For decades, the notary remained the most "offline" figure in law: seal, personal appearance, paper register. Nevertheless, over the past few years, all three legal systems of interest to us—Russian, English, and American—have learned to certify documents remotely, and each has done so in its own characteristic way: Russia built state infrastructure, England made do with pragmatic practice, the USA left the matter to the market.
For clients with assets and family in multiple jurisdictions, this is not theory. A power of attorney for a transaction in Moscow when the principal is in London; selling an apartment in Russia without flying from Dubai; documents for an American SPV signed from Europe—all of this is now done without boarding a plane. Below is how remote notarisation works in three systems, where its boundaries lie, and how we assemble from this a working "one-touch" service.
Where remote notarisation came from
It is commonly believed that the pandemic drove notarisation online. This is only half true. The first law on remote online notarization was passed by the American state of Virginia back in 2011, and the Russian "digital notary law"—Federal Law No. 480-FZ—was signed in December 2019, several months before lockdowns. The pandemic did not create the trend but compressed a decade of evolution into a couple of years: the technologies were already on the shelf; all that remained was to give them legal force.
Then the paths diverged. Russia built a centralised system—a unified information system for notaries, qualified electronic signatures, biometrics. England did not change its laws and relied on the flexibility of its notaries. The USA left the matter to the market, and within a few years an entire sector of online notarial platforms grew there. Three models—three different answers to the same question: how to verify the identity and will of a person who is not in the room.
Russia: notarisation on state rails
What can be done remotely
Since the end of 2020, Article 44.3 of the Fundamentals of Legislation on Notaries has allowed a number of notarial acts to be performed without appearing at the office at all. The application goes to the Federal Notarial Chamber through the unified information system for notaries—including directly from Gosuslugi—and is signed with an enhanced qualified electronic signature (UKEP), which today can be issued free of charge in the "Goskluch" app. The system itself distributes the application to a free notary: the executor may turn out to be a notary from any region, and for the applicant this does not matter.
Actions that do not require verification of will are available remotely: certification of the accuracy of translation, transmission of applications and documents to third parties, acceptance of money and securities on deposit, writ of execution, storage of electronic documents, securing of evidence—a classic of the genre, notarial inspection of a website or correspondence—extract from the register of movable property pledges, certification of the equivalence of an electronic document to a paper one. The notary is obliged to issue a document or a reasoned refusal no later than five working days after payment.
Remote transactions: two notaries, one transaction
For transactions, the law proposed a separate construction—Article 53.1: the transaction is certified by two or more notaries. Each party comes to their own notary in their own city, the parties see each other via the secure video link of the UIS, the electronic copy of the contract is signed in the presence of the notaries and sealed with their UKEP. Personal appearance remains, but to the nearest notary—not halfway across the country to the counterparty.
The format caught on quickly. According to the FNP, in 2025 remote transactions increased by 11–12%, remote notarial acts increased by 1.8 times, and the share of the remote format in notarial real estate transactions grew from 19% in 2022 to approximately one-third. For the "Moscow–Sochi" or "St. Petersburg–Crimea" pair, this is already effectively the market standard.
Where the boundary lies
It is not possible to certify a power of attorney, will, spousal consent, or the contract itself remotely—everything that requires verification of real will still presupposes personal presence, either in person or in the format of a remote transaction. The legislator's logic is simple: UKEP proves whose signature it is, but does not prove that the person signed freely and understood the consequences. Therefore, the Russian model is not "notary by video link," but a careful division: actions without verification of will have gone completely online, actions with verification of will remain at the notary's desk.
A separate story is the electronic apostille, which the Ministry of Justice has been affixing since 2022. In combination with remote actions, this provides a fully digital chain "document—notary—apostille" without a single sheet of paper: a rare case where Russian bureaucracy is ahead of European.
England: pragmatism instead of infrastructure
Notary for the outside world
The English notary public is a paradoxical figure: within the country he is almost unnecessary. English law does not require notarial form for contracts or powers of attorney—a signature is sufficient, and for deeds a witness as well. There are fewer than a thousand notaries in England and Wales, they are regulated by the Faculty Office of the Archbishop of Canterbury—yes, seriously—and they work mainly "for export": certifying documents going to foreign registers, banks, and courts.
What remote notarisation looks like
Remote certification here is arranged without any state system. The Faculty Office back in 2020 permitted the performance of notarial acts by video link: the notary must satisfy himself of the identity of the signatory and directly indicate in the certificate that the act was performed remotely. In practice, this is a video call with demonstration of a passport, signing on camera—and the original that goes to the notary by post. A hybrid of digital and paper.
There is also a fully electronic route: e-notarisation, when the notary signs a PDF with a qualified electronic signature (QES), plus e-Apostille—an electronic apostille issued by the FCDO. The "PDF + QES + e-Apostille" chain closes the task without any paper at all—for jurisdictions ready to accept it.
The recognition trap
The weak point of the English model is the continuation of its strength, flexibility. Since everything rests on guidance rather than statute, the fate of a remote act is decided not in London but in the country of destination: a German land court, an Emirati registrar, or a Russian notary has the right not to accept a remote act or electronic apostille. A competent English notary therefore begins not with the question "what document," but with the question "where will it go." Checking the requirements of the receiving jurisdiction is a mandatory zero step.
USA: notarisation as a market
RON American-style
The American notary public is not a lawyer and not an analogue of the Latin notary: he certifies the signature, not the transaction. That is precisely why the USA most easily handed notarisation over to technology. Remote online notarization (RON) is a video session on a licensed platform: the authenticity of the document is verified by an algorithm (credential analysis), identity—by KBA, knowledge-based authentication, those same tricky questions about past addresses and credits. The document is signed electronically, the notary applies a digital certificate, and the entire session is recorded and stored for years. The video archive here plays the role that qualified signature plays in Europe.
Law: states and the federal umbrella
Virginia started in 2011, the pandemic pushed the rest: permanent RON laws are now in effect in virtually all states, with California remaining the last holdout, whose law will come into full force by 2030. Over this mosaic, Congress has been trying for years to stretch a federal umbrella—the SECURE Notarization Act, guaranteeing interstate recognition of remote acts; the bill passed the House of Representatives but is still stalled in the Senate. This does not hinder the market: acts of one state are recognised in others under general rules, and millions of transactions—primarily mortgage—are closed completely online.
For international clients, there is a pleasant detail in RON: many platforms work with foreign passports, and the signatory can be outside the USA—legally the action is performed where the notary is located. You can sign documents for a Delaware company from London, Dubai, or Almaty—as long as there is stable internet.
What to do with this—and what we have to do with it
In the real practice of a family office, the three models do not compete but combine. A power of attorney for managing Russian assets is signed with a London notary by video and goes to Moscow with an apostille. An apartment in Sochi is sold through two notaries while the seller is in the Emirates. A package for an American SPV is signed in a RON session from Europe. Each time the question is the same: which form will be recognised where the document is presented.
This is where the main complexity is hidden. Remote notarisation in each country grew under its own needs, and no one designed the joints between systems: a Russian notary may look sceptically at a RON document, a German registrar—at an English e-Apostille. Selecting a working chain—form of certification, apostille or consular legalisation, translation—is the professional task.
For Private.law clients, we have assembled it into a ready product—one touch. You describe the task—then we determine the optimal form, prepare documents, organise the issuance of UKEP or a RON session, coordinate notaries in the necessary countries, conduct apostillisation, and bring the document to recognition in the target jurisdiction. On your side—one request and one video meeting; everything else happens without your participation.