Three out of four consular files we translate need a criminal record certificate from the applicant's country of origin. For the three big origins — United States, United Kingdom and France — the document required has a different name, issuing authority and apostille regime. Confusing them means requesting the wrong certificate and starting over.
This comparison places the three side by side: what they're called, who issues them, what they cost, how long they take and whether they need apostille.
Executive summary
| FBI Identity History Summary | ACRO Police Certificate | B3 (Bulletin n°3) | |
|---|---|---|---|
| Country | 🇺🇸 United States | 🇬🇧 United Kingdom | 🇫🇷 France |
| Issuer | Federal Bureau of Investigation | ACRO Criminal Records Office | Casier judiciaire national (Nantes) |
| Coverage | Federal (all US) | UK (England/Wales) + some adjacent | Metropolitan France + DOM-TOM |
| Cost | ~$18 USD | £55 (standard) / £80 (premium) | Free |
| Issue timeline | 1-2 weeks with channeler | 10 calendar days (standard) / 2 days (premium) | Minutes online / 2-3 weeks postal |
| Apostille | Yes — Department of State federal | Yes — FCDO Milton Keynes | No — EU Reg 2016/1191 |
| Spain validity | 3 months from issue | 3 months from issue | 3 months from issue |
| Original language | English (with fingerprints) | English | French (with EU multilingual form) |
| Sworn translation to Spanish | Yes, mandatory | Yes, mandatory | Yes, mandatory |
The FBI Identity History Summary (United States)
The US federal criminal record. It is the only universal criminal record certificate in the US because there is no state equivalent with national coverage — state databases do not communicate. The FBI summary collects all federal and state arrests recorded in the National Crime Information Center (NCIC).
How to obtain it:
- Fingerprinting (ink or digital) at an FBI-authorized channeler (Identogo, Accurate Biometrics, etc.).
- Submission of fingerprints to the FBI with form and payment (~$18).
- FBI issues the Identity History Summary in 1-2 weeks and emails it as a signed PDF.
Key particular: the apostille is federal (Department of State in Washington DC), not state. It is the #1 mistake we see in US files — many applicants send it to their state Secretary of State and get rejected. Details in our US apostille guide.
When requested: NLV, Digital Nomad Visa, golden visa (currently suspended), initial residence from the US, family reunification, Spanish citizenship by residence.
Complete technical sheet: Sworn translation of FBI background check.
The ACRO Police Certificate (United Kingdom)
UK criminal record issued by the ACRO Criminal Records Office. Primarily covers England and Wales; for Scotland there's a parallel certificate from SPRA (Scottish Police Recorded Information) and for Northern Ireland the PSNI Criminal Records Office, although most consulates accept the standard ACRO for UK residents.
How to obtain it:
- Online application at acro.police.uk.
- Payment: £55 standard (10 days) or £80 premium (2 working days).
- Provide passport copy and proof of address.
- ACRO issues the certificate as an electronically signed PDF.
Key particular: requires apostille from the Foreign, Commonwealth & Development Office (FCDO) in Milton Keynes. UK apostille has its own process, timelines and fees separate from ACRO. Timeline: 1-2 weeks; cost: ~£30.
When requested: any Spanish file for British nationals post-Brexit — assimilated EU residence, initial authorisation, citizenship by residence, public-sector exams open to British nationals.
Complete technical sheet: Sworn translation of UK ACRO Police Certificate.
The French B3 (Bulletin n°3 of the Casier judiciaire)
The most restricted French criminal record (the most limited of the three versions existing in France, alongside B1 for magistrates and B2 for public administrations). Issued by the Casier judiciaire national in Nantes, the single body centralising all French territory.
How to obtain it:
- Online application at casier-judiciaire.justice.gouv.fr (FranceConnect authentication).
- Free — the French administration charges nothing for this certificate.
- Online timeline: minutes if born in metropolitan France and have FranceConnect; 2-3 weeks by post if born outside France.
- Downloaded as electronically signed PDF with QR verification code.
Key particular: does NOT require apostille. The B3 falls within EU Regulation 2016/1191 which removes the apostille requirement between Member States for civil status documents — including "absence of criminal record" (art. 2.1.l). It is the only one of the three reaching Spain directly, without additional legalisation.
But beware: the EU Regulation's multilingual form does not replace sworn translation. The body of the document remains in French and Spain requires sworn translation by MAEC translator.
When requested: EU residence, NIE, initial authorisation from France, citizenship by residence, public-sector exams.
Complete technical sheet: Sworn translation of French B3.
The decision: which to request by country
The rule is simple: you request the certificate of the country of which you are a national, not the country you live in. A Spaniard living in the UK applying for Spanish citizenship only submits the ACRO (because they're not from the UK). An American living in France applying for Spanish NLV submits both FBI AND B3 (because they lived in both countries the last 5 years).
For Spanish files covering continuous residence in several countries over the last 5 years, you must submit each country's criminal record. It's common to see files combining all three: FBI + ACRO + B3.
Comparative table of effective costs and timelines
Adding up time and cost of the certificate itself, apostille (where applicable) and sworn translation, the total cost to reach the consulate with each document is approximately:
| Total cost | Total time | |
|---|---|---|
| FBI Identity History Summary | $18 (certificate) + $8 (federal apostille) + Textualia sworn translation | 2-3 weeks (expedited apostille) or up to 14 weeks (standard apostille) |
| ACRO Police Certificate | £55-80 (certificate) + ~£30 (FCDO apostille) + Textualia sworn translation | 2-3 weeks total |
| French B3 | Free (certificate) + €0 (no apostille) + Textualia sworn translation | Minutes + translation time (3-5 days) |
B3 is clearly the cheapest and fastest. FBI is the slowest due to federal apostille. ACRO sits in between.
Particulars by Spanish consulate
| Consulate | Common particulars |
|---|---|
| London, Manchester, Edinburgh | Accept standard ACRO without special nuance |
| New York, Miami, Houston, Los Angeles, San Francisco, Chicago, Boston | FBI mandatory + federal apostille; some also require state from each US residence state |
| Paris, Lyon, Marseille, Toulouse, Bordeaux, Strasbourg, Bayonne, Montpellier | B3 with multilingual annex; no apostille; some prefer sworn translation despite the EU form |
| Other consulates (Rome, Berlin, etc.) | If applicant is British/American/French and lives in that third country, generally accept the certificate of country of nationality |
Common mistakes in multi-country files
- Forgetting one of the certificates. If you've lived in several countries the last 5 years, all count.
- Apostilling the FBI at state SoS. The most expensive US mistake — lose 3-4 weeks.
- Requesting apostille of French B3. The Cour d'appel will reject it — EU Reg 2016/1191 makes apostille unnecessary.
- Assuming the B3 multilingual form replaces sworn translation. It doesn't: Spain still requires MAEC translation.
- Requesting ACRO more than 3 months in advance. It expires at 3 months for Spain; if you don't make it in time, you pay £55-80 again.
- Apostilling before checking consular appointment date. Since certificates expire at 3 months, you have to sync the whole process with submission date.
Related pages
- Sworn translation of FBI background check
- Sworn translation of UK ACRO Police Certificate
- Sworn translation of French B3
- Sworn translation of a criminal record certificate — general overview applicable to other countries
- Spain Non-Lucrative Visa for US citizens
- US apostille: federal vs state
→ Request my sworn translation
Whatever your criminal record — FBI, ACRO or B3 — upload the PDF to the quote tool and get an instant price. We work with US, UK and FR files every day.