a need in their area
- Total training: typically 7+ years of legal education and professional qualification
United States
- Requirements vary by state but are generally minimal
- In many states, you only need to be 18+, a resident, pass a background check, and complete a short course or exam
- No legal degree or legal training is required
- Appointments are typically for a fixed term (usually 4–10 years, renewable)
- Some states require as little as a few hours of training
- There are approximately 4.4 million notaries in the US
Scope of Authority
Irish Notary Public
- Authenticates documents for international use
- Prepares notarial certificates and attestations
- Reviews documents for legal compliance
- Verifies identity through rigorous due diligence
- Administers oaths and affirmations
- Certifies true copies
- Provides legal advice on notarial matters
- Maintains a notarial register (protocol) of all acts performed
US Notary Public
- Primarily witnesses signatures
- Administers oaths
- Certifies copies (in some states)
- Cannot provide legal advice
- Cannot prepare legal documents
- Identity verification is typically limited to checking a government-issued photo ID
Fees
The fee difference reflects the vastly different levels of service:
- Ireland: Notarisation fees typically range from €65 to €150+ per document, reflecting the legal expertise, thorough review, and international authentication provided
- United States: Notarisation fees are often capped by state law at very low levels — many states cap fees at $2–$15 per signature. Some states allow higher fees for mobile notary services or remote online notarisation
International Recognition
This is perhaps the most practically important difference. Irish notarial acts carry full international recognition because:
- The Irish notary system is rooted in the civil law notarial tradition recognised worldwide
- Irish notaries are members of the International Union of Notaries (UINL) through the Faculty of Notaries Public in Ireland
- The appointment by the Chief Justice and the rigorous qualification requirements give Irish notarial acts significant legal weight
US notarial acts, while valid domestically, may face acceptance issues internationally, particularly in civil law countries (most of continental Europe, Latin America, Asia, and Africa). This is because authorities in these countries expect notarial acts to come from qualified legal professionals, not lay persons.
Remote Online Notarisation (RON)
One area where the US is ahead of Ireland is remote online notarisation. Many US states now allow notarisation via video call using identity verification technology. Ireland does not currently permit remote notarisation — in-person attendance before the notary is required. See our article on online notarisation in Ireland for more details.
Practical Implications
If you are an American in Ireland or an Irish person dealing with US documents, here's what you need to know:
- In Ireland needing US documents: Use an Irish Notary Public. The Irish notarial act will be accepted in the US, particularly with an apostille.
- In the US needing Irish documents: Use a US notary, then have the document apostilled by the relevant US state authority. Note that some Irish authorities may require additional verification.
- US Embassy in Dublin: The US Embassy provides certain notarial services for US citizens in Ireland, particularly for documents that need to comply with specific US requirements.
Need a Notary in Cork?
Hugh Phelan, Solicitor and Notary Public in Douglas, Co. Cork, regularly handles documents for use in the United States and can advise on the specific requirements for your situation.
Contact us at 021-489-7134 or info@phelansolicitors.com, or book an appointment online.
Looking for a Notary Public in Cork?
Hugh Phelan is a Solicitor & Notary Public appointed by the Chief Justice of Ireland. Same-day appointments available.
Notary Public Cork — Book Now📞 +353-21-489-7134 · East Douglas Street, Douglas, Cork