What is three-step authentication?

Three-step authentication refers to consular authentication. Put simply, it means a Chinese consulate in the United States can certify that documents issued by relevant U.S. authorities are genuine. More formally:

The embassy may authenticate notarized documents or other supporting documents issued by relevant U.S. authorities, authenticated by the U.S. Department of State, and intended for use in China; a consulate general may authenticate notarized documents or other supporting documents issued by relevant U.S. authorities, authenticated by the Secretary of State of a state within its consular jurisdiction, and intended for use in China. (Quoted from the website of the Chinese Consulate General in San Francisco)

Because before consular authentication, the document has already gone through two prior steps—local notarization plus authentication by the Secretary of State or U.S. Department of State—consular authentication is commonly called “three-step authentication.”

Why do you need three-step authentication?

In general, there are two common situations.

First, important documents issued in the U.S. need to be taken back to China for use, such as a birth certificate or marriage certificate. For example, if your child was born in the U.S. but needs to return to China for household registration, the birth certificate needs three-step authentication. Likewise, a marriage certificate issued in the U.S. must go through three-step authentication before institutions in China will recognize it.

Second, sometimes a matter in China requires the person’s signature or proof of identity/status, but the person cannot travel back to China for the time being. In that case, you may need to get a power of attorney authenticated, or obtain other related authentication.

Originally, in the second situation, Chinese citizens could handle this through consular notarization as a one-stop process. But on September 9, 2017, a new rule was issued:

What I needed was a power of attorney for a real estate sale, so I could only apply for consular authentication, not consular notarization.

How to complete three-step authentication

Below I’ll use my own real estate power of attorney authentication as an example. The steps for other document types are basically similar, but you should check the website of the consulate that covers your area for the exact required materials.

I live in Seattle, so the information I used came from the Chinese Consulate General in San Francisco.

Step 1: Local notarization

First, prepare your power of attorney. A template can be downloaded from the consulate website.

You can also draft it yourself, but note that the notarial wording for the notary public must follow the required format, which is easy to find online. Banks generally provide free notary service for their customers. At first, I thought notarization was just about witnessing the signature, so as long as I signed in front of the notary, it would be fine. So I brought a Chinese-only version of the power of attorney. I first went to BofA, and the banker said it had to include an English translation, and it had to be professionally translated—my own translation would not work. Then I went to Chase and met a Chinese banker. Although she could read Chinese, she said it would still be better to translate it, but that my own translation was fine. So I went home, translated it paragraph by paragraph, then brought it back to Chase and had the banker notarize it for me. It took less than 10 minutes and was free.

A quick logo shoutout here, as a thank-you.

As a side note, it really is useful to have a checking account at a local brick-and-mortar bank, since it makes getting documents notarized much easier. For example, you may also need notarization when buying or selling a car. Some banks may even ask you to fax notarized copies of your ID or proof of address when you’ve just applied for a credit card or when they suspect your identity may have been stolen.

Step 2: Authentication by the Secretary of State

In Washington state, authentication by the Secretary of State is sufficient. You can either go in person to Olympia, where the state government is located, or mail your documents in. The fee is $15 per document set (regardless of page count), with a processing time of 5-7 business days. Expedited service costs an additional $50. If you go in person, you can pick it up the same day; for mailed expedited processing, it takes 2 business days.

Here’s what I submitted:

  • The original locally notarized document
  • A completed application form
  • The fee (if applying in person, you can pay by credit card; for mail-in applications, personal checks are accepted)

For details, see: List of required materials

The first time, I drove there directly. Parking was free, the office environment was excellent, there was no line, and they even offered free coffee and cookies. They also gave my daughter some small crayons and coloring paper. Three authenticated copies were processed in 20 minutes. I was honestly amazed by how pleasant it was (especially since the other government office I most often deal with in the U.S. is the DMV). The second time, I mailed it in without paying for expedited service and included a USPS prepaid envelope. From mailing it out to receiving it back, it took a total of 5 business days.

Step 3: Consular authentication

Make sure you apply through the consulate that corresponds to your place of residence. “For documents authenticated by a state government, please refer to the consular jurisdiction divisions of Chinese embassies and consulates in the United States. If the document falls under the jurisdiction of a consulate general, please apply to the relevant consulate general for consular authentication; if it falls under the jurisdiction of the embassy, it must first be authenticated by the U.S. Department of State and then submitted to the embassy for consular authentication. Applications submitted outside the proper consular jurisdiction will be refused.” (Quoted from the website of the Chinese Consulate General in San Francisco)

The consulate website is very comprehensive, so be sure to read it carefully.

Consular authentication can be done either in person or by mail. The fees are $8 per civil document and $16 per commercial document. For in-person applications, neither submission nor pickup requires an appointment, and expedited service is available. Rush service can be completed in 1 business day for an additional $37 per document. Even regular processing without rush service takes only 4 business days, which is quite a bit faster than mailing.

I chose to apply by mail. That requires an additional $5 return-mail fee, and you must provide a prepaid envelope with tracking. I used a USPS flat priority priority envelope. At the post office, just tell the staff you want to buy a prepaid envelope, and they will affix a $6.7 stamp to it. Don’t forget to ask them to include tracking, and keep the tracking receipt for your own records. On the prepaid envelope, both the sender and recipient addresses should be your home address.

There is no expedited service for mail-in applications. Processing time is 7 business days after the consulate receives the documents. Based on my two applications, that timing was basically accurate.

Below is the full list of documents I submitted for my power of attorney authentication:

  • The original and a copy of the power of attorney that had completed step 1 and step 2 authentication
  • My new passport and a copy of the photo information page
  • My old passport and a copy of the visa page (my U.S. visa was in the old passport, so I included it just in case)
  • A copy of the I797
  • A completed Application Form for Notarization and Authentication of the Embassy/Consulates of the People’s Republic of China (note that there are two places on page 2 that require signatures)
  • One prepaid envelope with tracking
  • One Money order in the correct amount (mail-in applications only accept Money Order/Cashier's Check)

Finally, make sure the mailing address is marked in Chinese with “领事认证” (consular authentication).

Here is the precious consular authentication stamp, placed directly on the back of the Secretary of State authentication page.

Summary and follow-up

Three-step authentication sounds complicated, but in practice it was actually pretty straightforward. If you live in a convenient location, it’s entirely possible to submit your consular authentication application within a single day. The key is to read the consulate website carefully and follow all document requirements and instructions exactly. For example, if a copy of a document is required, be sure to include it; make sure every required signature is there; and don’t leave the payee line blank on the Money Order (yes, those are all painful lessons learned).

One more update on what happened afterward: after my parents brought the three-step authenticated documents back to China, they checked with the Shanghai real estate bureau. The staff there said the documents could be used, but the text on the state-level authentication still had to be translated into Chinese by one of three designated translation agencies in Shanghai, at a cost of 300-500 yuan. In other words, even with the consular authentication stamp from step 3, you still have to pay to translate the step 2 authentication into Chinese. The good news is that I had originally done three authenticated copies to take back to China, but the real estate bureau staff said one copy was enough, and if more were needed, they could simply be photocopied. I don’t know whether this is also true elsewhere, so if you’re planning to do this, it may be worth asking your family in advance. Since authentication fees are charged per copy, this is an easy place to save money if possible.