Recognition & Enforcement of Foreign Judgments in Türkiye

Recognition or enforcement — which one do you need?

Start here, because it decides everything that follows. A foreign judgment is not automatically valid in Türkiye. Whatever a court in London, New York or Dubai decided, no Turkish bank, land registry or enforcement office will act on it until it has been put through one of two processes.

The conditions to enforce a foreign court judgment

A Turkish court will enforce a final, binding foreign court judgment on a civil matter if a short list of conditions is met — and, crucially, it will not re-try your case.

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. 54, a Turkish court enforces the judgment where:

• there is reciprocity between Türkiye and the state that gave the judgment — by treaty, by statute, or in de facto practice;
• the matter is not within the exclusive jurisdiction of the Turkish courts;
• the judgment is not manifestly contrary to Turkish public policy (kamu düzeni) — the core values of the Turkish legal order; and
• the defendant's right to a proper defence and proper service was respected.

What the court does not do matters just as much. Under MÖHUK Art. 55 the action is heard under the simplified procedure (basit yargılama usulü), and the court does not re-examine the merits — there is no fresh trial of who was right (no révision au fond). It checks the gatekeeping conditions above, nothing more.

The action is filed at the civil court of first instance (asliye hukuk mahkemesiAsliye hukuk mahkemesiCivil court of first instanceThe general civil court that hears most disputes not assigned to a specialised court.Glossary →) where the party against whom enforcement is sought lives; if that party has no home in Türkiye, at a court in Ankara, İstanbul or İzmir; and a commercial matter goes to the commercial court of first instance (MÖHUK Art. 51).

Reciprocity — the condition that usually decides a commercial case

Of the four conditions, reciprocity is the one that most often makes or breaks a commercial enforcement. It asks a simple question: would the courts of the country that issued your judgment enforce a comparable Turkish judgment?

Under MÖHUK Art. 54, reciprocity can exist in three ways:

• By treaty — a bilateral or multilateral agreement between Türkiye and the state of origin;
• By statute — the other country's own law provides for enforcing Turkish judgments; or
• De facto — in actual practice, that country's courts do enforce Turkish judgments, even without a treaty.

Reciprocity is assessed case by case, on the current position between Türkiye and your country — it is not a fixed list. We check where your country stands before you commit to a filing. If your judgment comes from the United States, our US Desk covers the reciprocity question for US judgments directly; more broadly, see reciprocity and where your country stands.

Foreign arbitral awards — the smoother New York Convention route

If you hold an arbitral award rather than a court judgment, you are often in a stronger position. Türkiye is a party to the 1958 New York Convention, and foreign awards travel on that treaty — with narrower grounds to refuse than court judgments face.

A Turkish court will not review the merits of the arbitration. It may refuse enforcement only on the limited grounds in New York Convention Art. V, essentially:

• the arbitration agreement was invalid, or a party lacked capacity;
• a party was not given proper notice or could not present its case;
• the award goes beyond what was submitted to arbitration;
• the tribunal or the procedure was irregular;
• the award has been set aside or suspended at the seat;
• the subject matter is not arbitrable; or
• enforcement would be contrary to public policy.

There is no reciprocity requirement, and the court checks only these narrow gates. The action is filed at the asliye court the parties agreed on; failing that, at the debtor's Turkish home; failing that, where enforceable assets are (MÖHUK Arts. 60-61).

Recognising a foreign divorce or personal status

A foreign divorce — or a similar personal-status judgment — usually needs recognition, not enforcement, and there are two ways to get it in Türkiye.

• Court recognition (tanıma) before a Turkish family court under MÖHUK Art. 58, which does not require reciprocity; or
• The administrative route — since 2017, under the Population Services Act (Law No. 5490), Art. 27/A, a foreign divorce can be registered directly in the Turkish population register through the civil registry or a Turkish consulate, when the conditions are met, without a court case.

Which route fits depends on your documents and where you live. This is its own area with its own paperwork, so our divorce and family law team handles it end to end. A foreign inheritance or succession ruling can likewise need recognition before anyone acts on it here — see our inheritance service and the guide on recognising a foreign inheritance ruling.

What we do — end to end, run remotely

You do not need to come to Türkiye. Under 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 →), a Türkiye-bar lawyer can run the entire recognition or enforcement case for you, from filing to collection.

• Assess first. We test your judgment or award against the conditions above, and — for court judgments — check where your country stands on reciprocity, before you spend on a filing.
• Get the paperwork right. Finality, apostille and sworn translation, in the exact form a Turkish court will accept (see the next section).
• File and argue. We bring the tanıma or tenfiz action in the correct court and run it under the simplified procedure.
• Defend, if that is your side. If you are resisting enforcement of a foreign judgment or award, we act for the debtor.
• Collect. Once we hold a tenfiz judgment, we execute against assets in Türkiye through the enforcement offices under the Enforcement and Bankruptcy Act (İİK, Law No. 2004) — attaching bank accounts, real estate and receivables.

Once the judgment is Turkish-enforceable, collection is ordinary debt enforcement — the same machinery behind our debt collection and enforcement work. See how it plays out in enforcing against assets in Türkiye (İİK).

The documents you will need

Three things turn a foreign judgment or award into something a Turkish court can act on — plus the power of attorney that lets us act for you.

How long it takes

Timelines depend on whether the other side fights and how busy the court is, so treat these as estimates, not promises.

An appeal can add time, and execution against assets runs after the tenfiz judgment is granted. We cannot promise a result or a date — no lawyer honestly can — but we can tell you early how strong your case looks and keep it moving. For a deeper look, see how long it takes and what it costs. When you are ready, send us the judgment or award and we will assess it.

This article is general information about Turkish law and is not legal advice; for advice on your specific situation, consult a qualified lawyer.

How we make your foreign judgment count in Türkiye

Recognition & enforcement in Türkiye — FAQ

Which countries have a bilateral treaty with Türkiye?

This is the Ministry of Justice's own list of the states with which Türkiye has a bilateral treaty in civil and commercial matters. Read it as an answer to “is there a treaty relationship at all?” — not to “will my judgment be enforced?”. A judicial-assistance treaty governs service of documents and the taking of evidence; whether it also governs recognition and enforcement depends on that treaty’s own scope, which is why the middle column reports only what each treaty’s official title covers. Reciprocity can also rest on a statutory provision or on de facto practice, and the court assesses it at the time of your case.

Source: T.C. Adalet Bakanlığı — Dış İlişkiler ve Avrupa Birliği Genel Müdürlüğü — 2026-07-26.