Notaries Abroad
Notaries in England and Wales deal solely with documents for use abroad, and the requirements of the laws of other countries. They act as independent professionals. Their role is unique throughout the world.
Notaries elsewhere have a slightly different role, depending on the nature of their legal system. Notaries in other jurisdictions deal solely with domestic legal business, and do not deal with anything involving the laws of other countries.
England is a common-law system. The laws of most Commonwealth countries, and of every state of the United States of America (except Louisiana) are based on the common law.
Notaries in most Commonwealth countries are appointed by the state. In the USA, Notaries are not even qualified lawyers, and have a very limited role.
All of the mainland continental European legal systems are based on civil law. Unsurprisingly, so too are the legal systems of South America and, more surprisingly, is Japan.
Notaries in civil law countries are state-appointed officials, often required by their governments to provide legal certainty for people entering contracts, including marriage and inheritance contracts.
Scotland (a mixture of common and civil law) and Northern Ireland are separate legal jurisdictions.
An English or Welsh notary can only practise in England and Wales.