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Avukat Emirhan Keskin
Author: Attorney Emirhan KeskinPublished: Updated: General legal information

International legal services in Türkiye › Foreign judgments and awards

Enforcement of Foreign Judgments in Turkey: Recognition and Procedure

About the author and office

Attorney Emirhan Keskin

Prepares legal information on proceedings in Türkiye and provides legal services from Mersin. Content is reviewed against current official Turkish sources.

Mersin Bar Association · Registration No. 5507

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This publication provides general information on Turkish law as of its stated review date. It does not create an attorney–client relationship; documents, time limits, jurisdiction and current rules require a matter-specific assessment.

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Direct answer: Enforcement of foreign judgments in Turkey generally requires a Turkish court to issue an enforcement decision before compulsory execution can begin. Recognition may be sufficient where the foreign judgment will only be relied on as conclusive evidence or to establish its legal effect. The correct route depends on the relief granted, finality, service on the defendant, applicable treaties and the requirements of Turkish private international law.

Enforcement of foreign judgments in Turkey
Foreign judgments and arbitral awards require separate legal and document reviews before execution in Türkiye.

This guide is intended for foreign companies, creditors and individuals who already have a court decision outside Türkiye or are considering proceedings abroad against a person or company with assets in Türkiye. A favourable foreign judgment does not by itself authorise a Turkish enforcement office to seize assets. The decision, procedural history and intended use in Türkiye must first be examined.

Recognition and enforcement: what is the difference?

Recognition gives a qualifying foreign judgment legal effect in Türkiye. It may be sought when the applicant needs to rely on the judgment as conclusive evidence or as a final adjudication, but does not need compulsory execution of a payment or performance order.

Enforcement makes the enforceable part of a foreign judgment capable of compulsory execution in Türkiye. It is usually relevant to monetary awards, delivery obligations or another order requiring performance. Once the Turkish enforcement decision becomes enforceable, the creditor may proceed under Turkish execution rules, subject to the nature of the claim and the debtor's available assets.

For foreign judgments, the distinction matters. Filing the wrong application can add cost and delay, while some disputes require recognition for one legal effect and enforcement for another.

Legal framework for enforcement of foreign judgments in Turkey

The principal domestic framework is the Turkish Code on Private International Law and International Civil Procedure, Law No. 5718. International conventions to which Türkiye is a party may also apply and can change the document or procedural analysis. The current text of Law No. 5718 should be checked through the official Turkish legislation database.

The Turkish court does not normally conduct a new trial on the underlying merits merely because one party disagrees with the foreign court's factual or legal assessment. Its review focuses on the statutory recognition and enforcement conditions, the documents submitted and properly raised objections. This is not a substitute for case-specific analysis: family judgments, insolvency matters, interim orders and decisions involving exclusive Turkish jurisdiction may require different treatment.

Core conditions examined by the Turkish court

Depending on the judgment, country of origin and any applicable treaty, the court may examine matters including:

  • whether the decision was issued by a foreign court and concerns a civil-law matter;
  • whether the judgment has become final under the law of the country where it was issued;
  • whether reciprocity exists for enforcement where Turkish law requires it;
  • whether the decision concerns a matter within the exclusive jurisdiction of Turkish courts;
  • whether the foreign court assumed an excessive basis of jurisdiction in the circumstances, if the relevant objection is made;
  • whether enforcement would be manifestly contrary to Turkish public policy;
  • whether the party against whom enforcement is requested was duly summoned and represented, or whether defence rights were otherwise respected; and
  • whether a properly raised objection shows that the judgment was satisfied, prevented from being enforced or otherwise affected after it was issued.

These points are document-sensitive. For example, a finality certificate does not necessarily prove proper service, and proof of service may not establish that the judgment is final. For foreign judgments, both the wording and the issuing authority of each document should be reviewed before filing.

Documents commonly required

An initial assessment of foreign judgments usually begins with electronic copies. A court filing commonly requires formally acceptable versions of some or all of the following:

  1. the complete foreign judgment, including its operative part;
  2. a document or annotation showing that the judgment is final and, where relevant, enforceable in the country of origin;
  3. documents showing service of the proceedings and the judgment on the opposing party;
  4. certified Turkish translations prepared in the form accepted by the Turkish court;
  5. apostille or consular legalisation where required;
  6. a power of attorney suitable for Turkish court proceedings;
  7. corporate authority and registry documents if the applicant is a company; and
  8. payment, settlement or enforcement records relevant to the outstanding amount.

Apostille is not a universal answer. The issuing country, applicable convention, type of document and Turkish authority receiving it determine whether apostille, consular legalisation or another certification route is needed. It is often safer to confirm the required form before ordering translations or sending originals.

How the procedure usually progresses

  1. Pre-filing review: the judgment, finality, service, jurisdiction, parties and intended enforcement target are checked.
  2. Document preparation: certified copies, apostille or legalisation, translations and the power of attorney are arranged as required.
  3. Application to the competent Turkish court: venue and jurisdiction are determined under the applicable rules and the known Turkish connection.
  4. Service and response: the opposing party is notified and may raise objections within the procedural framework.
  5. Court decision and review: the court decides whether the statutory conditions are met; appellate review may follow.
  6. Execution: after an enforceable Turkish decision is available, the creditor may use the appropriate Turkish enforcement route.

Timing for foreign judgments cannot be stated reliably without knowing the country of origin, service address, objection history, court workload and whether an appeal is filed. Translation, notification abroad, expert review and incomplete finality documents are common sources of delay.

Enforcement is not the same as collecting the debt

An enforcement order gives the judgment the required legal effect in Türkiye, but recovery still depends on identifying the correct debtor and reachable assets. Company status, registered property, vehicles, bank relationships, receivables, security and insolvency information may affect strategy. Where the underlying problem is an unpaid invoice or contract debt, see the related guide to debt collection in Türkiye.

Urgent protective measures are separate from the final enforcement decision. If there is a concrete risk of asset dissipation, the available interim measures, evidentiary threshold and possible security requirement should be assessed without assuming that relief will be automatic.

Foreign arbitral awards follow a separate route

A foreign arbitral award is not treated as an ordinary foreign court judgment. The 1958 New York Convention and Turkish legislation may govern recognition and enforcement. Türkiye is a contracting state, subject to its recorded reservations. The official UNCITRAL New York Convention status table identifies Türkiye's treaty status. The dedicated foreign arbitral award enforcement in Turkey guide covers treaty selection, documents, refusal grounds and execution.

The arbitration agreement, authenticated award, proper notice, scope of the submission to arbitration, final or binding status, arbitrability and public policy may become relevant. A creditor should not assume that documents prepared for a court judgment application will also satisfy the requirements for an arbitral award.

Can the matter be handled remotely?

Many files involving foreign judgments can be assessed and prepared without the client travelling to Türkiye. Documents can be sent electronically for preliminary review. Where appropriate, representation may be authorised by a power of attorney issued through a Turkish consulate or a competent foreign authority, with apostille or legalisation and translation as required. Personal attendance may still become necessary in exceptional circumstances, depending on the case and the court's directions.

Frequently asked questions

Can a foreign judgment be sent directly to a Turkish enforcement office?

Generally not. A foreign court judgment normally needs the required Turkish recognition or enforcement decision before compulsory execution can begin. Treaty-specific rules and the nature of the decision must still be checked.

Will the Turkish court retry the entire dispute?

The recognition and enforcement court generally does not rehear the merits as an ordinary appeal court. It reviews the statutory conditions, submitted documents and relevant objections. Public policy review is not intended to become a full merits retrial.

Is a translated PDF enough to start the case?

A PDF may be enough for an initial assessment, but filing normally requires documents in a formally acceptable form. Certified copies, finality and service records, sworn translations and apostille or legalisation may be required.

What if the defendant was never properly notified abroad?

Defence rights and proper notice can be decisive. The method, address, date and legal basis of service should be reviewed together with the foreign court record and any participation by the defendant.

Can only part of a judgment be enforced?

Partial enforcement may be possible where the enforceable part can be separated and the legal conditions are met. Interest, costs, non-monetary orders and other parts of the operative section should be assessed individually.

Recognition and enforcement: what is the difference?

Recognition gives a qualifying foreign judgment legal effect in Türkiye. It may be sought when the applicant needs to rely on the judgment as conclusive evidence or as a final adjudication, but does not need compulsory execution of a payment or performance order. Enforcement makes the enforceable part of a foreign judgment capable of compulsory execution in Türkiye. It is usually relevant to monetary awards, delivery obligations or another order requiring performance. Once the Turkish enforcement decision becomes enforceable, the creditor may proceed under Turkish execution rules, subject to the nature of the claim and the debtor's available assets.

What legal rule applies to Legal framework for enforcement of foreign judgments in Turkey?

The principal domestic framework is the Turkish Code on Private International Law and International Civil Procedure, Law No. 5718. International conventions to which Türkiye is a party may also apply and can change the document or procedural analysis. The current text of Law No. 5718 should be checked through the official Turkish legislation database. The Turkish court does not normally conduct a new trial on the underlying merits merely because one party disagrees with the foreign court's factual or legal assessment. Its review focuses on the statutory recognition and enforcement conditions, the documents submitted and properly raised objections. This is not a substitute for case-specific analysis: family judg

What legal rule applies to Core conditions examined by the Turkish court?

Depending on the judgment, country of origin and any applicable treaty, the court may examine matters including: whether the decision was issued by a foreign court and concerns a civil-law matter; whether the judgment has become final under the law of the country where it was issued; whether reciprocity exists for enforcement where Turkish law requires it; whether the decision concerns a matter within the exclusive jurisdiction of Turkish courts; whether the foreign court assumed an excessive basis of jurisdiction in the circumstances, if the relevant objection is made; whether enforcement would be manifestly contrary to Turkish public policy; whether the party against whom enforcement is requested was duly sum

What legal rule applies to Documents commonly required?

An initial assessment of foreign judgments usually begins with electronic copies. A court filing commonly requires formally acceptable versions of some or all of the following: the complete foreign judgment, including its operative part; a document or annotation showing that the judgment is final and, where relevant, enforceable in the country of origin; documents showing service of the proceedings and the judgment on the opposing party; certified Turkish translations prepared in the form accepted by the Turkish court; apostille or consular legalisation where required; a power of attorney suitable for Turkish court proceedings; corporate authority and registry documents if the applicant is a company; and paymen

What legal rule applies to How the procedure usually progresses?

Pre-filing review: the judgment, finality, service, jurisdiction, parties and intended enforcement target are checked. Document preparation: certified copies, apostille or legalisation, translations and the power of attorney are arranged as required. Application to the competent Turkish court: venue and jurisdiction are determined under the applicable rules and the known Turkish connection. Service and response: the opposing party is notified and may raise objections within the procedural framework. Court decision and review: the court decides whether the statutory conditions are met; appellate review may follow. Execution: after an enforceable Turkish decision is available, the creditor may use the appropriate

Request an initial document review

For an initial assessment, send the complete judgment, finality and service documents, a short chronology, the parties' full legal names, the outstanding amount and any information about assets or proceedings in Türkiye. Avukat Emirhan Keskin's office is based in Mersin and assists international clients with Turkish proceedings according to the agreed scope.

Telephone / WhatsApp: +90 552 224 43 66
Email: avukatemirhankeskin@gmail.com

General information only. Recognition, enforcement and execution depend on the specific judgment, treaties, documents and current Turkish law.

Foreign judgments in Türkiye: recognition, enforcement and execution

A foreign judgment can become relevant in Türkiye in three different ways. Recognition allows the foreign decision to have legal effect, for example when a status or decided issue must be relied on. Enforcement adds the authority needed for coercive execution where the decision orders payment or performance. Execution then takes place through the competent Turkish enforcement system against reachable assets. Success at one stage does not establish that assets exist at the next.

The requested Turkish remedy should match the operative part of the foreign decision. A declaratory, constitutive, monetary, injunctive, family, insolvency or costs order may require a different analysis. If only part of the decision is enforceable, partial enforcement may need to be considered. Interest, currency and costs should be identified separately rather than silently added to the foreign order.

When are foreign judgments final and enforceable?

Turkish private international law requires examination of whether the decision has become final under the law of the country where it was rendered. The required evidence is not always the same document called a “finality stamp” in another system. The foreign court, its registry or another competent authority may need to certify the decision’s status. If enforcement is provisionally available abroad despite an appeal, Turkish treatment requires specific review.

The complete operative decision and finality evidence should be obtained, not only a case summary, online docket printout or lawyer’s letter. If the judgment was corrected, supplemented or interpreted, those later orders may be part of the package. Dates and case numbers must be consistent across the original, certificates, apostille or legalisation and translation.

Jurisdiction questions for foreign judgments

The Turkish court does not ordinarily retry the merits, but it examines the statutory enforcement conditions. One question is whether the foreign decision concerns a matter within exclusive Turkish jurisdiction. Another is whether, following a defendant’s objection, the foreign court assumed jurisdiction through a connection that the statute treats as unacceptable in the circumstances. Contractual jurisdiction or arbitration terms and the defendant’s participation can be relevant.

These issues cannot be resolved from the country name alone. The subject matter, defendant’s domicile, place of performance, property location, contractual clause and procedural history should be mapped. A foreign judgment concerning Turkish real property, corporate registers, status or another regulated matter can raise distinct competence questions.

Service and defence rights in foreign judgments

Proper service is one of the most contested parts of cross-border enforcement. The Turkish court may examine whether the defendant was duly summoned or represented under the law of the foreign forum and whether the decision was rendered consistently with defence rights. A certificate stating only that service occurred may be insufficient if the defendant produces a specific objection supported by the record.

The file should include the originating claim, summons, service certificates, translations used abroad, address evidence, appearance documents and any default-judgment notices relevant to finality. Service by post, electronic means, publication or an agent should be assessed under the applicable foreign law and any convention. A Turkish defendant’s awareness of a commercial dispute does not automatically prove proper procedural notice.

Public-policy review of foreign judgments

Turkish public policy can prevent enforcement where the result or procedure is manifestly incompatible with fundamental Turkish legal principles. It is not a general opportunity to argue that the foreign judge misunderstood evidence or foreign law. The distinction between a merits complaint and a genuine public-policy issue should be maintained.

Punitive or multiple damages, due process, prohibited subject matter, inconsistent status decisions or effects on fundamental rights may require careful analysis depending on the case. The Turkish court examines the concrete effect of enforcement, not an abstract comparison between legal systems. Assertions should be tied to the judgment and record.

Reciprocity and treaty analysis

For enforcement of foreign court judgments, reciprocity may be established through a treaty, statutory rule or de facto practice according to Turkish law. It should not be assumed merely because both countries recognise judgments in some circumstances. The type of judgment and current practice matter. Bilateral agreements and multilateral conventions may modify the document or substantive analysis for specific subjects.

Treaty research should identify whether the instrument is in force between the two states, its material scope, reservations and required channel. Family, maintenance, commercial, civil-status and service conventions do not necessarily cover the same questions. The most specific applicable instrument should be read together with Law No. 5718.

Documents required for foreign judgments

  • complete certified copy of the foreign judgment, including its operative part;
  • official evidence that the judgment is final under the law of origin;
  • originating claim, summons and service records where defence rights may be disputed;
  • records showing representation, appearance or default;
  • any correction, appeal, suspension or satisfaction decision;
  • apostille, consular legalisation or treaty certification as applicable;
  • sworn Turkish translations and required notarial certifications;
  • party registry and address information for Turkish proceedings;
  • calculation of unsatisfied principal, interest, currency and costs; and
  • information about Turkish assets and any urgent preservation risk.

Before translating a large record, Turkish counsel should identify the minimum legally necessary package and any portions likely to become contested. Under-translation can cause rejection or delay, while unnecessary translation of an extensive foreign file increases cost without assisting the statutory review.

Security, court fees and service in Türkiye

A foreign claimant may face a security requirement under Article 48 of Law No. 5718 unless a treaty, reciprocity or another applicable basis supports exemption. Security for being a foreign party is different from security for an interim measure. The claimant’s nationality or place of incorporation and applicable international instruments should be reviewed before budgeting.

Court fees, translation, experts, service and enforcement expenses are determined under current rules. Fixed figures become outdated and should be calculated when filing. The respondent must be served through the correct Turkish or international route. An old registry address should not be accepted without verification.

Interim measures before the enforcement decision

A creditor may be concerned that Turkish assets will be transferred while the enforcement case is pending. Interim attachment or another measure is not automatic merely because a foreign judgment exists. The statutory conditions, maturity, evidence, urgency, competent court, proportionality and security must be assessed. The foreign judgment can be significant evidence but does not remove Turkish procedural requirements.

If a measure is granted, implementation and follow-on deadlines are critical. The order should identify the asset or enforcement target with sufficient precision. An unjustified measure can create compensation exposure, so the application must distinguish documented risk from general suspicion.

Execution of foreign judgments after the Turkish decision

Once the foreign decision is declared enforceable and the Turkish decision can be used for execution, the creditor proceeds within Turkish enforcement law. The debtor’s bank receivables, real property, vehicles, company shares or third-party receivables may be relevant, subject to exemptions, ownership and priority. The foreign judgment does not give automatic priority over secured or earlier creditors.

Payments, interest and costs should be reconciled to prevent over-enforcement. If the debtor alleges that the foreign obligation was paid or extinguished, the timing and procedural route of that objection must be examined. Cross-border settlement should state how the Turkish enforcement file and foreign proceeding will be closed.

Foreign arbitral awards: a different framework

An arbitral award is not enforced as if it were a foreign court judgment. The New York Convention, Law No. 5718 and any applicable arbitration legislation must be analysed. The arbitration agreement, seat, scope, composition of the tribunal, notice, binding nature, set-aside status, arbitrability and public policy are central. The Convention limits the grounds for refusal, but the document and procedural record remain important.

The creditor should provide the award and arbitration agreement in the required authenticated form and Turkish translation. Institutional confirmation, correction decisions and proof of notice may be needed depending on the dispute. A pending set-aside application at the seat can affect timing and security but does not automatically dictate a single result.

An anonymised enforcement example

Assume a European supplier obtains a final default judgment for unpaid goods against a Turkish distributor. The judgment includes principal, contractual interest and costs. The service certificate states that the claim was mailed to an address used in the contract, while the debtor says the office had moved and it never received the proceedings.

A Turkish enforcement assessment would obtain the full claim and service record, confirm finality, examine the law and method of service, check reciprocity or an applicable treaty, prepare authenticated translations, calculate the unsatisfied amount and identify assets. It would not retry whether the goods conformed merely because the debtor now disputes the invoice, but a concrete defence-rights objection would need analysis under the statutory conditions.

Remote representation and international coordination

The claimant can usually coordinate a Turkish enforcement case from abroad through a suitable power of attorney. Corporate authority, apostille or legalisation and sworn translation may be required. One contact should coordinate the foreign court, original documents, translations, Turkish counsel and asset information.

Parallel proceedings should be disclosed. Insolvency, appeals, settlement, partial payment or enforcement in another country may affect strategy and calculations. Turkish counsel can explain Turkish procedure but should not give definitive advice about the law of origin without coordination with counsel there.

Additional frequently asked questions

Does apostille mean the judgment will be enforced?

No. Apostille authenticates a public document for cross-border use between Convention states. The Turkish court still examines the statutory enforcement conditions.

Will the Turkish court hear the entire dispute again?

Enforcement is not ordinarily a merits retrial. The court examines the limited statutory conditions and properly raised objections.

Can only part of a judgment be enforced?

Potentially, if the enforceable part can be separated and statutory conditions are met. The operative wording and requested relief must be precise.

Can a foreign injunction be enforced?

Non-monetary orders require close analysis of their nature, finality, Turkish enforceability and public-policy effects. They should not be treated as ordinary money judgments.

Official Turkish sources checked

Legal-source control date: 3 September 2026. Reciprocity, treaty status, document form, deadlines, fees and the foreign decision’s legal status must be checked for the specific file.

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