Recognition vs Enforcement in Türkiye: Tanıma or Tenfiz?
You won your case abroad, and now you need that win to count in Türkiye. 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 →) gives a foreign judgment legal effect as proof and as a final, settled matter; enforcement (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 →) goes further and lets you actually collect — seizing assets the way a Turkish judgment would. Which one you need depends entirely on what you plan to do with the judgment: register a change of status, or act against money and property. This guide explains the difference in plain terms, with a worked example of each. Both go through a Turkish court under the same core conditions — with one key exception we come to below.
What's the real difference between recognition (tanıma) and enforcement (tenfiz)?
In short: recognition (tanıma) makes a foreign judgment count in Türkiye (Turkey) as evidence and as a settled matter, while enforcement (tenfiz) goes one step further and makes it work — executable like a Turkish judgment, so you can act against assets.
Recognition means Turkish authorities and courts treat the foreign judgment as a final, binding fact — for example, that you are divorced, or that a certain claim has already been decided. Enforcement means you can hand the judgment to Türkiye's enforcement offices and have them seize bank accounts, property or other assets to satisfy it. Every enforcement carries recognition inside it; recognition on its own does not carry the power to seize.
| Question | Recognition (tanıma) | Enforcement (tenfiz) |
|---|---|---|
| What it does | Gives the judgment effect as proof and as a final, settled matter (res judicata) | Everything recognition does, plus makes the judgment executable in Türkiye like a Turkish judgment |
| Can you seize assets? | No | Yes — through the enforcement offices |
| Typical use | Register or rely on a status or fact (e.g. a divorce) | Collect a money judgment; act against property |
| Reciprocity required? | No (MÖHUK art. 58) | Yes (MÖHUK art. 54) |
| Governing articles | MÖHUK arts 58–59 | MÖHUK arts 50–57 |
| Merits re-tried? | No | No (MÖHUK art. 55) |
You can see how both fit into the wider process on our recognition and enforcement of foreign judgments service page.
Which of these is your situation?
What does recognition (tanıma) give you on its own?
Recognition (tanıma) gives a foreign judgment res judicata and evidentiary effect in Türkiye — meaning it is treated as a final, settled matter that cannot be re-argued, and it can be used as proof.
Practically, that lets you rely on the judgment to establish a status or a fact inside Türkiye without turning it into a collection tool. Common examples are:
- Having a foreign divorce reflected in the Turkish population register.
- Relying on a foreign ruling as settled proof in another Turkish proceeding.
- Confirming a decided family-law or personal-status point so a Turkish authority will act on it.
What recognition does not do: it does not let you seize anything. If you also need to take money or property, recognition alone will not get you there — you need enforcement.
What does enforcement (tenfiz) add that recognition does not?
Enforcement (tenfiz) does everything recognition does and adds the crucial piece: it makes the foreign judgment executable in Türkiye, exactly as if a Turkish court had issued it.
Once a Turkish court grants tenfiz, the judgment becomes an enforceable title. You can then instruct the enforcement offices (icra daireleri) to act — freezing and seizing bank accounts, real estate, vehicles or receivables — to satisfy the debt.
So the mental model is simple: recognition proves your judgment; enforcement lets you use it to collect. If your reason for coming to Türkiye is to get paid, tenfiz is the route.
How do you decide which one you actually need?
Start from what you want to do with the judgment, not from the judgment itself.
- If your goal is to register or rely on a status or fact — you are divorced, a family-law point is settled — recognition (tanıma) is usually enough.
- If your goal is to get paid or take something — collect a money judgment, seize property or accounts — you need enforcement (tenfiz).
Is reciprocity required for both recognition and enforcement?
No — and this is the single most important exception to remember. Reciprocity is required to enforce (tenfiz), but not to recognise (tanıma).
Reciprocity means Türkiye and the country where your judgment was given each honour the other's judgments. It can exist through a treaty, through matching statutes, or through established practice in fact (de facto).
The practical effect: even if there is no reciprocity with the country that issued your judgment, you may still be able to have it recognised as proof — you just cannot use it to seize assets. To see how reciprocity is assessed for your jurisdiction, read our guide on reciprocity and where your country stands.
A judgment from my country is automatically valid in Türkiye, the way judgments travel between EU states.
It is not. A foreign judgment takes effect in Türkiye only through a Turkish court, by recognition (tanıma) or enforcement (tenfiz). The one exception is a foreign divorce, which can also be registered administratively under the Population Services Act (Law No. 5490), art. 27/A.
The Turkish court will hear the whole dispute again, so the other side gets a second chance on the facts.
Under 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. 55 the case is heard under the simplified procedure (basit yargılama usulü) and the court does not review the merits of the foreign decision. It checks the conditions in MÖHUK art. 54 — reciprocity for enforcement, exclusive Turkish jurisdiction, public policy, and proper service and defence rights — not whether the foreign court decided rightly.
There is no reciprocity between Türkiye and my country, so there is nothing I can do here.
Reciprocity is a condition for enforcement (MÖHUK art. 54), not for recognition (MÖHUK art. 58). Even without reciprocity you may still have the judgment recognised as proof and as a settled matter — you simply cannot use it to seize assets.
Once my judgment is recognised in Türkiye, I can start collecting.
Recognition gives the judgment res judicata and evidentiary effect only. To reach bank accounts, real estate, vehicles or receivables you need enforcement (tenfiz); every enforcement contains recognition inside it, but recognition on its own carries no power to seize.
Can you show a worked example of each?
Yes — the difference is easiest to feel with two real-world situations.
Example 1 — a foreign divorce you just need recognised. You divorced abroad and simply need Türkiye to treat you as divorced, so your marital status in the population register (nüfus) is correct. You are not seizing anything, so you do not need enforcement — recognition (tanıma) is enough. In many cases a divorce can also be registered directly through the administrative route under the Population Services Act (Law No. 5490), art. 27/A, at the civil registry or a Turkish consulate, without a court case at all, when the conditions are met. Because personal status carries its own rules, our divorce and family law team handles this path.
Example 2 — a money judgment you need to enforce. A foreign court ordered a company in Türkiye to pay you. Recognition alone will not get you paid — you need the judgment to become executable so you can act against the debtor. That is enforcement (tenfiz). Once the Turkish court grants it, you can move against the debtor's assets through the enforcement offices, as explained in our guide to enforcing against assets in Türkiye.
Do the same labels apply to arbitral awards?
People use the everyday words "recognition" and "enforcement" for arbitral awards too — but a foreign arbitral award follows a different legal regime, so do not apply the court-judgment articles to it.
The main route for a foreign arbitral award is the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, to which Türkiye is a party; MÖHUK arts 60–63 also govern enforcement of foreign awards in Türkiye. The grounds a court can rely on to refuse are narrower than for court judgments — essentially those in New York Convention Art. V (for example, an invalid arbitration agreement, improper notice, an award that goes beyond what was submitted, an irregular tribunal, an award set aside at the seat, a non-arbitrable subject, or enforcement contrary to public policy). MÖHUK art. 62 lists the corresponding grounds, including public policy under art. 62/1-b.
What do both routes share, and how do you start?
Apart from reciprocity, recognition and enforcement of a court judgment share the same core conditions and the same basic process.
Under MÖHUK art. 54, a Turkish court checks that: (a) there is reciprocity with the state of origin (for enforcement only); (b) the judgment is not on a matter within the exclusive jurisdiction of the Turkish courts; (c) the judgment is not manifestly contrary to Turkish public policy (kamu düzeni) — the country's fundamental legal principles; and (ç) the defendant's right to a proper defence and due service was not violated.
Importantly, the court does not re-try your case. Under MÖHUK art. 55 the action is heard under the simplified procedure (basit yargılama usulü), and the court does not review the merits of the foreign decision. It checks the conditions above — not whether the foreign court decided rightly. To go deeper on each requirement, see the conditions to enforce a foreign judgment.
A few practical points apply to both routes:
- Where you file. Under MÖHUK art. 51, the civil court of first instance at the Turkish domicile or residence of the party you are proceeding against — or, if none in Türkiye, a court in Ankara, İstanbul or İzmir; a commercial matter goes to the commercial court of first instance.
- Documents. The judgment must be final (kesinleşmiş, with a finality annotation), apostilled under the 1961 Hague Convention or consular-legalised, and accompanied by a sworn Turkish translation.
- You need not travel. A power of attorney (vekâletname) lets a Türkiye-bar lawyer run the whole case for you.
- Security for costs. A foreign claimant may have to post security for costs (yabancılık teminatı) under the Code of Civil Procedure (HMKHMKCode of Civil Procedure No. 6100The rulebook for how a civil case actually runs in Türkiye — which court, which steps, which deadlines, and what evidence counts.Glossary →), art. 84, unless a treaty or reciprocity exemption applies.
As for timing, these are estimates only, never a promise: an uncontested enforcement case often runs around 6–10 months at first instance, contested cases longer (roughly 12–24 months), and administrative divorce registration can take weeks to a few months. If you would like your situation reviewed, you can tell us about your matter and we will explain which route fits.
This article is general information about Turkish law and is not legal advice; for advice on your specific situation, consult a qualified lawyer.
Sets both routes: enforcement in arts 50–57, recognition in arts 58–59, the shared conditions in art. 54, the court in art. 51, and no review of the merits under art. 55.
Once a Turkish court has granted tenfiz, execution against the debtor's assets runs through the enforcement offices under this Act.
Allows a foreign divorce to be registered administratively at the civil registry or a Turkish consulate, without a court case, where the conditions are met.
What to gather before you take advice
These are documents and facts you can put together yourself. With them in hand, the choice between tanıma and tenfiz is usually settled at the outset.
Frequently asked questions
Is a foreign judgment automatically valid in Türkiye?
No. A foreign judgment does not take effect on its own — it needs a Turkish court, either through recognition (tanıma) or enforcement (tenfiz). The one exception is a foreign divorce, which can also be registered through the administrative route under the Population Services Act (Law No. 5490), art. 27/A.
Do I need enforcement (tenfiz) if I only want my foreign divorce recognised?
Usually not. Recognition (tanıma) is normally enough to have your marital status reflected in Türkiye, and in many cases the administrative route under Law No. 5490, art. 27/A, avoids a court case altogether. You would only need enforcement if the divorce judgment also orders something to be executed against assets that you want to collect.
Does a lack of reciprocity block recognition?
No. Reciprocity is a condition for enforcement (tenfiz) under MÖHUK art. 54, but recognition (tanıma) under art. 58 does not require it. So even where reciprocity is missing, you may still have the judgment recognised as proof — you simply cannot use it to seize assets.
Will the Turkish court re-examine whether the foreign judgment was correct?
No. Under MÖHUK art. 55 the case is heard under the simplified procedure and the court does not re-try the merits of the foreign decision. It checks the conditions in MÖHUK art. 54 — such as public policy and proper service — not whether the foreign court reached the right result.
Do I have to travel to Türkiye for the case?
Not necessarily. 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 →) lets a Türkiye-bar lawyer run the whole matter for you. The judgment must be final, apostilled or consular-legalised, and come with a sworn Turkish translation.
How long does the process take?
These are estimates only, and no date or outcome can be promised. An uncontested enforcement case often runs about 6–10 months at first instance, contested cases roughly 12–24 months, and administrative divorce registration can take from a few weeks to a few months.
