Power of Attorney from Abroad: How to Issue and Legalize in 2026

Updated: May 2026 • Includes Federal Law 145-FZ changes (Jan 2025)
Reading time: 18 min Author: Global Docs Pro

You live abroad, but you need to sell an apartment in Russia, obtain a birth certificate from a ZAGS office, apply for a pension, or sign a contract. Without a power of attorney (POA), none of this is possible — but issuing one from thousands of kilometers away is entirely doable. In this guide, we break down both methods for issuing a POA from abroad (through a Russian consulate and through a local notary), explain what changed with Federal Law No. 145-FZ that entered into force on January 1, 2025, and provide step-by-step instructions for every situation. Spoiler: it's not as complicated as it seems.

Why You Need a Power of Attorney from Abroad

A power of attorney is a legal document that grants one person (the representative, or "attorney-in-fact") the authority to act on behalf of another person (the principal, or "grantor"). For Russian citizens and former residents living abroad, this document becomes an essential tool for interacting with Russian bureaucracy. Without a POA, you cannot sell property, obtain a marriage certificate from ZAGS, pick up a criminal record certificate, apply for a pension, or represent yourself in court — all of these require either your personal presence or properly authorized representation.

In practice, the need to issue a POA from abroad arises in the following situations: selling or buying real estate in Russia, obtaining duplicate ZAGS certificates (birth, marriage, divorce), ordering a criminal record certificate for immigration purposes, applying for a pension or social benefits, representing interests in court or government agencies, managing bank accounts, registering a business (individual entrepreneur or LLC), and delegating authority to a lawyer or relative for complex legal matters. Each of these situations requires a specific set of powers in the text of the POA, which is why it is so important to draft the document correctly from the start — errors in wording can lead to rejections from government agencies and wasted time.

What Changed: Federal Law 145-FZ (January 1, 2025) NEW

On January 1, 2025, Federal Law No. 145-FZ of June 22, 2024, "On the Legalization of Russian and Foreign Official Documents and on the Requisition of Personal Documents" entered into force. This law substantially updated the legalization procedure, which was previously governed by fragmented regulations. Here are the key changes that affect powers of attorney issued abroad:

1. Unified Legalization Authority — Russian Ministry of Foreign Affairs

Previously, document legalization was handled by two agencies: the Ministry of Justice (for domestic documents) and the MFA (for cross-border documents). Now, legalization of all Russian and foreign official documents is carried out by the Russian Ministry of Foreign Affairs and its territorial offices. This simplifies the procedure: instead of going through multiple agencies, you only need to contact one. For POAs issued by a foreign notary that require consular legalization, this means a shorter and more transparent chain of certifications.

2. Electronic Submission of Documents for Legalization

The law expanded the options for submitting documents electronically. You can now submit an application for an apostille through the Gosuslugi portal (Russian government services website) or through specialized electronic services. This is particularly important for those who are abroad and cannot personally visit the apostille-issuing authority. A representative with a POA can submit documents electronically, reducing processing times and simplifying the process.

3. Clear Procedure for Consular Legalization

For the first time, FZ-145 established at the legislative level a clear procedure for consular legalization of foreign official documents intended for use in countries that are not parties to the 1961 Hague Convention (UAE, Canada, Qatar, Saudi Arabia, and others). Previously, this procedure was governed by sub-legislative acts and consular instructions, which created uncertainty. Now the deadlines, list of required documents, and submission procedures are clearly defined.

4. POAs Certified by a Russian Consul — No Changes

Importantly, for powers of attorney that you issue through a Russian consulate, nothing has changed. A consular POA still does not require an apostille, legalization, or any additional certification for use on Russian territory. This is directly provided by Article 40 of the Basics of Legislation on Notaries of the Russian Federation: consular officials perform notarial acts that are equivalent to those of notaries on Russian territory.

Key takeaway: If you have a choice between issuing a POA through a Russian consulate or a local notary — choose the consulate. It is cheaper, simpler, and does not require additional legalization. FZ-145 primarily affects POAs from foreign notaries that require an apostille or consular legalization.

Method 1: Issuing a Power of Attorney Through a Russian Consulate

Issuing a POA at a consulate (or consular section of an embassy) of the Russian Federation is the simplest and most reliable method for Russian citizens abroad. The consul performs the functions of a notary: verifies your identity, confirms your legal capacity, explains the consequences of issuing a POA, and certifies the document with their signature and seal. A document certified by a consul has full legal force on Russian territory without any additional certification.

Step-by-Step Instructions

Step 1. Prepare the text of the power of attorney. This is the most important step. The text must contain all necessary powers — otherwise, the Russian authority will refuse to perform the action. You can draft the text yourself, but we strongly recommend consulting specialists who know the specific wording required by particular agencies (Rosreestr, ZAGS, MVD, courts). Global Docs Pro provides a free POA template with correct wording — just message us on WhatsApp or Telegram.

Step 2. Book an appointment at the consulate. Most consulates accept visitors by appointment through the electronic queue system at kdmid.ru. In some countries, appointments are available 2-4 weeks out; in others, you can get an appointment within a few days. Factor this timeline into your planning. If online booking is unavailable, try calling the consulate directly — cancellations do occur.

Step 3. Gather documents for your visit. To certify a POA, you will need: a valid Russian foreign passport, details of the attorney-in-fact (full name, date of birth, passport details, registered address), the exact text of the POA (on paper or USB drive), and a receipt for the consular fee payment (some consulates accept payment on-site). If the POA is being issued to a close relative, bring documents confirming the family relationship — this may reduce the consular fee.

Step 4. Visit the consulate and sign the POA. The consul will verify your documents, confirm your identity, ask clarifying questions, and ask you to sign the POA. Read the text carefully before signing — any errors or inaccuracies are best corrected on the spot. After signing, the consul will add their signature, seal, and enter the POA details into the register of notarial acts.

Step 5. Send the POA to Russia. The consulate does not mail the document — that is your responsibility. The most reliable method is a courier service (DHL, FedEx). Delivery costs from Europe to Russia are approximately 50-80 USD, from the USA — 60-100 USD, from Israel — 50-70 USD. Delivery time is 2-5 business days. Regular international mail is cheaper (5-15 USD) but significantly slower (2-4 weeks) and carries the risk of document loss.

Electronic Power of Attorney Through the Consulate SINCE 2025

Since 2025, Russia has been actively implementing the machine-readable power of attorney (MChD / МЧД) — an electronic document signed with an enhanced qualified electronic signature. Consulates have also begun introducing a procedure for certifying the equivalence of an electronic document to a paper one: after signing the paper POA, the consul can create an electronic copy, sign it with their digital signature, and enter it into the register. This means that a representative in Russia can use the electronic POA to interact with government agencies online, without needing to present the paper original.

However, in practice, the availability of electronic POAs through consulates is still limited. Not all consulates are technically equipped to issue MChDs, and Russian government agencies are not always ready to accept electronic powers of attorney. We recommend checking with the specific consulate whether the service of certifying electronic document equivalence is available. In any case, a paper POA certified by a consul remains fully valid and is accepted by all agencies without exception.

Cost of a Power of Attorney at the Consulate

Type of Power of Attorney Consular Fee
General representation (standard) ~30 USD
Real estate transactions ~60 USD
Obtaining documents (ZAGS, MVD) ~30 USD
Managing bank accounts ~30 USD
POA for a close relative Reduced fee (at consul's discretion)

Additional costs: courier delivery — 50-100 USD; notarized translation of the POA into the language of the host country (if needed for local authorities) — 15-30 USD.

Method 2: Issuing Through a Local Notary + Apostille

If a Russian consulate is far from your place of residence, or appointments are booked months in advance, or you are not a Russian citizen — the alternative is to issue a POA through a local notary with subsequent apostille and notarized Russian translation. This route is more complex and expensive, but in certain situations it is the only option available.

When This Method Is Necessary

Step-by-Step Instructions

Step 1. Draft the text of the POA. As with the consulate method, the text must contain all necessary powers. However, there is an important nuance: the text is drafted in the language of the host country (or in two languages), and the translation into Russian must be notarized. We recommend preparing a bilingual POA (Russian + local language) to avoid translation errors.

Step 2. Visit a local notary. The notary will verify your identity and certify the POA according to the rules of their country. Make sure the notary includes the date, place of certification, their credentials, and a seal — without these elements, an apostille cannot be obtained.

Step 3. Obtain an apostille on the POA. This is the crucial step — without it, the POA will not be recognized in Russia. The apostille is affixed by the competent authority of the country where the document was certified. In Germany, this is the President of the Regional Court (Landgericht); in Spain, the Ministry of Justice; in the USA, the Secretary of State's office; in Israel, the Ministry of Foreign Affairs. The apostille confirms the authenticity of the notary's signature and their authority. Processing time: 1-10 business days depending on the country and authority. For more details, see our apostille service page.

Attention: If the country where you are issuing the POA is NOT a party to the 1961 Hague Convention (e.g., UAE, Canada, Qatar), you will need full consular legalization instead of an apostille. Under the new FZ-145 rules from 2025, legalization of foreign documents is handled by the Russian MFA. The procedure: notary → authority of the destination country → Russian consulate in that country → Russian MFA. This takes longer (2-4 weeks) and costs more.

Step 4. Obtain a notarized Russian translation. The apostilled POA must be translated into Russian, and the translation must be notarized by a Russian notary. This means a qualified translator translates the text, and then a Russian notary certifies the translator's signature. Only then can the document be used in Russian government agencies. Global Docs Pro coordinates the entire process — from apostille to notarized translation. Learn more about our translation services.

Step 5. Send the document to Russia. Same as with the consular method — courier delivery via DHL or FedEx.

Comparison: Consulate vs Local Notary

Criterion Russian Consulate Local Notary + Apostille
Apostille / Legalization Not required — POA is immediately valid in Russia Required — apostille (or consular legalization)
Notarized Translation Not required — text is in Russian Required — translation into Russian + notarization by a Russian notary
Cost 30-60 USD (consular fee) + shipping 100-300 EUR (notary + apostille + translation + shipping)
Processing Time 1 day (with appointment) 1-3 weeks (notary + apostille + translation)
Availability Only in countries with a Russian consulate Available worldwide
For Russian Citizens Yes, the preferred option Yes, if consulate is unavailable
For Non-Russian Citizens Yes, possible (with ID document) Yes, the primary method
Risk of Rejection in Russia Minimal — format is familiar to Russian agencies Higher — possible errors in translation or apostille processing

Bottom line: If you are a Russian citizen and have access to a consulate — choose the consulate. It is faster, cheaper, and more reliable. A local notary with apostille is a backup option for when the consulate is unavailable or when urgent action is needed and appointments are weeks away.

Types of Powers of Attorney: Which One to Choose

Russian law does not have a rigid classification of POAs by type, but in practice there are three categories that differ in the scope of powers and the degree of risk for the principal.

Single-Action Power of Attorney (Разовая доверенность)

Issued for performing one specific action: for example, obtaining a duplicate marriage certificate from ZAGS or picking up a criminal record certificate. This is the safest option — the representative can only do what is explicitly stated in the text, nothing more. We recommend using a single-action POA wherever possible. After the action is completed, the powers terminate automatically.

Special Power of Attorney (Специальная доверенность)

Grants the right to perform several similar actions over a period of time. Examples: representation in court (for a specific case), receiving a pension (monthly), managing a specific bank account, obtaining documents from multiple agencies (ZAGS, MVD, Rosreestr). A special POA is the most common type for Global Docs Pro clients, since one document allows the representative to obtain several documents without needing separate POAs for each.

General Power of Attorney (Генеральная доверенность)

Grants the representative the broadest possible powers: disposing of all property, representing interests in all agencies and organizations, signing any contracts. This is the riskiest type of POA — an untrustworthy representative can cause significant harm. Russian notaries and consuls warn about the consequences of issuing a general POA. We recommend issuing a general POA only in exceptional circumstances and only to persons you trust absolutely.

Common Situations and Recommended POA Types

Situation POA Type Key Powers
Obtaining a ZAGS certificate Special Right to obtain duplicate certificates from a specific ZAGS office
Criminal record certificate Special Right to submit application and receive certificate from MVD
Selling an apartment Special Signing the sale agreement, registration with Rosreestr, receiving payment
Obtaining documents + apostille Special Obtaining documents + right to apply for apostille
Court representation Special Right to sign the claim, attend hearings, receive court decisions
Comprehensive legal management General (with caution) Broad powers — only to a trusted person

How to Draft the Text of a Power of Attorney

The text of the POA determines everything: if the powers are too narrow, the representative cannot perform the needed action; if too broad, you risk your assets. Here are the mandatory elements that must be present in any POA for use in Russia, and common mistakes to avoid.

Mandatory Elements of a Power of Attorney

Common Mistakes

Mistake 1. Overly general wording. Phrases like "represent my interests in all agencies" or "dispose of my property" without specifics can lead to rejection. For example, Rosreestr requires that a POA for selling an apartment explicitly states: the property address, the right to sign the sale and purchase agreement, the right to receive payment, and the right to submit documents for state registration.

Mistake 2. Inaccurate attorney-in-fact details. If the full name, date of birth, or passport details of the attorney-in-fact contain errors, the POA will not work. Always double-check the details against the attorney-in-fact's passport before visiting the consulate.

Mistake 3. Forgetting the right to receive documents. A common situation: the POA grants the right to "submit applications and represent interests" but does not grant the right to "receive completed documents." As a result, the representative submits the application but cannot pick up the result. Always include the wording "the right to receive documents and sign for them."

Mistake 4. Missing the right to obtain an apostille. If you plan for the representative to not only obtain a document but also arrange for an apostille, this right must be explicitly stated in the POA. Without it, the representative cannot approach the apostille-issuing authority.

Tip: Global Docs Pro provides a free POA template with correct wording for every situation. Message us on WhatsApp or Telegram — we will send you a ready-made template that you simply print and take to the consulate.

Apostille on a Power of Attorney: When Needed and How to Obtain

An apostille is a special stamp that confirms the authenticity of the signature and seal of the official who certified the document. It is affixed to documents that will be used in countries that are parties to the 1961 Hague Convention (over 120 countries). Without an apostille, a POA issued by a foreign notary will not be recognized in Russia — with the exception of POAs certified by a Russian consul (no apostille needed for those).

Which POAs Need an Apostille

Procedure for Obtaining an Apostille

The apostille is affixed in the country where the document was certified, by the competent authority of that country. You cannot obtain an apostille on a German POA in Russia — it must be done in Germany. The procedure depends on the country, but generally: the notary certifies the POA → you (or your representative) apply to the competent authority → the authority verifies the notary's signature → the apostille is affixed. Processing time: 1-10 business days. Cost: 10-100 EUR depending on the country.

New Apostille Rules in Russia (FZ-145)

Since January 1, 2025, under FZ-145, apostilles on Russian official documents are affixed by authorities designated by the Russian Government (Ministry of Justice, ZAGS, education authorities, and others). Applications for apostille can be submitted in person, through a representative with a POA, or electronically through Gosuslugi. This is important for your representative in Russia who will be obtaining apostilles on retrieved documents — the process is now faster and simpler. For more details, visit our apostille services page.

Notarized Translation of a Power of Attorney

If you issued your POA through a foreign notary, it must be translated into Russian and the translation must be notarized by a Russian notary. This is not just a translation — it is a notarial act in which the notary certifies the authenticity of the translator's signature on the translation. Without a notarized translation, the foreign document will not be accepted by any Russian government agency.

The procedure works as follows: a certified translator (not just any translator, but one whose signature is registered with a notary) translates the POA with the apostille into Russian → the translator signs the translation → a Russian notary certifies the translator's signature → the translation is attached to the original and sealed by the notary. Cost: from 1,000 to 3,000 rubles per page, depending on the language and urgency. Global Docs Pro works with certified translators in all major languages and provides notarized translation services in Moscow — learn more about translations.

Important note: you need to translate both the POA text and the apostille text. Russian authorities check both documents, and a missing translation of the apostille is a common reason for rejection. Also note that in some cases, you may need not just a notarized translation but a sworn translation (beeidigte Übersetzung in Germany, traduction assermentée in France). If you plan to use the POA not only in Russia but also in a third country, check the requirements of the receiving authority in advance.

Country-Specific Details

Germany

Germany is one of the most popular destinations for Russian emigration, and the question of powers of attorney arises frequently. There are four Russian general consulates in Germany (Berlin, Bonn, Hamburg, Munich) and the embassy in Berlin. Appointments for notarial services are typically available 1-3 weeks out. Consular fee: 30 EUR for a standard POA, 60 EUR for a real estate POA. Alternative: a German notary (Notar) with subsequent apostille at the Landgericht and notarized Russian translation. For more details about documents for Germany, visit our Germany page.

Israel

Russian consulates in Israel are located in Tel Aviv and Haifa. Appointments are usually available 1-2 weeks out. Consular fee: approximately 30-60 USD. A notable feature: many POAs are issued to obtain Russian documents required by Israeli authorities (residence permits, citizenship, qualification recognition). An Israeli notary can also certify a POA, but for use in Russia you will need an apostille from the Israeli Ministry of Foreign Affairs and a notarized Russian translation. For more details, visit our Israel page.

USA

Russian consulates in the USA are located in Washington, D.C., New York, San Francisco, and Houston. Appointments for notarial services may be 2-4 weeks out. Consular fee: 30-60 USD. Alternative: a US notary public with an apostille from the Secretary of State of the relevant state. The apostille procedure in the US is relatively straightforward and takes 1-5 business days. Notary cost: 10-50 USD; apostille: 5-25 USD depending on the state.

Spain

Russian consulates in Spain are located in Madrid and Barcelona. Appointments may be 2-3 weeks out. A Spanish notary (Notario) can certify a POA, but for use in Russia you will need an apostille from the Spanish Ministry of Justice (Ministerio de Justicia). For more details, visit our Spain page.

Turkey

Turkey is not a party to the Hague Convention, so instead of an apostille you will need full consular legalization of a POA issued by a Turkish notary. Under the FZ-145 rules from 2025: notary → Turkish authority (governorate or Ministry of Justice) → Russian consulate in Turkey → Russian MFA. This is a lengthy procedure taking 2-4 weeks. We recommend issuing a POA through the Russian consulate in Ankara, Istanbul, or Antalya — it is significantly simpler.

Common Mistakes and How to Avoid Them

Over the years of working with powers of attorney from abroad, we have compiled a substantial list of typical mistakes made by clients. Here are the most common ones and how to avoid them.

1. Wrong type of legalization. A client issues a POA through a local notary, obtains an apostille, but the destination country is the UAE (not a Hague Convention member). Result: instead of an apostille, consular legalization was needed. Always check whether the country is on the Hague Convention member list before proceeding.

2. Apostille on the wrong document. The apostille is affixed to the original POA or to a notarized copy — depending on the requirements of the receiving authority. If you obtained an apostille on a copy but the original was required, you will need to start over. Check the requirements before beginning the procedure.

3. POA without a validity period. If the POA does not specify a validity period, it is valid for 1 year (Art. 186 of the Civil Code of the Russian Federation). Many people do not know this and assume "no expiration date" means "indefinite." If you need a POA valid for 3 years — state this explicitly in the text.

4. POA for selling an apartment without the right to receive payment. This is a classic error: the POA grants the right to sign the sale agreement and register it with Rosreestr, but not the right to receive payment from the buyer. The deal is closed, but the money cannot be collected without a new POA. Always include the authority to receive funds.

5. Translation without notarization. A regular translation of a POA, even by a professional translation agency, has no legal force in Russia. You need a specifically notarized translation — with the translator's signature certified by a Russian notary.

6. Sending the original by regular mail. A POA is a legal document, and its loss can create serious problems (especially if it is a general POA). Never send the original POA by regular mail — only by courier service with tracking and insurance.

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Checklist: Step-by-Step Plan for Issuing a POA from Abroad

  1. Determine exactly what actions the representative needs to perform in Russia (obtain a document, sell property, represent you in court)
  2. Choose the method: Russian consulate (recommended) or local notary + apostille
  3. Obtain the exact details of the attorney-in-fact: full name, date of birth, passport, registered address
  4. Draft the POA text with correct legal wording (message us for a free template)
  5. Book an appointment at the consulate via kdmid.ru, or find a local notary
  6. Visit the consulate/notary and sign the POA
  7. If using a local notary: obtain an apostille from the competent authority in that country
  8. If using a local notary: arrange a notarized Russian translation (in Russia)
  9. Send the POA to Russia by courier (DHL, FedEx)
  10. Confirm that the representative has received the document and can proceed

How Global Docs Pro Helps with Powers of Attorney

Global Docs Pro has been specializing in Russian document services for clients abroad since 2015. Issuing a power of attorney is one of the most common requests, and we have streamlined the process to minimize your effort.

Step 1. Free consultation. Contact us via WhatsApp or Telegram and describe your situation. We will determine what type of POA you need, what powers to include, and which method to choose — consulate or local notary. The consultation is free and without obligation.

Step 2. Drafting the POA text. We prepare the POA text with precise wording that meets the requirements of specific Russian agencies (Rosreestr, ZAGS, MVD, courts). You receive a ready-made document that you simply print and take to the consulate or notary. This eliminates errors in wording and ensures the POA will work.

Step 3. Instructions for certification. We send you step-by-step instructions: how to book a consulate appointment, what documents to bring, what to look for when signing. For clients choosing a local notary — instructions for obtaining an apostille in your specific country.

Step 4. Representative in Russia. After receiving the POA, our representative in Moscow visits the necessary agencies on your behalf: obtains documents from ZAGS, orders a criminal record certificate, arranges an apostille, and commissions a notarized translation.

Step 5. Document delivery. Completed documents are shipped to you via DHL or FedEx with full insurance and tracking. You receive the documents at your address in any country within 2-5 days.

No prepayment — for most services, you pay only after seeing photos of the completed documents. We work on results and are confident in the quality of our services.

Get a Free POA Template

Message us — we will send you a precise POA template with correct legal wording for your situation. No obligations.

Frequently Asked Questions

Can I issue a power of attorney for Russia without visiting the consulate?

Since 2025, it is possible to issue an electronic power of attorney (MChD) through a Russian consulate using the consul's electronic signature. However, you still need to visit the consulate in person — a notarized POA cannot be issued remotely without a visit. The alternative is to have a local notary issue the POA and then obtain an apostille and a notarized Russian translation, which also does not require a consulate visit but takes more time and money for legalization.

How much does it cost to issue a power of attorney at a Russian consulate?

The consular fee depends on the type of document. A general power of attorney costs approximately 30 USD, while a POA for real estate transactions costs around 60 USD. Additional costs: courier delivery of the original to Russia — 50-100 USD; notarized translation (if needed for local authorities) — 15-30 USD.

Do I need an apostille on a power of attorney issued at a Russian consulate?

No. A power of attorney certified by a consul of the Russian Federation is valid on Russian territory without any additional legalization or apostille. This is directly provided by Article 40 of the Basics of Legislation on Notaries of the Russian Federation. Consular officials perform notarial acts that are equivalent to those of Russian notaries.

What changed in the legalization of powers of attorney on January 1, 2025?

On January 1, 2025, Federal Law No. 145-FZ of June 22, 2024 entered into force. Key changes: legalization of documents is now carried out by the Russian MFA (previously by the Ministry of Justice and MFA separately), the list of documents that can be submitted electronically has been expanded, and the procedure for consular legalization for countries outside the Hague Convention has been clearly defined. For POAs certified by a Russian consul, nothing has changed — they still do not require an apostille.

What is the difference between a consulate POA and a local notary POA?

The main difference is in the legalization procedure. A POA through a Russian consulate does not require an apostille and is immediately valid in Russia. A POA from a local notary requires an apostille (for Hague Convention countries) or consular legalization (for other countries), plus a notarized Russian translation. In terms of time: the consulate is usually faster (one visit), but appointments may be weeks away. A local notary is more accessible, but subsequent legalization takes 1-2 weeks.

Can I issue a power of attorney to sell an apartment from abroad?

Yes, this is one of the most common situations. A POA for selling real estate can be issued either through a Russian consulate or through a local notary with an apostille. The text must include: the property address, authority to sign the sale and purchase agreement, the right to receive payment, and authority to register the transaction with Rosreestr. We recommend using a Russian consulate — it is simpler and does not require an apostille.

How do I send a power of attorney from abroad to Russia?

There are several options: courier service (DHL, FedEx) — the most reliable, takes 2-5 days, costs 50-100 USD; regular international mail — cheaper but slower (2-4 weeks) with a higher risk of loss; electronic power of attorney (MChD) — since 2025, it can be issued through the consulate in electronic form, data is automatically entered into the register of notarial acts, and the representative can use the MChD without a paper original.

How long is a power of attorney issued abroad valid?

If the POA does not specify a validity period, it is valid for one year from the date of execution (Article 186 of the Civil Code of the Russian Federation). The maximum validity period is not limited by Russian law — you can specify 3 years, 5 years, or any other period. However, notaries usually recommend specifying a reasonable period (1-3 years) to minimize risks. The date of execution is the date of certification by the consul or local notary.

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