Documents for a Tenfiz Case: Finality, Apostille, Translation
You won abroad, and now you need that win to actually count in Türkiye (Turkey). To enforce or recognise a foreign judgment or award here, you need five documents: the final ruling carrying a finality annotation (kesinleşme şerhiKesinleşme şerhiCertificate of finalityThe note from the foreign court confirming that its judgment is final and no longer open to appeal.Glossary →); an apostilleApostilApostilleA certificate added to a public document in its own country so that it is accepted as genuine in Türkiye, without consular legalisation.Glossary → under the 1961 Hague Convention (or consular legalisation); a sworn Turkish translation; the identity or registry papers the court asks for; and a power of attorney (vekâletnameVekâletnamePower of attorneyThe notarised document that authorises a Turkish lawyer to act for you — the reason most matters can be handled without you travelling.Glossary →) so a Türkiye-bar lawyer can run the case for you. Prepare those correctly and the rest is usually procedural. The two documents that most often cause delay are the finality annotation and the apostille, so we spend the most time on those below. And in almost every case, you stay home while your lawyer handles the filing here.
What documents do you need for a tenfiz case in Türkiye?
The short answer: a tenfizTenfizEnforcement of a foreign judgment in TürkiyeThe Turkish court decision that makes a foreign judgment enforceable in Türkiye — the step that lets you actually collect.Glossary → case needs the final judgment or award with its finality annotation, an apostille (or consular legalisation), a sworn Turkish translation, your identity or registry documents, and a power of attorney for a Turkish lawyer. Two quick definitions first, because they change what you file: enforcement (tenfiz) makes a foreign decision executable in Türkiye, like a Turkish judgment, while recognition (tanımaTanımaRecognition of a foreign judgment in TürkiyeThe court decision that makes a foreign judgment legally effective in Türkiye as proof — without, by itself, making it enforceable.Glossary →) simply has the decision accepted here as legally settled — useful when you do not need to seize assets, only to have the foreign ruling count.
Here is the full set at a glance.
| Document | What it is | Why the court needs it |
|---|---|---|
| Final judgment or award + finality annotation (kesinleşme şerhi) | The complete ruling, plus a court note that it has become final | Proves the decision is settled, not still open to appeal |
| Apostille or consular legalisation | An official certificate that authenticates the document for use abroad | Lets Turkish authorities accept it as genuine |
| Sworn Turkish translation | A certified Turkish version of every foreign document | A Turkish court works in Turkish |
| Identity / registry documents | Passport, or a company registry extract and proof of signing authority | Shows who you are and who may act for you |
| Power of attorney (vekâletname) | Written authority for a Turkish lawyer to run the case | Lets the matter proceed without you travelling |
Most of these are mechanical. The two that most often send a file back are the finality annotation and the apostille, so we take those first. For what a Turkish court checks before it will enforce, see our guide to the conditions to enforce a foreign judgment, and for the wider picture our recognition and enforcement of foreign judgments service page. If you are unsure whether you need enforcement or only recognition, our note on recognition versus enforcement (tanıma vs tenfiz) sets out the difference.
What kind of decision are you holding?
What does a finality annotation (kesinleşme şerhi) mean, and why is it a stumbling block?
A finality annotation (kesinleşme şerhi) is a note or stamp from the court that issued your judgment, confirming that the judgment has become final — that it is no longer open to an ordinary appeal. Türkiye will not enforce a foreign decision that could still be overturned at home, so the court here needs proof, on the document itself, that yours is settled.
Why does this trip people up? Because "final" is a Turkish-law idea, and not every legal system produces a tidy certificate that says the decision is closed. Some courts abroad issue a clear finality stamp; others expect you to prove finality from the case history or an entry of judgment. Where there is no standard stamp, your lawyer helps you obtain an equivalent confirmation from the court or clerk that the ordinary appeal routes are exhausted.
What is an apostille — and what if your country is not in the Hague Convention?
An apostille is a standard, one-page certificate issued under the 1961 Hague Apostille Convention. It authenticates an official document — here, your court judgment and its finality annotation — so that authorities in another member country accept it as genuine without any further legalisation. Türkiye is a party, so an apostille from another member state is enough on its own.
If the country where your judgment was issued is not a party to the Convention, you use consular legalisation instead. That is an older, longer chain: the document is certified by the relevant authority or foreign ministry in the country of origin, and then legalised by the Turkish consulate there. The end result is the same — a document Türkiye will accept — but it takes more steps and time.
| Apostille | Consular legalisation | |
|---|---|---|
| When it applies | Country of origin is a party to the 1961 Hague Convention | Country of origin is not a party |
| Steps | One apostille certificate from the designated authority | Local certification, then the Turkish consulate legalises it |
| Typical effort | Shorter | Longer, more offices involved |
Do you need a sworn Turkish translation, and of what?
Yes. A Turkish court works in Turkish, so every foreign-language document must arrive with a sworn Turkish translation — a translation prepared by a sworn (certified) translator and, in practice, notarised. That covers the judgment, the finality annotation, the apostille itself, the power of attorney, and any registry or identity papers you rely on.
People sometimes translate the judgment but forget the apostille and the finality note. Translate all of it. The court reads the Turkish, and a document it cannot read is a document it cannot rely on.
What identity and registry documents will the court want?
That depends on who is bringing the case. The court needs to know that you are who you say you are, and — if you are a company — that the person signing the power of attorney is entitled to bind you.
- An individual: a passport copy, apostilled and translated where the court requires it.
- A company: a trade registry extract or certificate of incorporation, plus a document showing who holds signing authority for the company. Both are apostilled and translated when they come from abroad.
- The debtor's details: the Turkish address or known assets of the party you are enforcing against. This helps fix the competent court (MÖHUK art. 51) and matters again later, when you collect.
My judgment is final at home, so a Turkish court will take it as final too.
Finality has to be visible on the papers. MÖHUKMÖHUKTurkish Private International Law Act No. 5718The Turkish statute that decides which country's law applies to a cross-border matter, and how foreign judgments are recognised and enforced here.Glossary → art. 50 allows enforcement only of a foreign judgment that has become final under the law of the country that gave it, and the same requirement carries into recognition under art. 58, so the file needs a finality annotation (kesinleşme şerhi) from the issuing court. Where a legal system produces no standard finality stamp, an equivalent confirmation from the court or clerk that ordinary appeal routes are exhausted takes its place.
I will have to fly to Türkiye and give evidence about my case again.
In most tenfiz cases you never enter a Turkish courtroom. A power of attorney (vekâletname) lets a lawyer admitted to a Turkish bar file and conduct the case, and under MÖHUK art. 55 the action is heard under the simplified procedure (basit yargılama usulü). The court examines the enforcement conditions and the documents rather than re-trying the merits of the foreign case.
One apostille on the judgment covers the whole file.
Apostille the judgment and the separate finality confirmation — the two pages sometimes come from the court on different days, and a missing apostille on the finality page is a classic reason a file stalls. The translation reaches further still: the judgment, the finality note, the apostille itself, the power of attorney and any registry or identity papers all need a sworn Turkish translation.
Nothing can be done here unless my country has an enforcement agreement with Türkiye.
That depends on which route you need. Reciprocity is one of the enforcement conditions in MÖHUK art. 54, but recognition (tanıma) under art. 58 applies those same conditions with the reciprocity requirement switched off — so a decision you only need accepted as settled, rather than executed against assets, does not depend on it. Reciprocity surfaces in a second, separate place as well: it can exempt a foreign claimant from the security for costs (yabancılık teminatı) such a claimant may otherwise be required to post.
How can your lawyer run the whole case while you stay home?
In most tenfiz cases you never set foot in a Turkish courtroom. A power of attorney (vekâletname) is the document that lets a lawyer admitted to a Turkish bar file and conduct the case for you — attend hearings, receive the judgment, and take it through to execution.
You can sign it before a Turkish notary if you are in Türkiye. If you are abroad, you have two clean routes: sign at a Turkish consulate, which issues the power of attorney ready for use here, or sign before a local notary and then have it apostilled and translated.
Is the document set different for an arbitral award or a foreign divorce?
The five documents are the backbone in every case, but the legal track — and one or two documents — change depending on what you hold.
| What you hold | Legal route | Documents to note |
|---|---|---|
| Foreign court judgment | Enforcement or recognition, MÖHUK arts. 50–59 | Final judgment + finality annotation |
| Foreign arbitral award | 1958 New York Convention + MÖHUK arts. 60–63 | The award and the arbitration agreement |
| Foreign divorce | MÖHUK art. 58, or Law No. 5490 art. 27/A | Final divorce decree; the registry route may need no court case |
An arbitral award runs on a different regime. It is governed by the 1958 New York Convention, to which Türkiye is a party, alongside MÖHUK arts. 60–63 — not the court-judgment articles. In practice you file the award together with the arbitration agreement, both authenticated (apostilled where applicable) and accompanied by sworn Turkish translations. The grounds to refuse an award are narrower than for a court judgment and are set out in MÖHUK art. 62, mirroring the Convention — they include public policy (kamu düzeni). Our guide to enforcing a foreign arbitral award under the New York Convention goes deeper.
A foreign divorce often needs no court case at all. Since 2017, the Population Services Act (Law No. 5490), art. 27/A, lets you register a foreign divorce directly through the civil registry or a Turkish consulate when the conditions are met; otherwise you seek recognition (tanıma) under MÖHUK art. 58 before a family court. Either way the documents centre on the final divorce decree, its apostille and a sworn translation. This is a field of its own — see our divorce and family law service for how the registry route works.
What else affects your filing, and what is the checklist?
Two practical points before you assemble the file, then the checklist.
Security for costs. As a foreign claimant, you may be asked to post security for costs (yabancılık teminatı) under the Code of Civil Procedure (HMK, art. 84), unless a treaty or a reciprocity exemption applies. Your lawyer can check whether an exemption covers your country before you file.
After you win. A tenfiz judgment is executed against assets in Türkiye through the enforcement offices under the Enforcement and Bankruptcy Act (İİK, Law No. 2004) — another reason the power of attorney should already cover execution. As estimates only (never a promise), an uncontested tenfiz commonly runs around 6–10 months at first instance, a contested one 12–24 months, and administrative divorce registration weeks to a few months.
Your pre-filing checklist:
- The final judgment or award, with its finality annotation (kesinleşme şerhi).
- An apostille on the judgment and the finality page — or consular legalisation if your country is outside the Hague Convention.
- A sworn Turkish translation of every document, including the apostille.
- Your identity or company registry documents, plus signing authority, apostilled and translated.
- A power of attorney (vekâletname) for a Türkiye-bar lawyer, signed at a Turkish consulate or apostilled — covering both the case and execution.
- For an award, add the arbitration agreement. For a divorce, check first whether the registry route avoids a court case.
If your judgment comes from the United States, our US Desk handles finality, apostille and reciprocity questions for US-origin matters. Getting the documents in order is where a cross-border case is won or lost — long before any hearing.
This article is general information about Turkish law and is not legal advice; for advice on your specific situation, consult a qualified lawyer.
The court-judgment track: enforcement of a final foreign judgment (art. 50), the competent court and venue (art. 51), the enforcement conditions including reciprocity, public policy and the service check on default judgments (art. 54), the simplified procedure (art. 55), and recognition, which applies those conditions without the reciprocity requirement (art. 58).
The separate track for foreign arbitral awards alongside the 1958 New York Convention, with the closed list of refusal grounds — including public policy — in art. 62.
Since 2017, allows a foreign divorce to be registered directly through the civil registry or a Turkish consulate when the conditions are met, instead of a recognition case.
Governs the execution offices through which a tenfiz judgment is enforced against assets in Türkiye — which is why the power of attorney should already cover execution.
Get your file in order
Almost every delay in a tenfiz case starts with a document that arrives incomplete, unstamped or untranslated. Work through this list before your first conversation; the power of attorney itself is arranged with your lawyer afterwards.
Frequently asked questions
Do I need to travel to Türkiye for a tenfiz case?
Usually no. A power of attorney (vekâletname) lets a Türkiye-bar lawyer file and run the case for you, and because a tenfiz action is heard under a simplified procedure and the court does not re-try the facts, your physical presence is generally not required. You can sign the power of attorney at a Turkish consulate abroad, or before a local notary and then have it apostilled and translated.
My judgment was entered in the defendant's absence. Can it still be enforced?
Possibly. A default judgment is not barred outright, but under MÖHUK art. 54 the Turkish court checks that the defendant was properly served and had a genuine chance to defend. If you can show proper service, that objection usually falls away; without it, the case is more likely to be contested. No outcome can be promised.
What if my country does not issue a finality certificate?
This is common and workable. The finality requirement belongs to Turkish law, so where the origin court has no standard finality stamp, a lawyer helps you obtain an equivalent confirmation — from the court or clerk — that the judgment is no longer subject to ordinary appeal, then has it apostilled and translated. Sorting this out early prevents the most frequent delay.
Do foreign claimants have to post security for costs?
Often, yes. Under the Code of Civil Procedure (HMK, art. 84), a claimant who is a foreign national may be required to post security for costs (yabancılık teminatı), unless a treaty or a reciprocity exemption applies. Your lawyer can check whether an exemption covers your country before you file.
How long does a tenfiz case take?
As an estimate only, an uncontested enforcement action commonly takes around 6–10 months at first instance, while a contested one can run 12–24 months. Administrative registration of a foreign divorce is usually faster — weeks to a few months. Timelines depend on the court and the other side and cannot be guaranteed.
Do I need enforcement (tenfiz), or is recognition (tanıma) enough?
It depends on what you want to do with the ruling. Choose enforcement (tenfiz) when you need to execute it in Türkiye — for example, to seize assets. Choose recognition (tanıma) when you only need the foreign decision accepted as legally settled, such as a status or a finding; recognition does not require reciprocity (MÖHUK art. 58). The core documents are the same either way.
